Covington & Burling LLP today released new data showing that the Department of Justice has maintained an increased level of Foreign Agents Registration Act audits,and settled into a consistent pattern of conducting 15 audits of FARA registrants each fiscal year.

In each of the last four years, the Department of Justice’s FARA office has conducted 15 audits of FARA registrants, we reported at Covington’s Corporate Political Activity & Government Affairs Compliance Conference held in Washington today.  The new data are based on information that Covington obtained from our work with the Department of Justice’s FARA office.

FARA audits have increased precipitously in the last few years.  The Department conducted no audits in 2004 through 2007, but then 13 in 2008, 14 in 2009, and 15 from 2010 through 2013.  The new data reported today supplement information obtained by the Project on Government Oversight in 2011 under a Freedom of Information Act request.

The number of FARA registrants fluctuates with time, but there are usually around 400 active FARA registrants.  With 15 audits conducted each year, each FARA registrant faces about a 4% chance of an audit each year.

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Photo of Brian D. Smith Brian D. Smith

Brian Smith provides strategic and legal advice on matters that require substantial political, reputational, or government relations considerations.  He represents companies and individuals in high-profile or high-risk investigations, particularly congressional investigations, criminal investigations with political implications, and investigations related to political law compliance. …

Brian Smith provides strategic and legal advice on matters that require substantial political, reputational, or government relations considerations.  He represents companies and individuals in high-profile or high-risk investigations, particularly congressional investigations, criminal investigations with political implications, and investigations related to political law compliance.  He has significant experience in crisis management, where he advises clients facing combined legal, political, and media relations risks.  His practice also includes the development and execution of government relations initiatives, including securing the U.S. government’s political support on behalf of U.S. companies facing international legal issues.