Washington is awash with lobbyists seeking to address new steel and aluminum tariffs, and other potential tariffs, on behalf of both foreign and domestic clients.  Lobbying on trade issues in some circumstances may trigger Foreign Agents Registration Act (“FARA”) obligations.  The connection between trade lobbying and FARA was the subject of close scrutiny several decades ago, when Congress considered the issue in a 1991 hearing.  The latest changes in U.S. trade policy are bringing this issue back into focus.  Today, Covington issued a client advisory addressing the interplay between trade lobbying and FARA, which you can read here.