Following an announcement in September that the White House intends to deploy the Foreign Agents Registration Act (“FARA”) to investigate persons with foreign ties that “foment political violence,” the FARA Unit of the Department of Justice (“DOJ”) quietly (and maybe inadvertently) published and then unpublished 17 new advisory opinions regarding
Continue Reading DOJ Posts (then Takes Down) Seventeen New Advisory Opinions Regarding the Foreign Agents Registration Act
DOJ Withdraws Dozens of Regulatory Actions, Keeps FARA NRPM
The U.S. Department of Justice (“DOJ” or the “Department”) announced that, effective September 11, 2025, it is withdrawing several dozen Notices of Proposed Rulemaking (“NPRMs”), Advance Notices of Proposed Rulemaking, and Supplemental Notices of Proposed Rulemaking. The Department explained that it is “withdrawing these actions as part of the Federal
Continue Reading DOJ Withdraws Dozens of Regulatory Actions, Keeps FARA NRPMCongress Weighs Foreign Agent Disclosure and Registration Bills
Congress is considering several bills to broaden disclosure and registration requirements related to the regulation of foreign agents under the Foreign Agents Registration Act (“FARA”) and the Lobbying Disclosure Act (“LDA”): the Foreign Registration Obligations for Nonprofit Transparency (“FRONT”) Act (S. 2305), Disclosing Foreign Influence in Lobbying Act
Continue Reading Congress Weighs Foreign Agent Disclosure and Registration BillsTexas, Louisiana, and Nebraska Enact “Baby” FARA Laws
Over the last several weeks, Texas, Louisiana, and Nebraska have enacted so called “baby” Foreign Agents Registration Act (“FARA”) laws aimed at regulating foreign-influenced political activity in the states. There has been a trend in state legislatures over the last year to propose laws that apply to foreign-influenced political activity
Continue Reading Texas, Louisiana, and Nebraska Enact “Baby” FARA LawsArkansas Governor Signs Baby FARA Law
Over the past several months, several states have introduced bills that mirror the federal Foreign Agents Registration Act (“FARA”). There has been a trend in the states to propose so-called “baby FARA” laws that apply to foreign-influenced political activity in the states, though the proposals vary in the scope of
Continue Reading Arkansas Governor Signs Baby FARA LawAttorney General Issues Memorandum Regarding FARA Criminal Enforcement
On her first day in office, Attorney General Pam Bondi issued a significant memorandum to all Department of Justice employees regarding the Department’s criminal enforcement policies, including a notable directive related to the Foreign Agents Registration Act (“FARA”). The memorandum provides that “[r]ecourse to criminal charges under the Foreign Agents
Continue Reading Attorney General Issues Memorandum Regarding FARA Criminal EnforcementDepartment of Justice Proposes Major Changes to FARA Regulations, Including Sweeping Changes Affecting Multinational Companies
On January 2, 2025, the Department of Justice published a Notice of Proposed Rulemaking
(“NPRM”) soliciting public comments on potential amendments to the Department’s regulations
regarding the Foreign Agents Registration Act (“FARA”). The regulatory amendments proposed
by the Department are significant, and they would take the statute in a substantially
A Primer for Navigating the Presidential Appointee Vetting and Confirmation Process
Following the decisive election on November 5, the process of selecting and vetting individuals to fill the second Trump administration’s key appointed positions is quickly shifting into high gear. For those tapped for consideration, the decision to enter the process may be one of the most significant decisions of their
Continue Reading A Primer for Navigating the Presidential Appointee Vetting and Confirmation ProcessStates Introduce More “Baby” FARA Bills
Over the past several weeks, legislatures in Arizona, California, Georgia, Oklahoma, and Tennessee have introduced bills that mirror the federal Foreign Agents Registration Act (“FARA”). There has been a trend in the states to enact so-called “baby FARA” laws that apply to foreign influenced political activity
Continue Reading States Introduce More “Baby” FARA BillsDOJ Officials Signal New Trends in Enforcement and Interpretation of the Foreign Agents Registration Act
On December 1, 2023, three top U.S. government officials responsible for enforcing the Foreign Agents Registration Act (“FARA”) gave remarks at the American Conference Institute’s 5th National Forum on FARA. In their remarks, each of the speakers – Deputy Assistant Attorney General Eun Young Choi, the Acting Chief of the
Continue Reading DOJ Officials Signal New Trends in Enforcement and Interpretation of the Foreign Agents Registration Act