client alert

The 2025 proxy season saw significant developments with respect to proposals calling on companies to disclose information about their political contribution activity and lobbying activity, including an increase in support for political contribution proposals. That stronger support, particularly against the backdrop of reduced support for socially-oriented shareholder proposals, may lead

Continue Reading Is a Political Law Shareholder Proposal Under Your Tree? Strategies for Responding in the New Year

Shareholder proposals on political issues—particularly lobbying spending disclosure and campaign finance issues—have been a common part of the proxy landscape for some time now. This proxy season, proposals seeking greater transparency around corporate political spending had surprising success compared to the past. This alert highlights that, especially given this development

Continue Reading Corporate Political Disclosure Shareholder Proposals Draw Surprising Support

The Department of Justice’s FARA Unit released several new advisory opinions in recent weeks that interpret the Foreign Agents Registration Act (“FARA”) and its regulations.  While the newly published opinions addressed a number of topics, the FARA Unit’s broad reading of the FARA triggers and the jurisdictional scope of the

Continue Reading DOJ Releases New FARA Advisory Opinions Affecting Digital Media Platforms

Late last week, the Committee on Oversight and Accountability published the House of Representative’s “Authorization and Oversight Plans.” The massive 241-page report is required by the House rules, and the Oversight Committee’s report collects the individual oversight plans that each standing committee of the House is required to create at

Continue Reading Newly Published “Oversight Plan” Outlines the House’s Investigative Priorities

At the start of a new Congress, the House and Senate, and their committees, adopt internal rules that govern their operations, including rules that affect congressional investigations. These rules are often revised from Congress to Congress. To assist our clients responding to congressional investigations, this alert summarizes the rules for

Continue Reading Congressional Investigations and the Rules of the 118th Congress

The contentious 2020 election cycle, debate over hot-button issues, including the Supreme Court’s 2022 decision in Dobbs v. Jackson Women’s Health Organization, and increased investor focus on ESG matters (as well as criticism of such focus) have led to an increased focus on shareholder proposals requesting disclosure of corporate

Continue Reading Tips for Responding To Corporate Political Disclosure Shareholder Proposals

Political committees, advertisers, and advertising platforms have operated under a cloud of uncertainty regarding which disclaimers, if any, must appear on internet-based advertisements. Existing Federal Election Commission (“FEC”) regulations and guidance left many unanswered questions about the disclaimers required for these increasingly important internet ads. The FEC has finally offered

Continue Reading What You Need to Know about the FEC’s New Internet Communications Disclaimer Rules

In 2018, Covington published the original version of its widely read primer on the Foreign Agents Registration Act, “FARA: A Guide for the Perplexed.” We have updated this primer periodically. Today, the firm released the latest edition of the primer, featuring new analysis of recent Department of Justice guidance

Continue Reading Covington Releases Updated Version of “FARA:  A Guide for the Perplexed”

The Department of Justice (“DOJ” or “The Department”) recently released a letter, sent to Senator Chuck Grassley (R-IA) and a bipartisan group of Senators a few weeks ago, in which DOJ expressed support for eliminating the Lobbying Disclosure Act (“LDA”) registration exemption to the Foreign Agents Registration Act (“FARA”).

Continue Reading Department of Justice Reveals Support for Eliminating the LDA Exemption to FARA and Other FARA Reforms

Last week, the Department of Justice published an Advance Notice of Proposed Rulemaking (ANPRM), the first step toward a major rulemaking that DOJ says would “modernize” the current regulations, including by clarifying certain exemptions and definitions.

In a client alert today, we review key portions of the ANPRM and the
Continue Reading DOJ Solicits Comments for Potential Major Changes to FARA Regulations