It may begin with an unusual media inquiry or a sudden spike in interest on social media. Just as often, it starts with a non-public request for documents or other evidence. Your boss or your staff have been accused of wrongdoing, and it falls to you to lead the response.
Continue Reading Handling Investigations of Members of Congress and Congressional Staff: A How-To Guide for Chiefs of StaffDepartment of Justice
DOJ Posts (then Takes Down) Seventeen New Advisory Opinions Regarding the Foreign Agents Registration Act
By Robert Kelner, Brian D. Smith & Alex Langton on
Posted in Foreign Agents Registration Act
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violence,” the FARA Unit of the Department of Justice (“DOJ”) quietly (and maybe inadvertently) published and then unpublished 17 new advisory opinions regarding…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 ActDOJ Withdraws Dozens of Regulatory Actions, Keeps FARA NRPM
By Brian D. Smith, Zachary G. Parks & Alex Langton on
Posted in Foreign Agents Registration Act
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 NRPMAdministration Targets Lobbying by Federal Grantees with New Presidential Memorandum
Posted in Enforcement
Federal contractors, grantees, borrowers, and others receiving federal funds face a variety of restrictions on their use of those funds for political purposes, including for lobbying. A new presidential memorandum issued last week by President Trump highlights one of those restrictions, 31 U.S.C. § 1352, also known as the…
Continue Reading Administration Targets Lobbying by Federal Grantees with New Presidential MemorandumDOJ Issues Memorandum for Federal Funding Recipients Addressing “Unlawful Discrimination” Practices
On July 29, 2025, Attorney General Pam Bondi issued a memorandum titled “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination.” The memorandum purports to offer “guidance” and “Best Practices” to recipients of federal funding, including “non-binding suggestions to help entities comply with federal antidiscrimination laws and avoid legal pitfalls.” …
Continue Reading DOJ Issues Memorandum for Federal Funding Recipients Addressing “Unlawful Discrimination” PracticesTax-Exempt Organizations: Understanding Executive and Congressional Enforcement Priorities
Tax-exempt organizations, including private foundations and other types of nonprofits associated with high-net worth individuals, have been subject to increasing investigative scrutiny in recent years. Last Congress, for example, the House Judiciary Committee and several other committees issued document requests to multiple nonprofit organizations, and in this Congress the trend…
Continue Reading Tax-Exempt Organizations: Understanding Executive and Congressional Enforcement PrioritiesAttorney General Issues Memorandum Regarding FARA Criminal Enforcement
By Robert Kelner, Brian D. Smith & Alex Langton on
Posted in Enforcement, Foreign Agents Registration Act
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 EnforcementDOJ Officials Signal New Trends in Enforcement and Interpretation of the Foreign Agents Registration Act
Posted in 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 ActRecent Arkansas Sentencing Highlights How Easily Federal Prosecutors Can Target State Campaign Finance Issues
By Peter Koski, Robert Lenhard & William Sokolove on
Posted in Campaign Finance, Enforcement
What happens in Arkansas does not stay in Arkansas. Or at least not when federal prosecutors from the Department of Justice’s Public Integrity Section get involved.
A recent sentencing from Arkansas highlights the many options in DOJ’s toolkit to pursue “state-level” misconduct involving public officials. In the case of former…
Continue Reading Recent Arkansas Sentencing Highlights How Easily Federal Prosecutors Can Target State Campaign Finance IssuesDOJ Announces Arrest in New FARA Case
By Robert Kelner on
Posted in Enforcement, Foreign Agents Registration Act
The U.S. Department of Justice today announced the arrest of an alleged agent of the Iranian government, who has been charged with violating the Foreign Agents Registration Act (“FARA”). The defendant is an Iranian political scientist, living in the United States as a permanent resident. The Justice Department alleges that…
Continue Reading DOJ Announces Arrest in New FARA Case