DOJ

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

An opinion by Chief Judge Beryl Howell of the U.S. District Court for the District of Columbia unsealed yesterday has generated much attention for its discussion of contributions-for-pardons allegations in a case that is still largely obscured from public view.  But the underlying offenses at issue in the case also…
Continue Reading Contributions-for-Pardons Opinion Reveals DOJ Efforts, and Challenges, Prosecuting Lobbying Violations

Every four years, prosecutors at the Department of Justice (“DOJ”) train their sights on money spent to influence the outcome of the presidential election—and those who spend it.  While the Federal Election Commission (FEC) has exclusive jurisdiction to penalize and enforce civil violations of the Federal Election Campaign Act (FECA), …
Continue Reading Increased Enforcement Risk for Criminal Campaign Finance Violations

Following the Department of Justice’s announcement in March 2019 of an initiative to increase enforcement of the Foreign Agents Registration Act (“FARA”), the Department began rolling out a new electronic filing system for FARA registrations in September 2019. At that time, as Covington reported, the new system applied only…
Continue Reading DOJ Begins to Move Existing FARA Registrants to a New E-File System

Following the Department of Justice’s announcement in March of an initiative to increase enforcement of the Foreign Agents Registration Act (“FARA”), the Department has rolled out a new e-file system for FARA registrations.  Notably, the new system only applies to new registrants, although the Department indicated that it will transition…
Continue Reading New Changes to Foreign Agents Registration Act Forms and E-File System

The House Appropriations Committee has quietly directed the Department of Justice to issue new guidance on the commercial exemption to the Foreign Agents Registration Act (“FARA”) with respect to state-owned companies.  The directive came in a Committee report accompanying legislation that provides funding for the Department for fiscal year 2020. …
Continue Reading Appropriations Committee Directs New FARA Guidance on Commercial Exemption

Covington issued several client alerts in recent years warning of a rising tide of enforcement of the once-obscure Foreign Agents Registration Act of 1938 (“FARA”). Signs of this trend emerged long before the recent, high-profile Special Counsel’s Office investigation. Nonetheless, there was persistent skepticism abroad in the land, particularly among…
Continue Reading U.S. Department of Justice Announces Foreign Agents Registration Act Enforcement Initiative

As the Foreign Agents Registration Act continues to receive national attention, an article in this quarter’s PLI Current journal describes the Justice Department’s increased focus on the statute.  The article, authored by Covington’s Rob Kelner, Zack Parks, and Alex Langton, discusses the shifting FARA enforcement landscape, analyzes how the statute…
Continue Reading PLI Current Highlights New Wave of FARA Enforcement