FARA

Shortly before adjourning for 2025, the Senate passed two 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 Disclosing Foreign Influence in Lobbying Act (S. 856 / H.R. 1883)

Continue Reading Senate Advances Bills To Broaden Foreign Agent Disclosures in Lobbying Reports

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violence,” the FARA Unit of the Department of Justice (“DOJ”) quietly (and maybe inadvertently) published and then unpublished 17 new advisory opinions regarding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

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 Bills

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 Laws

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 Law

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 Enforcement

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

Continue Reading Department of Justice Proposes Major Changes to FARA Regulations, Including Sweeping Changes Affecting Multinational Companies

With Election Day fast approaching, corporations face increasing pressure from both internal and external forces to make legal decisions about political activities. This can be a fraught area of law, with little understood, highly technical regulatory issues that vary significantly across jurisdictions. Corporate counsel should be mindful of common—and sometimes

Continue Reading Avoiding Pitfalls on the Path to Election Day: Common Political Law Risks for Corporations in Election Season

Georgia Governor Brian Kemp has vetoed Georgia Senate Bill 368, which would have created a requirement in state law for certain “agents of foreign principals” to register and report certain lobbying and political activities in Georgia.  This is the first of the wave of recently proposed baby FARA bills at

Continue Reading Georgia Governor Vetoes “Baby” FARA Bill

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 Bills