rulemaking

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 Counterintelligence and Export Control Section…

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 direction it suggests the DOJ…

With the swearing in of Shana M. Broussard, Sean J. Cooksey, and Allen Dickerson, the Federal Election Commission now has a full roster of six Commissioners for the first time since 2017.  While the FEC briefly enjoyed a quorum with four Commissioners in May, since then it has lacked a sufficient number of Commissioners to…

The Internal Revenue Service today announced proposed regulations to eliminate donor information disclosure requirements for certain nonprofits.  The proposed regulations provide “relief from requirements to report contributor names and addresses on annual returns filed by certain tax-exempt organizations, previously provided in Revenue Procedure 2018-38.”  Once the notice is published in the Federal Register, the…

The Federal Election Commission (FEC) unanimously approved a Notice of Proposed Rulemaking, beginning the formal process of amending the agency’s regulations on internet political disclaimers.  The proposal and the Commissioners’ comments at the hearing reflect a fair amount of consensus on how to refashion rules that have been the source of significant disputes over…

On Thursday, the FEC will return to the question of foreign nationals’ involvement in United States elections. This is an important question that deserves appropriate attention from our government.  Be it the role of Chinese government-linked funds in the 1996 presidential campaign or the Russian government-linked cyber intrusion in the 2016 presidential race, Congress and…

A major spending bill posted late last night by Congressional leaders contains provisions shooting down two key initiatives of the campaign finance reform community. 

Stymied by a Federal Election Commission that has increasingly struggled to find consensus, campaign finance activists in recent years have turned their attention to other federal regulators, pressing those regulators to …

A hot topic we’ve been tracking closely this year concerns the regulatory and legal battles over corporate political activity disclosure.  This past week has been notable in two respects.

As we’ve previously reported here, in December 2012 the Securities and Exchange Commission (“SEC”) identified potential rulemakings that it might undertake in 2013.  Among the…

At a public hearing tomorrow, the Federal Election Commission (FEC) will discuss a proposed rulemaking that would allow certain Limited Liability Partnerships (LLPs) to establish separate segregated funds (SSFs), commonly known as PACs.  If the proposed rule were ultimately to be adopted, it would create rules for LLPs that are similar to the existing rules…