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…

Continue Reading DOJ Officials Signal New Trends in Enforcement and Interpretation of the Foreign Agents Registration Act

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

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…
Continue Reading IRS Issues Notice of Proposed Rulemaking on Donor Disclosure Rules in Response to Court Ruling

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…
Continue Reading The FEC Revisits the Ban on Foreign Nationals’ Financing of American Elections

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 …
Continue Reading Congressional Spending Bill Shuts Down Key Goals of Campaign Finance Reform Community

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…
Continue Reading Update on Corporate Political Activity Disclosure