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DOJ Proposes Significant Changes to FARA’s Regulations

For the first time in nearly 30 years, the U.S. Department of Justice (DOJ) proposes to materially revise the Foreign Agents Registration Act (FARA). On December 19, 2024, DOJ issued a Notice of Proposed Rulemaking (NPRM)...more

FARA Officials Reveal Upcoming Regulatory Changes and Enforcement Priorities for 2025

On December 6, 2024, the U.S. Department of Justice (DOJ) provided insights into Foreign Agents Registration Act (FARA) regulatory changes and focus areas for 2025. Speaking at the American Conference Institute’s National...more

FARA Unit Takes Aim at Foreign Litigation Funding and Commercial Exemption

On November 18, 2024, the U.S. Department of Justice (DOJ) Foreign Agents Registration Act (FARA) Unit published an advisory opinion that appears to severely narrow the statute’s most important exemptions. In the opinion, the...more

D.C. Circuit Limits DOJ’s Ability to Retroactively Enforce FARA

Last week the D.C. Circuit released its long-anticipated opinion in the Attorney General v. Wynn, holding that the Department of Justice (“DOJ”) could not compel Steve Wynn to retroactively register under the Foreign Agents...more

FARA Officials Preview Major Regulatory Changes and Identify New Areas of Focus

The U.S. Department of Justice (DOJ) recently provided fresh insights into upcoming regulatory changes to key Foreign Agents Registration Act (FARA) exemptions and discussed new areas of concern. These insights were shared at...more

Third FARA Lawsuit Shows Focus on Civil Enforcement

On April 25, 2023, the U.S. Department of Justice (“DOJ”) filed a civil enforcement action seeking to compel the Federación de Alcades Pedaneo (“FDAP”) to comply with requirements for registrants under the Foreign Agents...more

New Advisory Opinion Extends FARA to Online Networks and Service Providers

In an advisory opinion released last week by the U.S. Department of Justice (DOJ) Foreign Agents Registration Act (FARA) Unit, DOJ adopts a potentially expansive interpretation of FARA that could require online networks,...more

FARA’s Big Finish

At the beginning of the year, we predicted that 2022 would be the next big year for the Department of Justice’s (DOJ) enforcement of the Foreign Agents Registration Act (FARA). And 2022 delivered, though not always in ways...more

A Win for Wynn: Judge’s Dismissal of Civil Case Against Steve Wynn Could Fundamentally Change FARA Enforcement

On October 12, 2022, a federal district judge in the District of Columbia, Judge James E. Boasberg, dismissed a U.S. Department of Justice (DOJ) civil complaint against businessman Steve Wynn, which sought to compel Wynn to...more

DOJ Intends to Significantly Change FARA for the First Time in Decades

Last week the U.S. Department of Justice (DOJ) announced that it is seeking public comment as it considers substantive updates to the implementing regulations of the Foreign Agents Registration Act (FARA) for the first time...more

Amid Increased FARA Enforcement, New Advisory Opinions Narrow the Scope of Registrable Activity

Amid a rise in U.S. Department of Justice (DOJ) enforcement of the Foreign Agents Registration Act (FARA)—including an increase in criminal cases and staff dedicated to FARA investigations—last month the FARA Unit released...more

FARA Unit Continues Narrow Interpretation Of The Commercial Exemption

Last week’s release of advisory opinions related to the Foreign Agents Registration Act (FARA) – the first such opinions from the new Chief of the Department of Justice’s FARA Unit (the “Unit”) – signal that the Unit will...more

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