On February 21, 2025, President Trump published a National Security Presidential Memorandum outlining his administration’s views on foreign investment and substantial changes to current regulatory regimes. The...more
2/26/2025
/ America First Trade Policy ,
Artificial Intelligence ,
CFIUS ,
China ,
Compliance ,
Economic Sanctions ,
Export Controls ,
Foreign Agents Registration Act (FARA) ,
Foreign Investment ,
Foreign Policy ,
National Security ,
Regulatory Requirements ,
Russia ,
Trump Administration
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
1/2/2025
/ Department of Justice (DOJ) ,
Disclosure Requirements ,
Foreign Agents ,
Foreign Agents Registration Act (FARA) ,
Foreign Governments ,
Foreign Investment ,
Foreign Nationals ,
Foreign-Owned Corporations ,
Information Governance ,
National Security ,
Non-Commercial Use ,
Nonprofits ,
NPRM ,
Public Interest ,
Regulatory Requirements ,
Social Media ,
Substantial Interest Test ,
Tourism
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
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
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
On April 2, 2024, the Georgia State Senate sent Senate Bill 368, which creates a state law version of the U.S. Foreign Agents Registration Act (FARA) for the State of Georgia, to Governor Brian Kemp for his signature. The...more
On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more
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
On July 11, 2023, the UK’s Foreign Influence Registration Scheme (“FIRS”) became law. As part of the National Security Act 2023, FIRS requires registration of arrangements intended to influence UK politics at the direction of...more
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
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
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
The UK government has proposed new registration requirements for foreign influence activities in the UK as part of its attempts to strengthen the resilience of the UK’s political system and democratic institutions against...more
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
Last month, the Committee on Foreign Investment in the United States (CFIUS) released its Annual Report to Congress covering 2021. The key takeaway is that CFIUS is more active than ever, subjecting a record number of...more
9/15/2022
/ CFIUS ,
China ,
Corporate Counsel ,
FIRRMA ,
Foreign Agents Registration Act (FARA) ,
Foreign Direct Investment ,
Foreign Investment ,
Jurisdiction ,
Mitigation ,
National Security ,
Written Notice
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 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
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
5/28/2021
/ Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Domestic Policy ,
Entity List ,
Exemptions ,
Foreign Agents ,
Foreign Agents Registration Act (FARA) ,
Foreign Corporations ,
Foreign Governments ,
Material Dissemination ,
Promotional Items ,
Public Relations ,
U.S. Commerce Department
In late April 2021, the Federal Communications Commission (FCC) adopted new rules that require on-air programming sponsored or furnished by a foreign government to contain a disclosure statement noting the foreign government...more