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New Executive Order Adds Scrutiny to Universities’ and Other Higher Education Institutions’ Foreign Sources of Funding

As a part of the new administration’s broader effort to add regulatory requirements and scrutiny to institutions of higher education, on April 23, 2025, President Trump issued an Executive Order (EO) on Transparency Regarding...more

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 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

DOJ Updates Its Guidance on Corporate Compliance Programs, with an Emphasis on AI and Whistleblowers

The ECCP is intended to assist federal prosecutors in determining whether a corporation’s compliance program was effective at the time of the alleged offense(s) and, if not, what type of enforcement, monetary penalty, and...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

DOJ National Security Division Issues First-Ever Declination Under Voluntary Self-Disclosure Policy

On May 22, 2024, the Department of Justice’s (DOJ) National Security Division (NSD) announced its first-ever prosecution declination under its corporate voluntary self-disclosure (VSD) policy for sanctions and export controls...more

Top 10 International Anti-Corruption Developments for January 2024

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

MoFo's 2023 FCPA Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, our Foreign Corrupt Practices Act (FCPA) Year In Review provides quick, visual representations of key trends in FCPA enforcement over...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

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