Pompeo Calls on Think Tanks, Foreign Policy Organizations to Disclose Foreign Ties

Wiley Rein LLP

Secretary of State Michael Pompeo called on think tanks and other foreign policy organizations to prominently disclose any funding they receive from foreign governments, including state-owned or state-operated subsidiary entities.

In a statement, Pompeo said, “The unique role of think tanks in the conduct of foreign affairs makes transparency regarding foreign funding more important than ever. To protect the integrity of civil society institutions, the [State] Department requests henceforth that think tanks and other foreign policy organizations that wish to engage with the Department disclose prominently on their websites funding they receive from foreign governments, including state-owned or state-operated subsidiary entities.”

Pompeo noted that disclosure is not required for the Department to engage with such entities; however, Department staff will “be mindful of whether disclosure has been made and of specific funding sources that are disclosed when determining whether and how to engage.” Pompeo’s recent statement underscores the U.S. government’s heightened focus on foreign funding of certain activities in the United States, including political activities, and promoting enhanced transparency and disclosure in this arena.

Although this policy is distinct from the disclosure requirements under the Foreign Agents Registration Act (FARA), 22 U.S.C. 611 et seq., FARA similarly requires entities/individuals engaged in certain activities within the United States, including trying to influence U.S. public or political policy/opinion, and that receive funding or subsidization (in whole or in part) from a foreign source, to make certain disclosures/abide by certain reporting requirements absent an exemption to registration. Therefore, in addition to the Department’s new disclosure requirement, U.S. think tanks/foreign policy organizations that receive funding from foreign sources, including foreign governments, should also be mindful of FARA and whether they may have a registration obligation under the statute.

Nicole Hager, a Law Clerk at Wiley Rein LLP, contributed to this alert.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Wiley Rein LLP | Attorney Advertising

Written by:

Wiley Rein LLP

Wiley Rein LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.