Are You a Foreign Agent? [More with McGlinchey, Ep. 21
On June 10, 2025, the Media Bureau of the Federal Communications Commission (FCC or Commission) issued a Public Notice (Notice) announcing that broadcasters have until December 8, 2025 to comply with the FCC’s expanded rules...more
On July 1, 2025, the United Kingdom’s new Foreign Influence Registration Scheme (FIRS) will formally take effect, creating sweeping registration obligations under U.K. law for persons engaging in certain activities on behalf...more
After years of suggesting that modifications were in the works, the Department of Justice recently proposed drastic changes to the Foreign Agents Registration Act (FARA) that would, among other things, profoundly limit one of...more
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
Introduction - On December 20, 2024, the U.S. Department of Justice (DOJ) announced its long-awaited proposed amendments to the regulations adopted under the Foreign Agents Registration Act (FARA) in a Notice of Proposed...more
Securities and Exchange Commission (SEC) reporting companies with fiscal years ending December 31 that engage in the commercial development of oil, natural gas or minerals are required to file a Form SD with the SEC by...more
As previously discussed in our Client Alert issued on December 18, 2020 (available here), the U.S. Securities and Exchange Commission (the “Commission”) adopted its final rule (the “Final Rule,” available here) requiring...more
Section 317 of the Communications Act requires broadcast licensees to inform their audiences of when programming is being aired in exchange for payment or compensation to the station....more
On June 10, 2024, the Federal Communications Commission (FCC or Commission) released a Second Report and Order (Second R&O) that amends the Commission’s foreign sponsorship identification rules (FSID Rules). As explained in...more
International cooperation and welcoming foreign academics are critical to the success and leadership of U.S. institutions of higher education. These interactions enhance fundamental scientific research and promote the...more
On January 24, 2023, a bipartisan group of senators reintroduced the Disclosing Foreign Influence in Lobbying Act in the 118th Congress. The group is led by Senator Chuck Grassley (R-IA), a longtime proponent of the Foreign...more
When considering who must register under the Foreign Agents Registration Act (“FARA” or “the Act”), one normally thinks of individuals, law firms, or marketing firms, the typical kinds of agents that must register for...more
On 31 August 2022, California legislators passed a bill that would ban the sale of agricultural land in the state to foreign governments. Introduced by state Senator Melissa Hurtado (D-Fresno), the Food and Farm Security Act...more
The Federal Communications Commission’s (FCC) new rules governing foreign sponsorship disclosures for broadcasters went into effect on March 15, 2022. Broadcast stations airing BBC, France 24, Al Jazeera and Deutsche Welle...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
FARA is a disclosure statute that seeks to ensure that all persons acting politically or quasi-politically on behalf of foreign entities in the United States properly disclose their activities to the U.S. government. In...more
As part of the government’s broader efforts to combat foreign threats to U.S.-funded scientific research, the National Institutes of Health (NIH) and White House Office of Science and Technology Policy (OSTP) have announced...more
On March 24, 2021, the U.S. Securities and Exchange Commission (“SEC”) issued rule amendments to implement submission and disclosure requirements mandated by the Holding Foreign Companies Accountable Act (“HFCAA” or “Act”)....more
Recent measures from U.S. lawmakers and Nasdaq to impose additional requirements on U.S.-listed China-based companies could have wider implications. On May 20, 2020, the U.S. Senate unanimously passed the Holding Foreign...more
On May 20, 2020, the U.S. Senate passed S.945, the Holding Foreign Companies Accountable Act (“Bill”), which requires certain public companies to disclose whether they are owned or controlled by a foreign government,...more
In the wake of a global law firm entering into a multimillion-dollar settlement for failing to register as an agent of a foreign principal under the Foreign Agents Registration Act (FARA or the act), other law firms have...more
On December 18, 2019, the US Securities and Exchange Commission (SEC) proposed rules for the reporting of certain payments by resource extraction issuers (the “proposed rules”). The proposed rules represent the third attempt...more
The SEC is proposing Rule 13q-1 and an amendment to Form SD to implement Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “DoddFrank Act”) relating to disclosure of payments by resource...more
With the Department of Justice (“DOJ”) giving increased attention to Foreign Agent Registration Act (“FARA”) enforcement, companies that have international business operations or otherwise deal with foreign governments and...more
• A September 2016 audit report by the U.S. Department of Justice (DOJ) Office of Inspector General recommended more transparency regarding compliance and enforcement of the Foreign Agents Registration Act (FARA). • To...more