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
On February 19, 2025, the Committee on Oversight and Government Reform – specifically, Rep. Virginia Foxx and Committee Chairman James Comer – sent a letter to the U.S. Department of Education (DOE) Acting Secretary, Denise...more
The U.S. Department of Justice (DOJ) published a Notice of Proposed Rulemaking (NPRM) to update regulations under the Foreign Agents Registration Act of 1938 (FARA) on January 2, 2025. If adopted, DOJ’s proposed changes would...more
On December 20, 2024, the US Department of Justice (DOJ) issued a long-awaited notice of proposed rulemaking (NPRM) to revise regulations under FARA, three years after an Advance Notice of Proposed Rulemaking sought input on...more
On May 13, 2024 the U.S. Department of Defense (DoD) published Instruction 5205.87: Mitigating Risks Related to Foreign Ownership, Control, or Influence for Covered DoD Contractors and Subcontractors (the Instruction), which...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
With recent high-profile prosecutions continuing to draw attention to the Foreign Agents Registration Act (FARA) and related political laws, and a number of notable announcements by Department of Justice (DOJ) officials at a...more
On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Rule”), the first of three planned rulemakings implementing the beneficial ownership information reporting rules of the...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 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
The U.S. Department of Justice’s (DOJ) determined approach to identifying violations of the Foreign Agents Registration Act (FARA) shows no signs of slowing down. An inadvertently disclosed warrant revealed that John Allen, a...more
The Foreign Agents Registration Act (FARA), 22 U.S.C. § 611 et seq., is a federal statute passed in 1938 that was originally intended to combat the dissemination of Nazi and Communist propaganda within the United States. FARA...more
Following its efforts in recent years to enforce the Foreign Agents Registration Act of 1938 (22 U.S.C. 611 et seq. (FARA)) more rigorously and transparently, for the first time in nearly 15 years, the U.S. Department of...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
As we rapidly approach the New Year, higher education institutions should ensure they have met their foreign gift and contract reporting requirements. Institutions are required by Section 117 of the Higher Education Act to...more
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...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
As discussed in a previous alert dated June 18, 2019, the U.S. Department of Education (the “Department”) over the last year increased its scrutiny of postsecondary institutions’ contracts with, and gifts from, foreign...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
U.S. is increasing its enforcement to monitor foreign interests. The U.S. Department of Justice (DOJ) recently announced increased enforcement of the Foreign Agents Registration Act (FARA), which requires public...more
On March 6, Assistant Attorney General for National Security John C. Demers announced that the Department of Justice (“DOJ”) has designated a new deputy chief to lead the Foreign Agents Registration Act (“FARA”) unit and that...more
After decades in which the Foreign Agents Registration Act (FARA) received relatively little attention, a confluence of recent events has given the statute newfound prominence. Together, these developments compound the...more