In 2025, Texas, Nebraska, Louisiana, Arkansas and Oklahoma enacted state-level foreign agent registration and disclosure regimes that were loosely modeled on the federal Foreign Agents Registration Act. And in the first few months of 2026, several states — Alabama, Florida, Iowa, Missouri and West Virginia, to name a few — have already introduced similar bills.

The practice of requiring disclosure of efforts to influence state policy is nothing new. All states and Washington, D.C., have lobbying laws. Moreover, the legislative impulse to regulate foreign influence is easy to understand, particularly when it is framed around addressing activities by entities from so-called hostile foreign countries or countries of concern.

However, this article, published in Law360, explains why the state-level “baby FARA” laws focusing on foreign influence efforts present several unique constitutional challenges, and highlight questions about how far states can and should extend regulatory tools beyond traditional lobbying regimes to capture a wide range of foreign‑affiliated activity.

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Photo of Alex Langton Alex Langton

Alexandra Langton is a member of the Election and Political Law Practice Group in the Washington, D.C., office. She represents clients in high-profile and high-risk DOJ investigations, FEC investigations, congressional investigations, and other criminal and civil matters that present legal, political, and public…

Alexandra Langton is a member of the Election and Political Law Practice Group in the Washington, D.C., office. She represents clients in high-profile and high-risk DOJ investigations, FEC investigations, congressional investigations, and other criminal and civil matters that present legal, political, and public relations risks. She also advises companies, nonprofits, and individuals on compliance with federal and state campaign finance, ethics, lobbying laws, and vetting matters.

Alexandra has particular expertise in the Foreign Agents Registration Act (“FARA”). She frequently interacts with the FARA Unit of the Department of Justice and advises clients on top-tier FARA compliance programs, including FARA policies, FARA trainings, and FARA filings. Alexandra also represents a number of clients in high-profile civil and criminal FARA enforcement actions. She has also advised numerous government and former government officials in federal investigations and litigation.