In an August 2026 Unified Agenda entry, the Department of Justice (“DOJ”) stated that it intends to complete its long-running effort to revise the regulations implementing the Foreign Agents Registration Act (“FARA”). The National Security Division (“NSD”) stated that it is considering a final rule that would adopt “many
Continue Reading DOJ Signals it will Move Forward with Significant Revisions to FARA Regulations
Alex Langton
Alexandra Langton is an associate in Covington’s Election and Political Law Practice Group in the firm’s Washington, DC office. Her practice focuses on representing corporations, nonprofit organizations, public officials, and individuals in high-stakes matters involving legal, political, and reputational risk. She routinely counsels clients in matters arising from investigations and enforcement actions by the Department of Justice, the Federal Election Commission, congressional committees, and state regulatory authorities, as well as related internal investigations.
In addition to her investigations practice, Alexandra advises clients on compliance with federal and state campaign finance, ethics, and lobbying laws, including sensitive matters. Her work frequently involves advising on the application of federal ethics rules arising in connection with government transitions, appointments, and engagements involving current or former public officials. She also represents clients in state-level campaign finance enforcement matters and compliance reviews.
Alexandra has particular expertise in the Foreign Agents Registration Act (FARA) and is deeply involved in all aspects of FARA compliance and enforcement. She regularly interacts with the Department of Justice’s FARA Unit and advises clients on the design, implementation, and maintenance of sophisticated FARA compliance programs, including internal policies, tailored training programs, and registration and reporting obligations. She also represents clients in high-profile civil and criminal FARA enforcement matters, including internal investigations, retroactive registrations, and disputes with the government. Alexandra also regularly advises on compliance with the federal Lobbying Disclosure Act (LDA) and related reporting regimes, including the complex interplay between the LDA and FARA.
Ms. Langton is one of the few experts in the country on state, or “baby FARA,” laws and how they interact with the federal FARA statute.
She has been quoted in national publications regarding FARA, including Politico, Bloomberg, The National Law Journal, and Global News. She has written and speaks often on Foreign Agents Registration Act issues.
Early Post-NRSC Domino Falls: Minnesota Stops Enforcing Limits on Certain Party In-Kind Contributions
State regulators are beginning to grapple with the implications of the Supreme Court’s recent decision in National Republican Senatorial Committee v. FEC (“NRSC”). Minnesota may have provided the first clear example of how the ruling could reshape state campaign finance regimes. On June 30, the Supreme Court struck down the federal limits on coordinated party expenditures, holding that political parties have a First Amendment right to spend unlimited amounts in coordination with candidates and rejecting the argument that such limits are necessary to prevent corruption. Although the Court did not directly address limits on party-to-candidate contributions or in-kind contributions, the decision immediately raised questions about the constitutionality of such limits, particularly in jurisdictions that, unlike federal law, do not distinguish between coordinated expenditures and in-kind contributions. Minnesota’s response suggests that answers may be arriving sooner than expected.
Continue Reading Early Post-NRSC Domino Falls: Minnesota Stops Enforcing Limits on Certain Party In-Kind ContributionsState FARA Laws Pose Unique Constitutional Challenges
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…
Continue Reading State FARA Laws Pose Unique Constitutional ChallengesCovington Releases Updated Version of “FARA: A Guide for the Perplexed”
In 2018, Covington published the original version of its widely read primer on the Foreign Agents Registration Act, “FARA: A Guide for the Perplexed.” We have updated this primer periodically. This week, the firm released the latest edition of the primer, featuring new analysis of recent Department of Justice…
Continue Reading Covington Releases Updated Version of “FARA: A Guide for the Perplexed”Senate Advances Bills To Broaden Foreign Agent Disclosures in Lobbying Reports
Shortly before adjourning for 2025, the Senate passed two bills to broaden disclosure and registration requirements related to the regulation of foreign agents under the Foreign Agents Registration Act (“FARA”) and the Lobbying Disclosure Act (“LDA”): the Disclosing Foreign Influence in Lobbying Act (S. 856 / H.R. 1883)…
Continue Reading Senate Advances Bills To Broaden Foreign Agent Disclosures in Lobbying ReportsDOJ Posts (then Takes Down) Seventeen New Advisory Opinions Regarding the Foreign Agents Registration Act
Following an announcement last month that the White House intends to deploy the Foreign Agents Registration Act (“FARA”) to investigate persons with foreign ties that “foment political violence,” the FARA Unit of the Department of Justice (“DOJ”) quietly (and maybe inadvertently) published and then unpublished 17 new advisory opinions regarding…
Continue Reading DOJ Posts (then Takes Down) Seventeen New Advisory Opinions Regarding the Foreign Agents Registration ActCongress Weighs Foreign Agent Disclosure and Registration Bills
Congress is considering several bills to broaden disclosure and registration requirements related to the regulation of foreign agents under the Foreign Agents Registration Act (“FARA”) and the Lobbying Disclosure Act (“LDA”): the Foreign Registration Obligations for Nonprofit Transparency (“FRONT”) Act (S. 2305), Disclosing Foreign Influence in Lobbying Act (S. 856 / H.R. 1883) and the Lobbying Disclosure Improvement Act (S. 865 / H.R. 1887). Additionally, multiple proposed amendments to the FY 2026 National Defense Authorization Act (NDAA) would increase certain disclosure obligations. Together, these legislative proposals indicate continued lawmaker interest in regulating foreign influence in the United States.
Continue Reading Congress Weighs Foreign Agent Disclosure and Registration BillsTexas, Louisiana, and Nebraska Enact “Baby” FARA Laws
Over the last several weeks, Texas, Louisiana, and Nebraska have enacted so called “baby” Foreign Agents Registration Act (“FARA”) laws aimed at regulating foreign-influenced political activity in the states. There has been a trend in state legislatures over the last year to propose laws that apply to foreign-influenced political activity…
Continue Reading Texas, Louisiana, and Nebraska Enact “Baby” FARA LawsDepartment of Justice Proposes Major Changes to FARA Regulations, Including Sweeping Changes Affecting Multinational Companies
On January 2, 2025, the Department of Justice published a Notice of Proposed Rulemaking
(“NPRM”) soliciting public comments on potential amendments to the Department’s regulations
regarding the Foreign Agents Registration Act (“FARA”). The regulatory amendments proposed
by the Department are significant, and they would take the statute in a substantially…
A Primer for Navigating the Presidential Appointee Vetting and Confirmation Process
Following the decisive election on November 5, the process of selecting and vetting individuals to fill the second Trump administration’s key appointed positions is quickly shifting into high gear. For those tapped for consideration, the decision to enter the process may be one of the most significant decisions of their…
Continue Reading A Primer for Navigating the Presidential Appointee Vetting and Confirmation Process