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 ChallengesForeign Agents Registration Act
Covington 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
Posted in Foreign Agents Registration Act, Political Law
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
By Robert Kelner, Brian D. Smith & Alex Langton on
Posted in Election, 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violence,” the FARA Unit of the Department of Justice (“DOJ”) quietly (and maybe inadvertently) published and then unpublished 17 new advisory opinions regarding…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
Posted in Foreign Agents Registration Act, Political Law
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
By Robert Kelner & Alex Langton on
Posted in Foreign Agents Registration Act
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…
Avoiding Pitfalls on the Path to Election Day: Common Political Law Risks for Corporations in Election Season
With Election Day fast approaching, corporations face increasing pressure from both internal and external forces to make legal decisions about political activities. This can be a fraught area of law, with little understood, highly technical regulatory issues that vary significantly across jurisdictions. Corporate counsel should be mindful of common—and sometimes…
Continue Reading Avoiding Pitfalls on the Path to Election Day: Common Political Law Risks for Corporations in Election SeasonGeorgia Governor Vetoes “Baby” FARA Bill
By Robert Kelner on
Posted in Foreign Agents Registration Act
Georgia Governor Brian Kemp has vetoed Georgia Senate Bill 368, which would have created a requirement in state law for certain “agents of foreign principals” to register and report certain lobbying and political activities in Georgia. This is the first of the wave of recently proposed baby FARA bills at…
Continue Reading Georgia Governor Vetoes “Baby” FARA BillStates Introduce More “Baby” FARA Bills
By Robert Kelner & Alex Langton on
Posted in Foreign Agents Registration Act
POSTED IN FOREIGN AGENTS REGISTRATION ACT, STATE LAW
Over the past several weeks, legislatures in Arizona, California, Georgia, Oklahoma, and Tennessee have introduced bills that mirror the federal Foreign Agents Registration Act (“FARA”). There has been a trend in the states to enact so-called “baby…
Continue Reading States Introduce More “Baby” FARA Bills