Haydn Forrest on Foreign Agents

D.C. Circuit Limits DOJ’s Ability to Retroactively Enforce FARA

Last week the D.C. Circuit released its long-anticipated opinion in the Attorney General v. Wynn, holding that the Department of Justice (“DOJ”) could not compel Steve Wynn to retroactively register under the Foreign Agents...more

6/14/2024 / Department of Justice (DOJ) , Foreign Agents , Foreign Agents Registration Act (FARA) , Foreign Nationals , National Security , Retroactivity

FARA Officials Preview Major Regulatory Changes and Identify New Areas of Focus

The U.S. Department of Justice (DOJ) recently provided fresh insights into upcoming regulatory changes to key Foreign Agents Registration Act (FARA) exemptions and discussed new areas of concern. These insights were shared at...more

12/7/2023 / Advanced Notice of Proposed Rulemaking (ANPRM) , Department of Justice (DOJ) , Exemptions , Foreign Agents , Foreign Agents Registration Act (FARA) , Foreign Governments , Sovereign Wealth Funds

Third FARA Lawsuit Shows Focus on Civil Enforcement

On April 25, 2023, the U.S. Department of Justice (“DOJ”) filed a civil enforcement action seeking to compel the Federación de Alcades Pedaneo (“FDAP”) to comply with requirements for registrants under the Foreign Agents...more

6/15/2023 / Deficiency Notices , Department of Justice (DOJ) , Enforcement , FDAP , Foreign Agents , Foreign Agents Registration Act (FARA) , National Security

New Advisory Opinion Extends FARA to Online Networks and Service Providers

In an advisory opinion released last week by the U.S. Department of Justice (DOJ) Foreign Agents Registration Act (FARA) Unit, DOJ adopts a potentially expansive interpretation of FARA that could require online networks,...more

5/5/2023 / Advanced Notice of Proposed Rulemaking (ANPRM) , Advisory Opinions , Department of Justice (DOJ) , Foreign Agents , Foreign Agents Registration Act (FARA) , Foreign Governments , Public Disclosure , Public Relations , Social Media

FARA’s Big Finish

At the beginning of the year, we predicted that 2022 would be the next big year for the Department of Justice’s (DOJ) enforcement of the Foreign Agents Registration Act (FARA). And 2022 delivered, though not always in ways...more

12/22/2022 / Department of Justice (DOJ) , Foreign Agents , Foreign Agents Registration Act (FARA) , Lobbying , Lobbying Disclosure Act , Registration Requirement , Venezuela

A Win for Wynn: Judge’s Dismissal of Civil Case Against Steve Wynn Could Fundamentally Change FARA Enforcement

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

10/21/2022 / Department of Justice (DOJ) , Foreign Agents , Foreign Agents Registration Act (FARA) , Foreign Governments , Foreign Nationals , National Security , Registration Requirement , Reporting Requirements

Court Documents and Retroactive Registration Show Continued Focus on Expansive FARA Enforcement

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

6/14/2022 / Department of Justice (DOJ) , Foreign Agents , Foreign Agents Registration Act (FARA) , Foreign Governments , Foreign Nationals , National Security , Registration Requirement , Reporting Requirements

DOJ Seeks to Require U.S. Businessman to Register as a Foreign Agent on Expansive Agency Theory

Earlier this week, the U.S. Department of Justice (DOJ) filed a civil enforcement action seeking to compel U.S. businessman Steve Wynn to register under the Foreign Agents Registration Act (FARA) as an agent of the Chinese...more

5/23/2022 / Asylum , China , Department of Justice (DOJ) , Foreign Agents , Foreign Agents Registration Act (FARA) , Foreign Governments , Foreign Nationals , Registration

DOJ Intends to Significantly Change FARA for the First Time in Decades

Last week the U.S. Department of Justice (DOJ) announced that it is seeking public comment as it considers substantive updates to the implementing regulations of the Foreign Agents Registration Act (FARA) for the first time...more

12/16/2021 / Advanced Notice of Proposed Rulemaking (ANPRM) , Department of Justice (DOJ) , Exemptions , Foreign Agents , Foreign Agents Registration Act (FARA) , Foreign Governments , Notice of Proposed Rulemaking (NOPR) , Registration , Religious Exemption

Haydn Forrest

Morrison & Foerster LLP

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