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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

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

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

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

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

Amid Increased FARA Enforcement, New Advisory Opinions Narrow the Scope of Registrable Activity

Amid a rise in U.S. Department of Justice (DOJ) enforcement of the Foreign Agents Registration Act (FARA)—including an increase in criminal cases and staff dedicated to FARA investigations—last month the FARA Unit released...more

FARA Unit Continues Narrow Interpretation Of The Commercial Exemption

Last week’s release of advisory opinions related to the Foreign Agents Registration Act (FARA) – the first such opinions from the new Chief of the Department of Justice’s FARA Unit (the “Unit”) – signal that the Unit will...more

The CLOUD Act One Year Later: DOJ White Paper Aims to Promote Greater Understanding of the Act's Purpose and Impact

Since it was enacted in March 2018, the Clarifying Lawful Overseas Use of Data Act (CLOUD Act) has been controversial with privacy advocates in the United States and the subject of sustained criticism by the European...more

DOJ Signals Once More that FARA Is an Enforcement Priority

In another indication of the U.S. Department of Justice’s increased focus on the Foreign Agents Registration Act (FARA), Assistant Attorney General John Demers announced that the Department is overhauling its FARA enforcement...more

Senior DOJ Official Discusses the Department's Renewed Focus on FARA: What Companies Need to Know

During a Tuesday event at the Center for Strategic and International Studies in Washington, D.C., Assistant Attorney General of the National Security Division John Demers highlighted the renewed focus of the Department of...more

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