The number of persons and entities registering with the Department of Justice (DOJ) as foreign agents under the Foreign Agents Registration Act (FARA) is on the rise. According to DOJ FARA Registration Unit, the number of new primary registrations had grown from 69 in 2016 to 102 in 2017. Likewise, short form registrations had grown from 549 in 2016 to 713 in 2017. The statistics for 2018 already suggest another year of growth. According to the DOJ, in the first five months alone, there were 52 new primary registrations and 383 short form registration statements filed.
The growth in FARA registrations has been attributed to a number of events, including a September 2016 Audit Report of the DOJ Office of Inspector General, the October 2017 Indictment related to the investigation by DOJ Special Counsel Robert S. Mueller III, the November 2017 FARA registrations related to the Russian-owned RT Network, and a number of legislative proposals in 115th Congress throughout 2017 and 2018. Consider the following examples of recent FARA-related activity:
While we are not yet certain of the exact parameters of a final FARA bill given the congressional and media attention the issue is getting, we expect (1) more registrations, (2) more enforcement actions, (3) and a legislative update to the this World War II era law.
We are watching this one closely, and will keep providing updates. Please contact Holland & Knight should you have a question regarding FARA registration obligations or desire assistance in your review or completion of FARA reporting.
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