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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

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

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

Preserving Data from Personal Devices and Third-Party Messaging Platforms – What Should Companies Do?

Deputy Attorney General (DAG) Lisa Monaco’s September 15, 2022, memorandum on revisions to the Department of Justice’s (DOJ) Corporate Enforcement Policies (the Monaco Memo) reflects that preservation of business...more

Proposed Registration Requirements for UK Foreign Influence Activities

The UK government has proposed new registration requirements for foreign influence activities in the UK as part of its attempts to strengthen the resilience of the UK’s political system and democratic institutions against...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

Justice Department Announces Launch of Task Force “KleptoCapture” focused on Russia-related Sanctions Violations

On March 2, 2022, the U.S. Department of Justice announced the launch of Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the unprecedented sanctions, export, and other measures taken...more

Department of Justice Signals Its Growing Focus on Cryptocurrency Enforcement

On February 17, 2022, Deputy Attorney General (DAG) Lisa Monaco announced a significant step in advancing its cryptocurrency-related enforcement priorities by naming the first leader of the National Cryptocurrency Enforcement...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

U.S. Government Takes Increasingly Aggressive Actions Targeting Ransomware

On November 8, 2021, the U.S. Department of Justice (“DOJ”), U.S. Department of the Treasury (“Treasury”), and the U.S. Department of State (“State”) made several significant announcements regarding recent U.S. government...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

DOJ Announces Resolution Of First-Ever Voluntary Self-Disclosure Related To Export Control And Sanctions Violations

On April 29, 2021, the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the District of Massachusetts (collectively, “DOJ”) announced that DOJ entered into a precedent-setting...more

DOJ Clarifies Incentives for Voluntary Self-Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the Department of Justice’s National Security Division (“NSD”) announced a revised policy to encourage voluntary self-disclosures (“VSDs”) of criminal violations of export control and sanctions laws. The...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

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