News & Analysis as of

Foreign Agents Registration Act (FARA) Enforcement Actions National Security

Morrison & Foerster LLP

FinCEN Targets Three Mexico-Based Financial Institutions with Sanctions Under New Authority to Address Money Laundering Associated...

On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...more

Saul Ewing LLP

Early Prosecutions Offer Glimpse Into Trump Administration’s National Security Enforcement Focus

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The recent announcements in three U.S. Department of Justice (“DOJ”) national security prosecutions offer an early glimpse into some of the Trump Justice Department’s enforcement priorities. Indeed, these actions are...more

Wiley Rein LLP

Sens. Grassley and Peters Introduce Foreign Agents Transparency Act to Enable DOJ to Require Retroactive FARA Registration

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On March 13, 2024, Senator Chuck Grassley (R-IA), Chairman of the Senate Judiciary Committee, and Senator Gary Peters (D-MI), Ranking Member of the Homeland Security and Governmental Affairs Committee, introduced the Foreign...more

ArentFox Schiff

White Collar and Enforcement Outlook 2025

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With 2025 underway, the ArentFox Schiff White Collar team highlights the US Department of Justice’s (DOJ) new enforcement priorities and two cases pending before the US Supreme Court that could have sweeping implications for...more

Saul Ewing LLP

The Foreign Agents Registration Act: 2024 Year in Review and Outlook for 2025

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Executive Summary - We entered 2025 with the world in turmoil, a new American administration in the White House, and various global actors—friends and foes alike—still actively vying for the attention of the American public. ...more

Torres Trade Law, PLLC

DOJ Memoranda Impact FCPA, FARA, and Other National Security Enforcement Priorities

President Trump’s pick for Attorney General, Pam Bondi, took quick action upon her swearing in on February 5, 2025, to make changes within the Department of Justice (“DOJ”) via the issuance of fourteen separate memorandum...more

Morgan Lewis

The State of FARA Following Attorney General Bondi’s Reprioritization of DOJ Resources

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On her first day in office, Attorney General Pam Bondi published several memorandums laying out the reprioritization of US Department of Justice (DOJ) efforts and funding, including the memorandum General Policy Regarding...more

Mayer Brown

US DOJ Outlines New Enforcement Priorities for Corporations and Individuals

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On Wednesday, February 5, 2025, the newly confirmed Attorney General (AG) Pam Bondi issued fourteen memoranda to all Department of Justice (DOJ or the “Department”) employees regarding a wide range of new policies and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Attorney General Issues New Policy on Prosecutorial Discretion and Enforcement Priorities

On February 5, 2025, the Office of the Attorney General issued a new policy to all Department of Justice (DOJ or Department) employees highlighting the boundaries of prosecutorial discretion with respect to charging, plea...more

Snell & Wilmer

FARA's Pendulum: Shifts in Foreign Agent Regulation

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On her first day in office, Attorney General Pamela Bondi issued a memorandum signaling a significant shift in the Department of Justice’s (DOJ) approach to Foreign Agents Registration Act (FARA) enforcement. The memorandum...more

Nossaman LLP

Attorney General Walks Back FCPA to Focus on “Total Elimination of International Drug Cartels”

Nossaman LLP on

The proposed expansion of the Foreign Agent Registration Act (FARA) further into private commercial activity published in the Federal Register just over a month ago may be halted due to one of the first directives issued by...more

Skadden, Arps, Slate, Meagher & Flom LLP

Attorney General Announces Shift in Foreign Agents Registration Act Enforcement Priorities

In a memorandum published on February 5, 2025, newly confirmed Attorney General Pam Bondi announced sweeping standards for the Department of Justice’s (DOJ’s) exercise of prosecutorial discretion and charging decisions. The...more

Baker Botts L.L.P.

Compliance and Enforcement Takeaways from the Attorney General’s February 5, 2025 Memos

Baker Botts L.L.P. on

On February 5, 2025, the newly sworn-in United States Attorney General, Pamela Bondi, issued 14 memos to DOJ employees. The memos make clear that, under AG Bondi, DOJ’s enforcement efforts will focus on (i) immigration...more

Paul Hastings LLP

DOJ Announces Significant Proposed Changes to Amend and Clarify FARA

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On December 19, 2024, the Department of Justice (DOJ) published a Notice of Proposed Rulemaking (NPRM) intended to “update and clarify” the regulations under the Foreign Agents Registration Act (FARA). The proposed changes to...more

Morgan Lewis

DOJ’s Latest Attempt at Modernizing FARA Signals Greater Focus on Compliance and Enforcement

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Following a decade of increased enforcement of what has been considered an oft-confusing law, the Department of Justice recently published a Notice of Proposed Rulemaking proposing several changes to regulations implemented...more

Jenner & Block

Client Alert: FARA Unit Enters Landmark DPAs to Resolve Lobbyists’ FARA Violations

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Earlier this year, the Department of Justice’s (DOJ) Foreign Agents Registration Act (FARA) Unit entered into what appeared to be the first publicly announced deferred prosecution agreements (DPAs) to resolve alleged FARA...more

Wiley Rein LLP

New Civil Enforcement Action Filed to Compel FARA Registration for Lobbying Activities on Behalf of China

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On May 17, 2022, the Department of Justice (DOJ) sued in U.S. District Court in D.C. to compel Stephen A. Wynn to register under the Foreign Agents Registration Act (FARA) as an agent of the People’s Republic of China (PRC)....more

The Volkov Law Group

DOJ Charges United States/Russian National with Acting as an Illegal Agent under FARA

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In another action targeting Russian actors and connections, the Justice Department indicted Elena Branson, a dual United States-Russian national with criminal evasion of Foreign Agents Registration Act (“FARA”) registration...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Steps Back From China Initiative but Remains Focused on China-Related Enforcement

On February 23, 2022, Assistant Attorney General (AAG) Matthew Olsen, the head of the Department of Justice’s (DOJ) National Security Division (NSD), announced that a review of the China Initiative begun under the Trump...more

Bracewell LLP

Biden Administration Prioritizes Increased and Broadened Anti-Corruption Enforcement

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On June 3, 2021, the White House issued a memorandum announcing anti-corruption as a core national security interest. The memorandum explains that, “[c]orruption threatens United States national security, economic equity,...more

Wiley Rein LLP

DOJ Charges Trump Fundraiser for Conspiring to Act as a Foreign Agent

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As yet another example of the U.S. Department of Justice’s (DOJ’s) increasing enforcement efforts with respect to the Foreign Agents Registration Act (FARA), DOJ recently unsealed a charge of conspiracy to violate FARA...more

ArentFox Schiff

Investigations Newsletter: Elder Care Companies Agree to Pay $15.5 Million to Resolve False Claims Act Allegations

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Headlines that Matter for Companies and Executives in Regulated Industries - Health Care Enforcement News - Elder Care Companies Agree to Pay $15.5 Million to Resolve False Claims Act Allegations - The Department...more

Polsinelli

Emerging Trend: DOJ Turns to Rarely Used FARA Statute in Recent Surge in Prosecutions

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Earlier this year, the Assistant Attorney General for the National Security Division publicly confirmed the Department of Justice’s (“DOJ”) intention to make Foreign Agents Registration Act (“FARA”) a criminal enforcement...more

WilmerHale

An Introduction to the Foreign Agents Registration Act for Firms Assisting Foreign Clients in the United States

WilmerHale on

After decades in which the Foreign Agents Registration Act (FARA) received relatively little attention, a confluence of recent events has given the statute newfound prominence. Together, these developments compound the...more

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