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Following several high profile cases and enforcement actions against individuals, companies, law firms, and public relations firms, many lawyers are reassessing compliance with the Foreign Agents Registration Act. Both in-house lawyers and lawyers in firms regularly engage in activities that may implicate the statute. Although many people incorrectly believe that FARA only applies to work for foreign governments, FARA also applies to activities conducted for foreign companies, individuals, associations, and anyone else outside the United States. Over the past several years, the Department of Justice has been reading the statute more broadly, and its exemptions more narrowly, increasing the FARA enforcement risks.
Robert K. Kelner and Brian D. Smith lead Covington & Burling LLP's FARA practice, including handling several of the most significant FARA enforcement actions in recent years, along with numerous FARA advisory matters.
The One-Hour Briefing will cover:
- The activities that trigger the registration and reporting requirements of the statute
- Key exemptions to registration and limitations on the use of the exemptions
- Recent trends related to FARA enforcement and DOJ's interpretation of the law
- Best practices for FARA compliance programs for companies and law firms seeking to avoid inadvertently triggering the statue