The Department of Justice announced on Jan. 17, 2019, that it had reached a settlement with a law firm over the failure to properly register and report under the Foreign Agents Registration Act (FARA). This settlement appears to be a significant escalation in the enforcement of FARA and could be a preview of other FARA enforcement cases in the near future.
In addition, Congress is considering changes to both FARA and the Lobbying Disclosure Act (LDA). Senator Chuck Grassley (R-IA) stated during Attorney General-nominee William Barr's confirmation hearing on Jan. 15, 2019, that he is still interested in pursuing these legislative changes.
Accordingly, all individuals and entities representing foreign clients in the United States must take steps to ensure compliance with FARA. Further, all individuals and entities advocating before the U.S. government must determine whether they must register and report under either FARA or the LDA.