Compliance Notes - Vol. 6, Issue 6

RECENT LOBBYING, ETHICS & CAMPAIGN FINANCE UPDATES

Campaign Finance & Lobbying Compliance

Senate Judiciary Committee Chairman Chuck Grassley (R-Iowa) and Homeland Security and Governmental Affairs Committee Ranking Member Gary Peters (D-Mich.) introduced the Foreign Agents Transparency Act to ensure those acting in the United States as unregistered foreign agents are unable to avoid disclosure requirements under the Foreign Agents Registration Act (FARA). In 2022, a DC federal district judge ruled that a foreign agent could not be compelled to register retroactively as a foreign agent because he stopped lobbying on behalf of the Chinese government before the lawsuit was filed. The U.S. Court of Appeals for the D.C. Circuit upheld this ruling in 2024. Senators Grassley and Peters said that, if the Department of Justice (DOJ) sues an unregistered foreign agent to force compliance with FARA, the unregistered agent could decide to end the agent relationship and not be