In what may mark a sea change in enforcement of the Foreign
Agent Registration Act, for the first time in more than 30 years,
the Department of Justice has filed a complaint seeking to compel an individual
− the former Finance Chair of the Republican National
Committee, Stephen A. Wynn − to register as a foreign
agent.
Generally speaking, FARA is a disclosure regime that requires
individuals to register with the Attorney General if, on behalf of
foreign clients, they lobby U.S. government officials or seek to
influence the American public.
The DOJ alleges that in 2017, the then-Deputy Finance Chair of
the RNC, Elliott Broidy, acting as an agent for both the former
Vice Minister of Public Security for the People's Republic of
China, Sun Lijun, as well as for the PRC itself, enlisted Mr. Wynn
to assist in lobbying President Trump and his administration to
remove a Chinese billionaire businessman, Guo Wengui, from the
United States. After leaving China in 2014, Mr.
