Department of Justice Proposes Major Changes to FARA Regulations, Including Sweeping Changes Affecting Multinational Companies

On January 2, 2025, the Department of Justice published a Notice of Proposed Rulemaking soliciting public comments on potential amendments to the Department’s regulations regarding the Foreign Agents Registration Act. The regulatory amendments proposed by the Department are significant, and they would take the statute in a substantially different direction. As detailed in this client advisory, the proposed changes would completely overhaul an exemption for commercial activity by foreign corporations, which has existed in its current form for more than two decades, and make other consequential changes, including changes to an exemption for lawyers representing foreign interests.

This advisory details the Department’s proposed revisions to the regulations and the implications of these proposed changes for multinational corporations, law firms, nonprofits, lobbying and consulting firms, public relations companies, and other organizations that may engage in activity within the scope of the statute.