Navigating the Foreign Agents Registration Act's Shifting Sands: What To Make of DOJ's New Enforcement Priorities

In a recent memorandum, Attorney General Pam Bondi outlined changes to specific Department of Justice enforcement priorities. Partners Ki Hong and Charles Ricciardelli and associate Alexa Santry discuss these changes, focusing on the Foreign Agents Registration Act (FARA). Along with the still-pending Notice of Proposed Rulemaking from the Biden administration, the changes create a dilemma for corporations trying to understand FARA's exemption for certain commercial activities.