Foreign Agents Registration Act

President Trump’s pick for Attorney General, Pam Bondi, took quick action upon her swearing in on February 5, 2025, to make changes within the Department of Justice (“DOJ”) via the issuance of fourteen separate memorandum directives to DOJ employees. The memoranda kick-off Bondi’s efforts to re-calibrate DOJ policies, enforcement priorities, and internal procedures to align with broader policies of the Trump administration. Two of the memoranda in particular, one laying out a “General Policy Regarding Charging, Plea Negotiations, and Sentencing” (“General Policy Memorandum”) and the other focused on the “Total Elimination of Cartels and Transnational Criminal Organizations” (“Cartel Policy Memorandum”), include several key changes related to the DOJ’s enforcement of corporate crime, corruption, and national security-related laws.

When considering who must register under the Foreign Agents Registration Act (“FARA” or “the Act”), one normally thinks of individuals, law firms, or marketing firms, the typical kinds of agents that must register for lobbying or image-laundering activities on behalf of foreign persons. 

The Foreign Agents Registration Act of 1938 (“FARA” or “the Act”) is a controversial disclosure law that aims to combat covert foreign influence in the United States by promoting transparency with respect to the political, media, and public relations activities of so-called “agents of foreign principals.”