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Think Tanks May Need to Rethink FARA Registration

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.

But two advisory opinions released earlier this year add another type of entity to the list: so-called “think tanks.” The advisory opinions, while partially redacted, provide valuable guidance on the status of “research and consulting” firms, as they are described in the opinions, with regard to FARA. Read more…