Over its 87-year history, enforcement of the Foreign Agents Registration Act has ebbed and flowed.  Here is a snapshot of recent and current developments in FARA enforcement:

Late last month, President Trump issued a Presidential Memorandum that reprioritized FARA enforcement by directing federal agencies to investigate “non-governmental organizations and American citizens residing abroad or with close ties to foreign governments, agents, citizens, foundations, or influence networks engaged in violations of the Foreign Agents Registration Act.” 

In February 2025, U.S. Attorney General Pamela Bondi issued a wide-ranging formal Memorandum that appeared to pause most FARA enforcement actions:

The comment period on the Department of Justice’s ongoing FARA rulemaking closed earlier this week, on March 3rd.  The Department received a total of 16 substantive comments. 

On her first day in office, new U.S. Attorney General Pamela Bondi issued a wide-ranging formal Memorandum that includes an important section related to FARA:

The Department of Justice first expressed an intent to revise its FARA regulations back in December 2021 when it solicited comments from the public on several FARA-related topics.  The Department finally took the next step in that process after a three-year wait by posting a Notice of Proposed Rulemaking this past week. 

The Department of Justice in late November 2024 published a batch of 14 new Advisory Opinions that indicate the Department’s latest views on FARA. 

Linda Sun, an aide to New York State Governor Kathy Hochul, has been charged with violating and conspiring to violate the Foreign Agents Registration Act, visa fraud, alien smuggling, and money laundering conspiracy.

Two Russian nationals, Kostiantyn Kalashnikov and Elena Afanasyeva, remain at large after being charged with conspiracy to violate the Foreign Agents Registration Act and conspiracy to commit money laundering.

Pierre Girgis, a dual U.S.-Egyptian citizen, was originally charged in 2022 with acting as an unregistered agent of the Egyptian government, in violation of 18 U.S.C. § 951. 

An Informational Resource in a New Era of Foreign Agents Registration Act Enforcement.

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