Navigating the Uncertainty Around the Commercial Exemption: How Practitioners are Applying the Exemption in the Wake of Recent Advisory Opinions

December 1, 2023 3:15pm

Adam Hickey
Partner
Mayer Brown LLP

William Minor
Partner
DLA Piper LLP, USA

  • Analyzing recent advisory opinions and their practical implications
  • New lessons for determining when an activity “directly promotes” the public or political interests of a foreign government or political party?
  • Recent investment and other activities that have unexpectedly come under FARA scrutiny
  • How far you need to go when conducting due diligence
  • The limits on exemptions for foreign commercial entities owned by a foreign government