Foreign Agents Registration Act (FARA) & Covert Foreign Influence Laws

Foreign funding, international partnerships and policy advocacy are colliding with a much broader federal focus on the nonprofit sector. Since returning to office, the Trump Administration has ordered a government-wide review of federal funding to NGOs, while NSPM-7 has placed NGO involvement, funding networks and potential FARA violations within a wider national-security investigative framework. At the same time, congressional investigations, subpoenas and proposed foreign-donation disclosure requirements are increasing pressure on tax-exempt organizations to understand—and be prepared to defend—not only who funds their work, but how those relationships intersect with advocacy, communications and U.S. policy.

Key questions include:

• What nearly two years of Trump 2.0 tell us about where scrutiny of NGOs is actually heading in 2027
• How foreign donations, grants, fiscal sponsorships, international affiliates and foreign-funded partnerships can create FARA and adjacent foreign-influence risk
• Where foreign funding ends and foreign direction, control or agency begins
• How FARA intersects with congressional oversight, tax-exempt status, state AG scrutiny, sanctions/AML considerations and emerging state foreign-influence laws
• When religious, scholastic, academic, scientific and other FARA exemptions protect legitimate nonprofit activity—and where the difficult boundaries remain
• Preparing for congressional inquiries, subpoenas, government scrutiny or public allegations even when no formal FARA enforcement action has begun
• Building defensible intake, escalation, documentation and governance practices around foreign-funded or internationally connected activities
• Separating political noise from enforcement signals that should actually change an organization’s compliance strategy
• Identifying which changes in the NGO risk environment may outlast the 2026 election cycle—and what organizations should be preparing for now