Workshop — A Complete Primer on FARA and the eFile System: Essential Takeaways on Key Definitions, Requirements and Compliance Program Components

Dec 5, 2024 1:30 pm – 05:00 PM

Heather Hunt
Senior Counsel for FARA Administration
FARA Unit
Counterintelligence and Export Control Section
National Security Division

U.S. Department of Justice

Keisha N. Stanford
Partner
Jenner & Block LLP

Prepare for the main conference by participating in this workshop, designed to get you up to speed and set the foundation for the in-depth, complex discussions to follow.

The workshop leaders will provide an essential overview of FARA requirements, the FARA eFile Systems and the core building blocks of FARA enforcement and compliance-and benefit from additional CLE credit and speaker-prepared reference materials.

Topics will include:

  • Defining “foreign agent” and “foreign principal” under FARA
  • What can trigger the need to register for:
    • Lobbying and public relations firms
    • Agents and their employers
    • Lawyers and law firms
    • Consulting firms
    • Non-profit groups
    • Universities and think tanks
    • Media
    • Trade associations
    • U.S. subsidiaries of foreign companies
  • The do’s and don’ts of using the FARA eFile System and common missteps to avoid Common pitfalls associated with using the filing process
    • common pitfalls associated with using the filing process
    • how much information is required to be submitted
    • how to streamline the filing system
  • Common misconceptions about FARA registration: When it is (and isn’t) required No de minimis threshold
  • What is meant by “at the order, request, or under the direction or control” of, a foreign principal”
  • Defining “political activities” and acting as a “public-relations counsel,” “publicity agent,” “information-service employee,” or “political consultant”
  • Representing the interests of a foreign principal before an agency or official of the United States Government
  • Assessing the nature and scope of activities by an “agent”
  • Overview of FARA Exemptions and DOJ Interpretations of:
    • The Commercial Exemption
    • LDA Exemption
    • Lawyers’ Exemption
    • Academic Exemption
  • The anatomy of a DOJ audit of a registered foreign agent
  • What is required by the DOJ for disclosure reports and copies of “informational materials”