Proposed DOJ FARA Rules Would Increase Uncertainty for Global Companies Amid Heightened Enforcement

The U.S. Department of Justice (DOJ) published a Notice of Proposed Rulemaking (NPRM) to update regulations under the Foreign Agents Registration Act of 1938 (FARA) on January 2, 2025. If adopted, DOJ’s proposed changes would give it more room to apply the 87-year-old counter-espionage law’s reporting requirements to the activities of global corporations, domestic subsidiaries of foreign companies, domestic nonprofits that take money from abroad, and public affairs and lobbying firms.