Working Paper
Tiffany Lee
Federal Bureau of Investigation
Abstract
The Foreign Agents Registration Act (FARA) exempts foreign commercial entities who have registered under the Lobbying Disclosure Act of 1995 (LDA) from registering with the US Department of Justice (DOJ). However, if the lobbying efforts of these entities benefit a foreign power they are required to be registered under FARA, not LDA. This paper will demonstrate that foreign entities—potentially hundreds—are likely exploiting the LDA exemption to circumvent FARA requirements and obfuscate foreign lobbying efforts. This examination will reveal which foreign commercial entities are exploiting the LDA exemption, deepening the capabilities of academic researchers to explore the threat of foreign influence and unveil efforts to destabilize democracies, in the United States and beyond.
Content

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Supplementary material
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Works Cited for the Working Paper
Works Cited
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Compiled FARA Annual Spending Data
Structured spending data retrieved from publicly available Foreign Agents Registration Act Bi-Annual Reports.
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xlsx : 0.81 MB
LDA Foreign Client Data 2016-2019*
Structured data retrieved from the US Senate Lobbying Disclosure Act database on foreign addressed clients and their US registered lobbyists from 2016 to quarter one 2019. Some charts and graphs are available within.
Supplementary weblinks
DOJ FARA Bi-Annual Reports
US Department of Justice Foreign Agents Registration Act Bi-Annual Reports data.
US Senate LDA Database
US Senate Lobbying Disclosure Act forms database.