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Lobby Horse

Foreign agent disclosures already down more than 30%

After the Trump administration said it won't make enforcing the law a priority, the results are coming in

Analysis | QiOSK

Enjoy our new column by the Democratizing Foreign Policy team exposing stealth corruption infecting our system — in plain sight.

Disclosure under the nation’s preeminent law for regulating foreign influence in America is plummeting.

A review of Foreign Agents Registration Act (FARA) filings shows that disclosure of informational materials — items such as one-pagers and lobbyist talking points that are distributed to influence policy and public opinion — is down over 30 percent in the first quarter of 2025, compared to this time last year and over 40 percent compared to 2022.

This follows repeated efforts by the Trump administration to curtail investigations and enforcement of FARA and other foreign influence laws.

In one of her first acts as attorney general, Pam Bondi — who was previously registered under FARA to represent the Qatari government — took a sledgehammer to FARA in a memo making clear that FARA was no longer a priority and that she would only bring criminal charges under the law in “instances of alleged conduct similar to more traditional espionage by foreign government actors.”

The Trump administration took the memo in stride, gutting efforts to combat foreign influence in America. The new administration is reportedly forcing out dozens of government officials flagging foreign interference in U.S. elections, including teams tracking cyberattacks and influence operations. Several government bodies working on these issues have been dismantled entirely, including the State Department’s Global Engagement Center and the FBI’s Foreign Influence Task Force. A Justice Department memo from late March reportedly called to reduce “the number of attorneys working on investigations and prosecutions related to the Foreign Agents Registration Act.”

The result of all this is a perverse incentive system where foreign powers are emboldened to disclose far less about their efforts to influence the American political system. We’re already seeing the results of this in reduced filings under FARA and multiple sources that spoke to us on condition of anonymity confirmed that foreign embassies are reviewing their FARA disclosures in light of the Bondi memo.

Even before the Trump administration gutted foreign influence oversight, foreign governments were seeking ways to avoid FARA registration altogether. The Trump administration has effectively given foreign powers the green light to move their foreign influence operations entirely underground, while Americans still have to play by the rules. If an American organization hires a lobbying firm, for example, they have to report it to the U.S. government under the Lobbying Disclosure Act, which has not been gutted.

In short, we’re quickly approaching the point where American citizens that want to influence their own government have to be more transparent about it than a foreign dictator.

Foreign influence is also on the rise in America — making this the worst possible time to pump the brakes on FARA enforcement. In 2016, the top 10 most active countries disclosed a combined $205 million on lobbying. In 2023, that number ballooned to a whopping $742 million. Similarly, foreign governments have increased their funding across D.C.’s foreign policy think tanks by 30% in the past five years, with the highest donor being the United Arab Emirates, as we discovered in creating the Think Tank Funding Tracker.

Incidents of foreign powers being caught engaging in illicit influence operations have also gone up in recent years, many of which included prominent elected officials. But now, because of the Trump administration’s changes to foreign influence enforcement, lawyers for the people caught up in these cases are seeking — and in some cases getting — reprieve from a sympathetic Trump administration.

“Some have requested that the Justice Department drop pending charges, or have suggested they are planning to make such requests,” wrote Ken Vogel in the New York Times. “Others are expected to use the directives to seek clemency from Mr. Trump or leniency in dealings with prosecutors, according to people familiar with the reactions to the changes ordered by the new administration.”

Former Senate Foreign Relations Committee Chair Bob Menendez (D-N.J.), for example, was caught taking gold bars from Egypt in exchange for political favors such as giving the go-ahead for arms sales. After being convicted and sentenced to prison for 11 years, Menendez appealed to the president on X.“President Trump is right. This process is political and has been corrupted to the core,” he said.

Similarly, lawyers for Rep. Henry Cuellar (D-Texas) — who was indicted last May for bribery and acting as a foreign agent while a sitting member of Congress — see the Trump administration’s shift on FARA as an opportunity. “The new policy largely affirms our position in the case,” Eric Reed, a lawyer for Mr. Cuellar, said in an interview with the Times. “We’re evaluating the new policy and assessing the best manner to address it with the Department of Justice.”

While Menendez and Cuellar are still seeking a reprieve from their alleged transgressions, New York City Mayor Eric Adams has already gotten it. Adams was indicted last year for allegedly accepting $123,000 in travel benefits and tens of thousands of dollars in illegal campaign contributions from Turkish nationals. Then the charm offensive began; Adams met with Trump in Mar-a-Lago, praised Elon Musk, and skipped two scheduled events in New York in order to attend the inauguration. With Trump’s intervention, last week a judge begrudgingly dismissed the charges against Adams, writing that he couldn’t force federal prosecutors to pursue charges.

"Everything here smacks of a bargain: dismissal of the Indictment in exchange for immigration policy concessions," the judge said.

All of this flies in the face of Bondi’s justification for crippling America’s ability to counter foreign influence operations: that it had been politicized. To be sure, FARA is an overbroad, vague statute that can be, and has been, politicized. The International Center for Non-Profit Law has tracked dozens of congressional investigations into U.S. non-profits, many of which called for the non-profit to be investigated for not registering under FARA. But, these are politicized accusations by Congress, not prosecutions by the Department of Justice.

The fact is that actual prosecutions for FARA related charges in recent years have not been politicized, despite the well-meaning concerns of non-profit groups and the self-serving alarmism of law firms that have created a cottage industry advising clients concerned about FARA compliance. In fact, all of the high-profile cases brought during the Biden administration were Democrats, including Cuellar, Menendez, and Adams (a Democrat whose case was dismissed by Trump). Sue Mi Terry, the wife of ardent Trump critic Max Boot who once called Trump a foreign asset, was also indicted for FARA violations during the Biden administration.

But, the larger problem is that even if you buy the argument that FARA has been politicized, that doesn’t mean that you should dismantle our government’s ability to track foreign influence operations in America. While it’s still too early to know exactly how the Trump administration’s FARA sledgehammer will play out, we are barrelling towards a wild west of unregulated foreign influence with a sheriff that is nowhere to be found. In this lawless land, foreign powers will be all too eager to work toward secretly bending U.S. foreign policy to their will.


Top image credit: Khody Akhavi
Analysis | QiOSK
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