International Trade

Foreign Agents Registration Act (FARA)

As a unique capability of our International Trade Practice, Fluet attorneys provide guidance on the Foreign Agents Registration Act (FARA), as the need to carefully consider FARA obligations, burdens, and alternatives, can impact companies and principles in significant ways. Notably, since the statute is broad enough to encompass something as innocuous as a meeting request, or letter sent on behalf of a customer, thoughtful consideration of the regime and potential risks associated with various courses of action is critical.

While there are several exemptions to FARA, they can be vague and subject to interpretation. As such, we proactively work to help clients determine eligibility for an exemption, as failure to register can carry significant penalties.

Fluet attorneys assists clients in navigating FARA by:

  • Analyzing proposed activities to determine whether registration is required and appropriate.
  • Seeking advisory opinions from the Department of Justice’s (DOJ) FARA Unit on specific exemptions, if needed.
  • Reviewing proposed activities relationships for FARA related issues.
  • Interpreting DOJ FARA guidance in accordance with the latest regulations and case law.
  • Advising on potential exemptions for commercial, legal, or other activities.

International Trade Co-Chairs

Our attorneys are adept at both structuring and negotiating international transactions and managing the regulatory risks that are unique to global operations, all while leveraging a deep understanding of U.S. foreign policy and U.S. national security interests.