In the last few years, the Department of Justice (“DOJ”) has substantially intensified enforcement of the Foreign Agents Registration Act (“FARA” or “the Act”). Letters of inquiry from DOJ’s FARA Registration Unit to potential registrants have increased in volume, and they now regularly contain more extensive, targeted requests for information and documents. DOJ has brought greater scrutiny to registrations under the Lobbying Disclosure Act to examine whether FARA registration, instead, is required. Criminal investigations of FARA-related violations have also increased, as exemplified by recent high-profile prosecutions. Given this heightened enforcement environment, companies and individuals engaged in activities potentially subject to FARA need an attorney who is knowledgeable about the statute, its implementing regulations, and DOJ’s enforcement policies and practices.
David H. Laufman is exceptionally qualified to help companies and individuals effect compliance with FARA and navigate the challenges of FARA-related administrative and criminal investigations. As Chief of DOJ’s Counterintelligence and Export Control Section from late 2014 to early 2018, Mr. Laufman closely oversaw DOJ’s administration of FARA and spearheaded the increased enforcement of the Act. He therefore possesses unique expertise to advise parties on whether they have an obligation to register under FARA, help them to satisfy FARA’s post-registration disclosure requirements, assist in responding to administrative requests for information, and represent them in investigative matters.