Article
Source: Law360
Article
By Jennifer Kennedy Gellie, Nicole Steinberg, Emily B. Erlingsson
11.04.25
In an article recently co-authored by a group of Pillsbury lawyers, the authors explain that Attorney General Pam Bondi’s first act in office was to disband the DOJ’s Foreign Influence Task Force and narrow Foreign Agents Registration Act (FARA) criminal enforcement to traditional espionage cases, reversing the post-2016 expansion of prosecutions. However, they note that President Trump’s subsequent executive actions—including labeling antifa a domestic terrorist group and issuing NSPM-7—signal a shift toward using FARA to target domestic actors allegedly linked to foreign influence or funding.
The authors caution that this indicates heightened enforcement scrutiny for nonprofits, universities and think tanks receiving foreign funds or advancing policy positions at odds with the administration. They also point out that, although a proposed rule clarifying FARA exemptions for nonprofits is unlikely to advance amid ongoing deregulation efforts, organizations with foreign connections should closely reassess their compliance obligations under FARA’s evolving interpretation.
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