At today’s #FARAForum, DOJ’s Adam Hickey reiterates how broad DOJ views the law. 1/
Some key takeaways: a) DOJ’s view is that one cannot avoid #FARA by sitting outside the US and using the internet to target US audiences; and b) foreign media are not automatically exempt. DOJ cares about editorial independence/control; 2/
C) US subsidiaries of foreign entities may be required to register. Merely having a US-based sub isn’t sufficient to create an exemption.
D) confirming what the bar has believed for some time: while #FARA is “threat agnostic”, and prosecutors will follow the facts, DOJ *will* prioritize resources on unfriendly regimes
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