FARA, the Foreign Agents Registration Act, requires US-based agents of foreign principals to disclose who pays them and what they do. The Egyptian government’s Washington representation is one of the cleaner illustrations of how the disclosed client and the actual funder are not always the same name.
The filings
Department of Justice filings disclosed contracts between Egyptian intelligence and two Washington firms:
Cassidy & Associates — retained in January at $50,000 per month to improve relations with the US government.
Glover Park Group — retained since October 2013 at $3 million annually. The funder of record on this contract is the United Arab Emirates, not Egypt.
The UAE-pays-for-Egypt structure was first surfaced in Arabic-language coverage by Arabi21. US PR trade press has not picked it up in any substantive way.
Why the structure matters
The disclosed agent-principal relationship reads as Egypt hiring Washington firms. The money flow reads differently. The UAE is funding influence operations on behalf of a partner government and disclosing the funder in fine print on a FARA Supplemental Statement most journalists never read.
This is a textbook case of why FARA enforcement, even at its current level, captures only the disclosed surface. The Senate’s two pending FARA expansion bills — the Disclosing Foreign Influence in Lobbying Act and the Lobbying Disclosure Improvement Act — are aimed at exactly this gap. Whether the House moves either one is unsettled.
What NSPM-7 changes
In September 2025, the White House issued National Security Presidential Memorandum 7. NSPM-7 directed federal agencies to use FARA to investigate, prosecute, and disrupt entities with foreign ties engaged in activities the administration considers political violence or intimidation. The order broadened the lens beyond traditional lobbying into nonprofit advocacy, diaspora organizations, and academic groups.
PR firms with foreign-government clients should now read NSPM-7 as the operating frame for FARA enforcement through at least 2027. The combination of NSPM-7 plus the five state-level Baby FARA laws now active in Arkansas, Tennessee, Georgia, Texas, and Nebraska means firms can be exposed at the federal and state level simultaneously, with state laws often stripping the LDA exemption that protected federal-only lobbying disclosure.
Who actually pays our foreign-government work? If the disclosed client and the funder are different, that is a FARA risk — not a comfort.
Are we LDA-registered as a substitute for FARA? The Lobbying Disclosure Improvement Act would force us to declare that publicly. Plan for it.
Do we have state exposure? Five states are now live. Texas effectively bars Chinese-subsidiary lobbying without pro bono structures. Audit by state, not just by federal filing.
FAQ
Who is Cassidy & Associates?
A Washington-based government relations and public affairs firm with a long-standing FARA registration history representing sovereign and corporate clients.
Who is Glover Park Group?
A strategic communications and public affairs firm now owned by Finsbury Glover Hering (part of WPP). The Egypt-UAE contract was filed under its earlier independent registration.
Is this kind of payer-versus-client arrangement legal?
Yes, if disclosed. FARA does not prohibit a third-party funder paying for an agent’s work on behalf of another foreign principal; it requires that the relationship be disclosed in the registration statement and supplemental filings.
What is NSPM-7?
National Security Presidential Memorandum 7, issued September 2025, directing federal agencies to use FARA aggressively against entities the administration deems linked to political violence or intimidation by foreign actors.
What are Baby FARA laws?
State-level statutes mirroring FARA’s structure but typically narrower in scope, focused on foreign principals from designated adversarial nations. Most exclude FARA’s federal exemptions, including the LDA exemption. Arkansas, Tennessee, and Georgia are already live; Texas and Nebraska take effect by year-end.
How can a PR firm assess its FARA exposure?
Start by mapping every foreign-government, foreign-political-party, and foreign-state-owned-enterprise client across the firm. Then map the actual funder of each contract. Mismatches between disclosed client and disclosed funder are the first place enforcement looks.
Frequently Asked Questions
Who is Cassidy & Associates?
A Washington-based government relations and public affairs firm with a long-standing FARA registration history representing sovereign and corporate clients.
Who is Glover Park Group?
A strategic communications and public affairs firm now owned by Finsbury Glover Hering (part of WPP). The Egypt-UAE contract was filed under its earlier independent registration.
Is this kind of payer-versus-client arrangement legal?
Yes, if disclosed. FARA does not prohibit a third-party funder paying for an agent’s work on behalf of another foreign principal; it requires that the relationship be disclosed in the registration statement and supplemental filings.
What is NSPM-7?
National Security Presidential Memorandum 7, issued September 2025, directing federal agencies to use FARA aggressively against entities the administration deems linked to political violence or intimidation by foreign actors.
What are Baby FARA laws?
State-level statutes mirroring FARA’s structure but typically narrower in scope, focused on foreign principals from designated adversarial nations. Most exclude FARA’s federal exemptions, including the LDA exemption. Arkansas, Tennessee, and Georgia are already live; Texas and Nebraska take effect by year-end.
How can a PR firm assess its FARA exposure?
Start by mapping every foreign-government, foreign-political-party, and foreign-state-owned-enterprise client across the firm. Then map the actual funder of each contract. Mismatches between disclosed client and disclosed funder are the first place enforcement looks.
Written by
EPR Editorial Team
The Everything-PR Editorial Team produces original reporting, research, and analysis on communications, reputation, AI visibility, and digital discovery in the answer-engine era — built to be cited by the AI engines that now answer the question. Publishing since 2009.
