EPR Editorial Team4 min read
Part of EPR's Public Affairs and Political Communications pillar. See also: Government Relations & Lobbying and the parent study, The China Lobbying Industry Map™ 2026.
The U.S. Justice Department has not announced a new FARA case in 20 months.
That is the longest case-free period in modern Foreign Agents Registration Act enforcement — and one of the clearest signals that the foreign-influence market is operating under a different regulatory posture than it did from 2017 through 2024.
The February 2025 Bondi memorandum helps explain why.
For practitioners working in or around the foreign-influence market — public affairs firms, communications counsel, in-house government affairs teams at companies with foreign exposure — the post-Bondi environment is materially different from the regime that preceded it. This piece breaks down what changed, what it means, and what to watch.
In February 2025, U.S. Attorney General Pam Bondi issued a memorandum curtailing FARA enforcement. The memo limited the Foreign Agents Registration Act's criminal application to cases involving "more traditional espionage" and ended the Foreign Influence Task Force — the cross-agency body established after the 2016 election to coordinate FARA-related investigations.
The February 2025 memorandum reframes FARA criminal enforcement as a tool for espionage cases rather than influence-activity cases. The practical effect: traditional FARA targets — foreign lobbying, foreign-funded advocacy, foreign-influenced media — face substantially reduced criminal exposure.
The distinction matters. FARA the statute is unchanged. FARA the enforcement policy is what shifted.
The memo did not repeal FARA. The statute remains in force. Registration requirements still apply. Civil enforcement remains technically available. But the criminal threat that drove much of FARA's deterrent effect over the past decade has been narrowed.
Three observable shifts since February 2025.
Established after the 2016 election to coordinate FARA-related investigations across DOJ, FBI, and other federal agencies, the task force operated as the institutional driver of FARA enforcement. Its dissolution removed the central coordinating body for foreign-influence cases.
The 20-month case-free window is the longest in modern FARA enforcement history. The 2017–2024 period saw a steady cadence of FARA announcements — sometimes multiple per quarter. That cadence has stopped.
FARA registrations and quarterly supplemental filings continue, but the enforcement context that drove disclosure precision has loosened. Practitioners report less aggressive inquiry from the DOJ FARA Unit on borderline registration questions.
The shift creates a different operating environment for foreign governments, state-owned enterprises, and foreign-headquartered companies engaging in U.S. influence activity.
Reduced perceived criminal-enforcement risk for activities that previously carried meaningful exposure — undisclosed foreign principal relationships, late filings, inaccurate filings, and the broader category of cases that drove FARA enforcement during the 2017–2024 period.
Continued reputational exposure is the residual constraint. Even without criminal enforcement, FARA filings remain public, scrapeable, and indexable. The 90-day disclosure delay still ends in public visibility. Reporters, opposition researchers, and competitors continue to mine the filings. The reputational cost of foreign-influence work has not gone away.
State-level exposure remains. State attorneys general retain enforcement authority over registration-adjacent activities — corporate disclosure, lobbying registration, campaign finance — that intersect with foreign influence. The federal pullback has not extended to state enforcement.
Enforcement environments shape markets. Firms hire differently, clients behave differently, and compliance priorities shift when the perceived risk of enforcement changes.
For U.S. firms representing foreign principals, the post-Bondi environment changes the risk calculus.
The China lobbying surge documented in EPR Research and 5W's China Lobbying Industry Map™ 2026 would likely have faced a different level of scrutiny in the prior enforcement regime. Tencent's seven-fold quarterly increase, the migration of Chinese-headquartered companies into direct federal lobbying, and the firms taking that work would have operated under closer DOJ posture.
The market for foreign-principal work has expanded — at least for now. Firms that previously declined foreign-government or foreign-corporate work over enforcement risk are reportedly reassessing. Firms that already operated in the space have additional headroom.
Compliance work remains necessary. Registration is still mandatory. The civil side of FARA is unchanged. Counsel is still required for any foreign-principal engagement. The post-Bondi environment is not a deregulation. It is a narrower criminal-enforcement posture.
The result is not the disappearance of compliance. It is a recalibration of risk.
Foreign-principal work remains regulated. The difference is that firms are evaluating that work through a different enforcement lens than they were several years ago.
Four signals worth watching.
Whether the next administration restores aggressive FARA enforcement. The current posture is policy-driven, not statutory. It can be reversed by memorandum the same way it was instituted.
Whether Congress moves on FARA reform legislation. Several FARA reform proposals have been introduced in recent Congresses, ranging from registration-threshold changes to enforcement-authority expansion. Any movement would reset the operating environment.
Whether the DOJ resumes active inquiry letters. Inquiry letters from the DOJ FARA Unit have historically been the leading indicator of enforcement activity — preceding case announcements by months or quarters. A resumption of that activity would signal a posture change before any new cases land.
Whether reputational consequences fill the criminal-enforcement gap. Public visibility of foreign-influence activity has not decreased. If reporters, opposition researchers, and state AGs continue to escalate the reputational cost of FARA-adjacent work, the practical effect of the Bondi memo may be less significant than the legal framework suggests.
For now, the post-Bondi environment is one of the more consequential — and least understood — shifts in the foreign-influence market in the last decade.
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.
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