December 01, 2023
Navigating the Uncertainty Around the Commercial Exemption: How Practitioners are Applying the Exemption in the Wake of recent Advisory Options
Speaker:
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Source: ACI’s Foreign Assets Registration Act (FARA) Conference
Adam’s session was “Navigating the Uncertainty Around the Commercial Exemption: How Practitioners are Applying the Exemption in the Wake of recent Advisory Options.” The 2-person panel covered:
- How have DOJ inquiries changed, if at all?
- Examples of resolving disagreements with the DOJ
- How to move forward if your client has not registered (but should have)—amid the Retroactive Foreign Agents Registration Act
- Assessing the odds of approval for a request not to register – then v. now
- Predictions for the future of FARA compliance and enforcement
- DOJ v. defense counsel positions on the scope of privilege
- Recent positions of the FARA Unit
- DOJ’s recent expansion of investigative inquiries