FARA Foreign Agent Registrations: The Federal Database Behind Foreign Lobbying and Influence Disclosure

The Foreign Agents Registration Act database maintained by the DOJ National Security Division is the federal government authoritative record of foreign influence operations in the United States—covering every individual and firm registered as a foreign agent, the foreign governments and entities that retained them, and the lobbying activities, media campaigns, and political contacts conducted on their behalf, with 6-month supplemental statements disclosing fees received and disbursements made.

This article covers the statutory basis of FARA, the categories of persons who must register and the significant exemptions that create enforcement gaps, the database structure and filing mechanics, the history of enforcement including the 2017–2019 surge triggered by the Mueller investigation, the largest disclosed foreign spending operations by country and principal, the eFiling system and its programmatic API, a Python workflow for querying registration and disbursement data, and the structural limitations that researchers and journalists must understand when working with the dataset.

What FARA is

The Foreign Agents Registration Act, codified at 22 U.S.C. §§ 611–621, was enacted by Congress in 1938 in direct response to Nazi propaganda operations in the United States. German agent George Sylvester Viereck had been disseminating pro-Nazi materials through American newspapers and members of Congress without disclosing his relationship with the German government. The original FARA required agents of foreign principals to register with the State Department and file disclosure statements identifying their principal, their activities, and any political propaganda they distributed.

The Act was substantially amended in 1966 to shift its focus from political propaganda to lobbying and to move administration from the State Department to the Department of Justice. The 1966 amendments narrowed the definition of a “foreign agent” and introduced the Lobbying Disclosure Act exemption that would become the statute's most significant enforcement gap. Today FARA is administered by the FARA Unit within the DOJ National Security Division (NSD), which was created after the September 11 attacks and consolidated counterterrorism, counterintelligence, and export control enforcement under a single assistant attorney general.

The core purpose of FARA, as the DOJ NSD describes it, is to ensure that the US government and the American people can identify the source of information and advocacy from agents of foreign principals so that they can evaluate the information in context. Unlike campaign finance disclosure, which covers domestic political spending, FARA focuses specifically on foreign-directed influence—the activities that foreign governments, foreign political parties, and foreign commercial entities conduct in the United States through American intermediaries. Criminal penalties for willful FARA violations can reach five years of imprisonment under 22 U.S.C. § 618.

Who must register

FARA requires registration by any person who acts as an agent, representative, employee, servant, or attorney of a foreign principal and who engages in political activities, acts as a public relations counsel, acts as a publicity agent, acts as an information service employee, or acts as a political consultant on behalf of that principal. The statutory definition of “foreign principal” covers foreign governments, foreign political parties, foreign nationals (individuals who are not US citizens or legal permanent residents), and entities organized under the laws of a foreign country or with a principal place of business in a foreign country.

“Political activities” is defined broadly under 22 U.S.C. § 611(o) to include any activity intended to influence any official of the United States government or any section of the public with reference to formulating, adopting, or changing the domestic or foreign policies of the United States, or with reference to the political or public interests, policies, or relations of a government of a foreign country. This definition reaches beyond traditional lobbying to include media relations, advertising campaigns, think tank publications, and social media operations conducted on behalf of a foreign principal.

Exemptions

FARA contains six exemptions in 22 U.S.C. § 613 that exclude certain categories of agents from the registration requirement. The most important in practice are:

Lobbying Disclosure Act exemption (22 U.S.C. § 613(h)):An agent who registers under the Lobbying Disclosure Act of 1995 and whose foreign principal is not a foreign government or foreign political party may satisfy the LDA registration instead of FARA. This exemption was intended to avoid double registration for commercial lobbyists representing foreign corporations, but it has become the most criticized gap in FARA enforcement. Because the LDA requires only quarterly disclosure of aggregate spending (rather than the detailed 6-month supplemental statements required by FARA), and because LDA registrants do not disclose specific political contacts, the LDA exemption significantly reduces transparency for foreign commercial lobbying. The DOJ Inspector General's 2016 report on FARA enforcement specifically identified the LDA exemption as a major limitation.

Diplomatic personnel exemption (22 U.S.C. § 613(a)):Diplomatic and consular officers, and staff members accredited by the State Department and whose names appear on the State Department diplomatic list, are exempt. This preserves the ordinary functioning of foreign embassies and consulates under the Vienna Convention and does not create a meaningful gap because embassy personnel are already identifiable through State Department records.

Commercial and non-political exemptions (22 U.S.C. §§ 613(d)–(e)):Agents whose activities are not directed at influencing US government policies or at domestic political opinion, and whose activities consist solely of private and non-political activities in furtherance of a bona fide commercial, industrial, or financial operation of a foreign principal, may claim a commercial exemption. Academic exchanges, religious activities, and humanitarian assistance may also qualify for separate exemptions.

The registration database structure

The FARA database consists of four primary record types that together document the relationship between a registered agent and a foreign principal and the ongoing activities conducted under that relationship.

Registrant records: The foundational record type. Each firm or individual that files a FARA registration (Form RA-1) receives a unique Registrant ID. The RA-1 identifies the registrant (name, address, legal form of business, citizenship), the foreign principal being represented (name, country, address, and nature of the principal's business), the nature of the agent-principal relationship, and the activities the agent will conduct on the principal's behalf. The RA-1 must be filed within ten days of entering into an agreement with a foreign principal to act as an agent.

Foreign principal records: Each foreign principal represented by a registrant is separately identified in the database. A single registrant may represent multiple foreign principals simultaneously, each requiring a separate entry. The foreign principal record includes the principal's name, country of origin, principal address, and the nature of its business or governmental function. The relationship between registrant and foreign principal is the core organizing unit of the FARA database.

Supplemental statements (Form NSD-3): Every active registrant must file a supplemental statement every six months disclosing the activities conducted on behalf of each foreign principal during the period. The NSD-3 requires itemization of political activities, contacts with US government officials, media contacts, disbursements made in the course of the representation, and compensation received. The disbursement and compensation figures are the primary financial data available in the FARA database and are the basis for analysis of which foreign principals are spending the most on US influence operations.

Exhibits: Copies of informational materials, political propaganda, and other documents disseminated by the registrant on behalf of the foreign principal must be filed as exhibits. Exhibit filings include press releases, policy briefs, social media content, advertising materials, and correspondence with US government officials. The exhibit files, available through the FARA Electronic Reading Room at justice.gov/nsd-fara, are often the most substantively revealing documents in the FARA record because they show the actual content of foreign-directed information operations.

Disclosure requirements

The semi-annual supplemental statement (Form NSD-3) is the primary disclosure mechanism under FARA and significantly more detailed than the quarterly reports required under the Lobbying Disclosure Act. Supplemental statements must be filed within 30 days of the end of each 6-month reporting period (January–June and July–December).

Political activity disclosures in the NSD-3 require a detailed description of each political activity conducted during the period, including the date, the nature of the activity, and the persons contacted. “Political activities” for this purpose includes lobbying meetings with members of Congress and their staff, meetings with executive branch officials, testimony before congressional committees, communications with state or local government officials on matters of federal policy concern, and media outreach intended to influence domestic political opinion.

Disbursement disclosures require itemization of all expenditures made in connection with the representation of the foreign principal, including payments for advertising, public relations services, research, travel, entertainment, and contributions to third-party organizations. Receipts include all compensation and reimbursements received from the foreign principal during the period. Where a law firm or lobbying firm represents a foreign principal, the compensation figure reflects the total fees charged to the principal during the period, not the individual billings of each attorney or lobbyist.

The 60-day filing window for initial registrations (RA-1) and the 30-day window for supplemental statements create structural delays in the public record. An agent who enters into a representation agreement in January may not be in the public database until March. Activities conducted during an unreported period remain invisible until the next supplemental statement is filed, which can be up to eight months after the activities occurred.

High-profile cases

FARA prosecutions are rare—between the 1966 amendments and 2015, only two criminal prosecutions were brought under the Act—but the cases that have arisen in the 2017–2022 period have involved some of the most prominent figures in Washington lobbying and politics.

Paul Manafort: The former Trump campaign chairman was convicted in August 2018 of tax and bank fraud charges in the Eastern District of Virginia and pleaded guilty in September 2018 to FARA conspiracy charges in the District of Columbia. Manafort and his business partner Rick Gates had conducted an extensive political influence campaign on behalf of the Ukrainian government of Viktor Yanukovych and a Ukrainian political party, the Party of Regions, from 2006 through 2014. The operation included hiring a network of Washington lobbyists, law firms, and public relations firms as subcontractors, routing payments through offshore accounts to conceal the Ukrainian source, and orchestrating a campaign to lobby US officials and shape media coverage without registering as a foreign agent. Manafort's firm, DMP International, filed retroactive FARA registrations in 2017 disclosing more than $17 million in political consulting fees from Ukrainian sources.

Tony Podesta and the Podesta Group: Tony Podesta and the Podesta Group, a major Democratic-aligned lobbying firm, also came under scrutiny for work related to the Ukrainian influence campaign. The Podesta Group had been retained by Manafort as a subcontractor to lobby members of Congress on behalf of the European Centre for a Modern Ukraine (ECMU), which was a front for Ukrainian government interests. In April 2017, Tony Podesta filed a retroactive FARA registration for the ECMU work. The Podesta Group dissolved in November 2017 as the Mueller investigation intensified, and Tony Podesta was referred for potential criminal prosecution, though charges were ultimately not brought.

Mercury LLC: Mercury Public Affairs, another lobbying firm retained in the Ukrainian network, also filed a retroactive FARA registration in 2017 covering its work for the ECMU. Mercury had lobbied members of Congress opposing sanctions against Ukraine and promoting a favorable image of the Yanukovych government without initially registering as a foreign agent.

Michael Flynn and Flynn Intel Group: Former National Security Advisor Michael Flynn filed a retroactive FARA registration in March 2017 for work conducted by his company, Flynn Intel Group, on behalf of Turkish interests. The representation involved a $530,000 contract with Inovo BV, a Dutch company with Turkish principals, during the period August–November 2016—concurrent with Flynn's service as a senior advisor to the Trump campaign. The work included research and lobbying activities related to Turkey's extradition request for the cleric Fethullah Gülen, who was residing in Pennsylvania. The retroactive filing was a significant political controversy because Flynn had been advising a presidential campaign while conducting unregistered foreign agent activities.

Tom Barrack and Colony Capital: Tom Barrack, a prominent Trump fundraiser and inaugural committee chairman, was indicted in July 2021 on charges of acting as an unregistered foreign agent of the United Arab Emirates, obstruction of justice, and making false statements. Federal prosecutors alleged that Barrack and his associates secretly lobbied within the Trump administration on behalf of UAE interests, influencing US foreign policy positions including on the Qatar blockade and arms sales. Barrack was acquitted by a jury in November 2022 on all counts.

Skadden, Arps and Greg Craig: The law firm Skadden, Arps, Slate, Meagher & Flom agreed in January 2019 to pay $4.6 million and register under FARA in connection with work it performed for the Ukrainian government in 2012. The work involved preparing a report on the prosecution of former Ukrainian Prime Minister Yulia Tymoshenko. Partner Greg Craig, who had served as White House counsel under President Obama, was separately indicted for making false statements to the FARA Unit. Craig was acquitted by a jury in September 2019. The case was the first time a major US law firm had been required to register under FARA for legal work.

Enforcement history and the 2017–2019 surge

FARA enforcement was historically rare and weak. Between the 1966 amendments—which replaced mandatory criminal prosecution with a more flexible civil compliance approach—and 2015, the DOJ brought only two criminal prosecutions under FARA. The statute was widely regarded as a paper compliance requirement that Washington's lobbying industry could largely ignore. The DOJ Inspector General reported in 2016 that the FARA Unit, staffed by only five attorneys and three paralegals, rarely followed up on potential non-compliance and had no systematic process for identifying unregistered agents.

The appointment of Special Counsel Robert Mueller in May 2017 produced the most significant period of FARA enforcement in the statute's history. Mueller's team used FARA as both a substantive charge and a pressure instrument. The FARA Unit, working with NSD and the Special Counsel's office, issued a series of letters to Washington lobbying and law firms demanding information about potential unregistered foreign agent relationships. These NSD inquiry letters—not public but widely reported in 2017–2018—triggered a wave of retroactive FARA filings as firms sought to come into compliance before receiving more formal enforcement attention.

The statistical result was dramatic. The DOJ's FARA annual reports showed a significant increase in new registrations after 2016. Active registrations, which had been in the range of 400–500 for most of the 2010s, increased substantially in 2017 and 2018 as retroactive filings accumulated. Seven criminal indictments were brought under FARA during the 2017–2022 period, compared with only two in the prior half-century. NSD also reached civil settlements with several firms, including the $4.6 million Skadden agreement, without criminal charges.

After Mueller's investigation concluded in 2019, FARA enforcement returned to a lower tempo. The DOJ NSD continued to send advisory opinions and inquiry letters, and the eFiling system launched in 2021 improved transparency, but the dramatic spike in prosecutions did not persist. Research by OpenSecrets and the Project On Government Oversight (POGO) found that the LDA exemption continued to enable significant foreign commercial lobbying without FARA disclosure, particularly for Middle Eastern governments whose US representatives registered under the LDA rather than FARA.

Top foreign principals by spending

FARA supplemental statements provide the most detailed public record of foreign government lobbying and public relations spending in the United States. The following table summarizes the largest disclosed foreign principal spending programs based on aggregated supplemental statement disbursements. Figures reflect cumulative disclosures through 2024 and are subject to the limitations described in the final section, including retroactive filings, the LDA exemption gap, and the delay between activity and disclosure.

Table 1. Top foreign principals by disclosed FARA supplemental statement spending. Figures are cumulative disclosed disbursements and exclude activities conducted under the LDA exemption. Saudi Arabia figures reflect post-2016 surge following Khashoggi-era scrutiny and Vision 2030 lobbying campaign.

Saudi Arabia represents the single largest FARA-disclosed foreign lobbying operation in the United States. Following the 2018 killing of journalist Jamal Khashoggi, congressional and media scrutiny of Saudi lobbying intensified, and the number of firms registering to represent Saudi government entities—the Ministry of Commerce and Investment, the Saudi Arabian General Investment Authority, the Public Investment Fund, and the Royal Embassy—increased substantially. Squire Patton Boggs, the largest registered agent for Saudi principals, has received tens of millions of dollars in disclosed fees for Saudi lobbying since 2016. Akin Gump Strauss Hauer & Feld and BGR Group are other major firms with significant Saudi FARA registrations.

Registration counts by country

The distribution of FARA registrations by country of the foreign principal reflects both the geographic range of foreign influence activity and the selective enforcement patterns that have shaped which foreign relationships appear in the database.

Table 2. Approximate active FARA registration counts by country of foreign principal. Counts are illustrative based on 2024 database snapshots; exact figures fluctuate as registrations are filed, amended, and terminated. Countries with significant lobbying conducted under the LDA exemption are underrepresented.

The FARA eFiling system and API access

The DOJ FARA Unit launched the eFiling system at efile.fara.gov in 2021, replacing a paper-based process that had required researchers to visit the DOJ FARA Registration Unit in person or request documents by mail. The eFiling system made the FARA database programmatically accessible for the first time through a structured JSON API and enabled bulk CSV downloads of registration, foreign principal, and supplemental statement data.

The FARA API is available at https://efile.fara.gov/api/v1/without authentication or API key requirements. The primary endpoints are /Registrants/json (active and terminated registrants),/ForeignPrincipals/json (foreign principal records with associated registrant IDs), and /SupplementalStatements/json(six-month disclosure statements with disbursement and compensation figures). Each endpoint accepts query parameters includingStatus (Active or Terminated), Country(for foreign principal searches), RegistrantID(to retrieve all filings for a specific registrant), Limit, and Offset for pagination.

Bulk CSV downloads are available at https://efile.fara.gov/bulk/ and are the preferred format for full-database analysis. The bulk CSV package includes separate files for registrants, foreign principals, supplemental statements, exhibit URLs, and DOJ advisory opinions. The bulk files are updated nightly and include both active and terminated records. OpenSecrets, POGO, and the Sunlight Foundation (now archived) have built secondary databases using FARA bulk data, providing more user-friendly search interfaces and cross-referenced spending totals than the raw DOJ database.

The FARA Electronic Reading Room at justice.gov/nsd-fara remains the authoritative source for exhibit documents, advisory opinions, and formal letters to registrants. Advisory opinions issued by the FARA Unit in response to requests for guidance about whether a particular relationship or activity requires FARA registration are publicly available through the Reading Room, though the identity of the requesting party is typically redacted. These opinions form an important interpretive record of how the FARA Unit construes the statute's exemptions.

Python workflow: querying the FARA API

The following Python script demonstrates how to query the FARA API to retrieve active registrants, search for foreign principal records by country of the principal, and aggregate disclosed disbursements across supplemental statements. The script identifies the top foreign principals by total disclosed spending across a set of high-interest countries. Requirements: requests (standard HTTP client); no API key is needed for the FARA API.

import requests
import csv
import io
from collections import defaultdict

# FARA eFiling API -- base URL
BASE = "https://efile.fara.gov/api/v1"

# ── 1. Fetch active registrants ────────────────────────────────────────────────
def get_active_registrants(page: int = 1, page_size: int = 100) -> dict:
    """Return a page of active FARA registrants."""
    r = requests.get(
        f"{BASE}/Registrants/json",
        params={"Status": "Active", "Offset": (page - 1) * page_size, "Limit": page_size},
        timeout=30,
    )
    r.raise_for_status()
    return r.json()


def collect_all_registrants() -> list[dict]:
    """Paginate through all active registrants."""
    registrants = []
    page = 1
    while True:
        data = get_active_registrants(page=page)
        rows = data.get("REGISTRANTS", {}).get("ROW", [])
        if not rows:
            break
        if isinstance(rows, dict):
            rows = [rows]  # single-row edge case
        registrants.extend(rows)
        print(f"  Page {page}: {len(rows)} registrants (total: {len(registrants)})")
        if len(registrants) >= int(data.get("REGISTRANTS", {}).get("@count", 0)):
            break
        page += 1
    return registrants


# ── 2. Search registrations by foreign principal country ───────────────────────
def search_by_country(country: str) -> list[dict]:
    """Return registrations where the foreign principal is from a given country."""
    r = requests.get(
        f"{BASE}/ForeignPrincipals/json",
        params={"Country": country, "Limit": 200},
        timeout=30,
    )
    r.raise_for_status()
    data = r.json()
    rows = data.get("FOREIGNPRINCIPALS", {}).get("ROW", [])
    if isinstance(rows, dict):
        rows = [rows]
    return rows


# ── 3. Pull supplemental statement data (disbursements) ───────────────────────
def get_supplemental_statements(registrant_id: str) -> list[dict]:
    """Fetch all supplemental statements filed by a registrant."""
    r = requests.get(
        f"{BASE}/SupplementalStatements/json",
        params={"RegistrantID": registrant_id, "Limit": 50},
        timeout=30,
    )
    r.raise_for_status()
    data = r.json()
    rows = data.get("SUPPLEMENTALSTATEMENTS", {}).get("ROW", [])
    if isinstance(rows, dict):
        rows = [rows]
    return rows


def parse_amount(val: str | None) -> float:
    """Convert a FARA dollar string to float, ignoring commas and dollar signs."""
    if not val:
        return 0.0
    cleaned = val.replace(",", "").replace("$", "").strip()
    try:
        return float(cleaned)
    except ValueError:
        return 0.0


# ── 4. Aggregate total disclosed disbursements per foreign principal ───────────
def top_principals_by_disbursements(
    countries: list[str], top_n: int = 10
) -> list[tuple[str, str, float]]:
    """
    For each country, collect all foreign principals and sum disbursements
    across their supplemental statements.  Returns a ranked list of
    (principal_name, country, total_disbursements).
    """
    totals: dict[tuple[str, str], float] = defaultdict(float)

    for country in countries:
        fps = search_by_country(country)
        print(f"  {country}: {len(fps)} principal records")
        for fp in fps:
            reg_id = fp.get("REGISTRANT_ID", "")
            principal = fp.get("FOREIGN_PRINCIPAL", "Unknown principal")
            if not reg_id:
                continue
            stmts = get_supplemental_statements(reg_id)
            for stmt in stmts:
                disbursed = parse_amount(stmt.get("DISBURSEMENTS"))
                totals[(principal, country)] += disbursed

    ranked = sorted(totals.items(), key=lambda x: -x[1])
    return [(name, country, amt) for (name, country), amt in ranked[:top_n]]


# ── 5. Run analysis ────────────────────────────────────────────────────────────
if __name__ == "__main__":
    print("=== Active FARA Registrants ===")
    regs = collect_all_registrants()
    print(f"Total active registrants: {len(regs)}")

    # Registration count breakdown by state
    state_counts: dict[str, int] = defaultdict(int)
    for r in regs:
        state = r.get("STATE", "Unknown")
        state_counts[state] += 1
    print("\nTop 10 states by active registrant count:")
    for state, cnt in sorted(state_counts.items(), key=lambda x: -x[1])[:10]:
        print(f"  {state:<25} {cnt:>4}")

    print("\n=== Top Foreign Principals by Disclosed Disbursements ===")
    target_countries = [
        "SAUDI ARABIA", "CHINA", "UNITED ARAB EMIRATES",
        "ISRAEL", "TURKEY", "JAPAN", "RUSSIA", "SOUTH KOREA",
    ]
    results = top_principals_by_disbursements(target_countries, top_n=10)
    print(f"\n{'Rank':<5} {'Principal':<40} {'Country':<25} {'Disbursements':>15}")
    print("-" * 90)
    for i, (name, country, amt) in enumerate(results, 1):
        print(f"{i:<5} {name[:39]:<40} {country:<25} ${amt:>14,.0f}")

The output of the script illustrates the geographic concentration of FARA-disclosed foreign influence spending. Saudi Arabia, Japan, and South Korea consistently account for the largest aggregate disbursements in the database, reflecting both their active Washington lobbying programs and their relative willingness to operate through FARA registration rather than the LDA exemption. Countries that route most foreign commercial lobbying through LDA-registered firms— including some EU member states and commercial partners—will appear substantially underrepresented in FARA disbursement totals.

For production analysis, the bulk CSV download at efile.fara.gov/bulk/ is more efficient than paginating through the API, particularly for full-database queries. The bulk files include a FOREIGN-PRINCIPALS.csv file with all principal records and a SUPPLEMENTAL-STATEMENTS.csv with all filed supplemental statements, enabling a single join on Registrant ID to produce a complete principal-to-disbursement table without API pagination.

Limitations

The FARA database has several structural limitations that significantly affect what it can and cannot reveal about foreign influence in the United States. Researchers and journalists working with FARA data must understand these gaps to avoid overstating or understating the scope of disclosed foreign lobbying.

The LDA exemption loophole: The single largest gap in FARA coverage is the Lobbying Disclosure Act exemption under 22 U.S.C. § 613(h). Agents representing foreign commercial entities (as opposed to foreign governments or political parties) may satisfy their disclosure obligation by registering under the LDA rather than FARA. Because LDA filings require only quarterly aggregate spending data and do not require itemized political contact disclosures, a large share of foreign commercial lobbying operates in the database with minimal transparency. OpenSecrets research has estimated that the volume of foreign-origin lobbying conducted under the LDA substantially exceeds what is visible in the FARA database. Congress has considered but not enacted legislation to narrow or eliminate the LDA exemption since at least the 2019 Mueller report period.

Enforcement gaps and self-reporting: FARA is a self-reporting system. No government agency audits the completeness of FARA filings against the actual universe of agents acting on behalf of foreign principals. The FARA Unit has a small staff and relies primarily on media reporting, congressional referrals, and DOJ investigations for information about potential unregistered agents. The spike in retroactive filings during the 2017–2019 Mueller period demonstrated that substantial unreported activity was occurring; it is not known how much continues to occur in the absence of equivalent investigative pressure.

The 60-day filing window: The FARA statute requires initial registration within ten days of the agent-principal relationship beginning, but in practice the FARA Unit has accepted registrations filed within 60 days without pursuing enforcement action for the delay. Supplemental statements are due within 30 days of the end of each 6-month period, meaning activities conducted in January may not appear in the public database until August of the same year. This lag is structurally unavoidable in a semi-annual disclosure system and means that real-time foreign lobbying activity is not visible in the FARA database.

Disbursement vs. activity completeness: The financial figures in FARA supplemental statements are self-reported and have not been independently verified against financial records or tax filings. The DOJ Inspector General found in its 2016 report that the FARA Unit did not routinely audit the accuracy of financial disclosures in supplemental statements. Several major retroactive FARA filings following the Mueller investigation period disclosed significantly different financial figures from what had been represented in prior lobbying disclosures, suggesting that the historical database contains material inaccuracies that were not corrected until legal pressure was applied.

State and local influence operations: FARA covers activities intended to influence the US government and domestic political opinion, but its enforcement focus has been almost exclusively on federal lobbying and federal policy influence. Foreign influence operations targeting state legislatures, state executive agencies, municipal governments, state pension funds, and public universities may not be captured by FARA even where they clearly serve foreign government interests. The absence of a state-level equivalent to FARA in most US states creates a significant gap in the public record of sub-federal foreign influence operations.