Members in Caplin & Drysdale's Political Law practice group, Matthew Sanderson and Bryson Morgan, joined other legal professionals in filing a comment letter to the Department of Justice's FARA Registration Unit related to disclosure forms filed under the Foreign Agents Registration Act ("FARA").
The comment letter proposed that the Department of Justice implement the following changes to the FARA disclosure forms:
- Redact personal residential information from FARA forms to protect the privacy of filers.
- Require updates on Supplemental Statements (Form NSD-2) only for partners who previously filed Short Form Registrations.
- Clarify the scope of certain questions on the Supplemental Statement and on Exhibit B to Registration Statement.
- Provide guidance on the proper use of the Amendment to Registration Statement.
- Clarify the scope of required disclosures of political contributions on Supplemental Statements.
In total, 14 FARA practitioners signed the comment letter in an effort aimed at improving FARA's disclosure regime.