Navigating the Uncertainty Around the Commercial Exemption: How Practitioners are Applying the Exemption in the Wake of recent Advisory Options

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