In recent months, the Department of Justice (DOJ), which administers FARA, has taken an increasingly broad view of FARA's scope, making many organizations wonder whether their work may trigger FARA registration.
Here is more from Foreign Lobby Report:
Foreign Lobby also notes that lobbying firm Waxman Strategies registered as a foreign agent for Norwegian-funded projects with the Center for International Policy (CIP), a think tank based in Washington, DC.
Nearly every major US think tank receives money from foreign governments as well as foreign businesses.
In its "FARA Guide for the Perplexed," the law firm of Covington & Burling LPP notes that FARA is written so broadly that it could potentially require registration even for some routine business activities at think tanks.
A number of foreign governments hire US-based lobbying firm to do outreach to think tanks. One example is DiNino Associates, LLC, which provides government relations assistance and outreach to think tanks on behalf of the Indian Embassy in the US.
Another example is Gotham Government Relations, which assists Libya's Government of National Accord (GNA) which outreach to think tanks.
Here is a previous Think Tank Watch piece about FARA entitled "When Think Tanking Becomes Illegal."