22 USC 614(b):
The Label Requirement
Section 614(b) of FARA requires that every piece of informational material disseminated by a registered foreign agent carry a clear and conspicuous disclosure identifying the distributor as a foreign agent. This is the statute at the center of the Salem Media / FARA #7649 question.
The Statute: 22 USC 614(b)
“Every person within the United States who is an agent of a foreign principal and required to register under the provisions of this subchapter and who transmits or causes to be transmitted in the United States any informational materials for or in the interests of such foreign principal (i) in the form of prints, or in any other form which is reasonably adapted to being, or which he believes will be, disseminated or circulated among two or more persons; or (ii) by means of any radio or television transmission, shall, contemporaneously with the transmittal of such informational materials, furnish to the Attorney General two copies thereof and cause to be plainly marked on each copy a statement that such informational material is distributed by the agent on behalf of the foreign principal.”
Source: 22 USC 614 (Cornell LII)
What 614(b) Requires in Plain Language
Who it applies to
Any person who is (1) a registered foreign agent under FARA, AND (2) transmits informational materials in the US for the benefit of their foreign principal.
What must be labeled
Every piece of informational material — including printed materials, digital content, radio broadcasts, and television transmissions — must carry a conspicuous label.
What the label must say
The label must plainly state that the material is distributed by the agent on behalf of the named foreign principal. The foreign principal must be identified by name.
Filing requirement
Two copies of every labeled informational material must be filed with the Attorney General contemporaneously with dissemination. This creates a public record.
Application to FARA #7649 and Salem Media
FARA #7649 (Clock Tower X LLC, Brad Parscale) explicitly lists “integration with Salem Media Network properties” as a contracted activity in the Exhibit AB filed with the DOJ. The contract is with Havas Media Germany GmbH on behalf of the Government of Israel.
If any content produced or distributed by Clock Tower X LLC was transmitted through Salem Media's 101 radio stations or digital properties as part of that contract, 22 USC 614(b) would require that such content carry a conspicuous label identifying it as distributed by a foreign agent on behalf of the Government of Israel.
AFNPT has not identified any instance of a 614(b)-compliant label on Salem Media content. We have also not confirmed that any contracted content has been distributed. What is documented: (1) the contract exists per FARA #7649; (2) Salem Media integration is explicitly listed as a contracted activity; (3) Brad Parscale is simultaneously Salem Media's CSO and the FARA #7649 registrant.
AFNPT Educational Analysis: The above constitutes documented facts from primary FARA filings. Whether a 614(b) violation has occurred is a legal determination for the DOJ to make. AFNPT does not allege any criminal violation.
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