FARA Penalties:
22 USC 618

Failure to register as a foreign agent, or filing false or incomplete registrations, is a federal crime under 22 USC 618. The statute provides for both criminal prosecution and civil enforcement by the DOJ.

22 USC 618: Criminal Penalties

5 years
Maximum prison term
$10,000
Maximum fine per violation
Felony
Classification

Applies to: willful failure to register, filing false statements in a FARA registration, failure to file supplemental statements, failure to furnish informational materials to the Attorney General, and failure to include required 614(b) labels on informational materials.

Willful vs. Negligent Non-Compliance

Willful Violation

Criminal prosecution under 22 USC 618. Requires DOJ to prove the defendant knowingly and intentionally failed to register or filed false information. Maximum: 5 years imprisonment plus $10,000 fine per count. The DOJ can bring multiple counts for multiple violations.

Non-Willful / Civil

DOJ may seek civil injunctive relief requiring registration and disclosure without criminal charges. The DOJ has increasingly used civil enforcement and informal guidance letters before moving to prosecution. Many cases are resolved through retroactive registration.

DOJ Enforcement History (Selected Cases)

2019
Paul Manafort / Rick Gates

Pleaded guilty to FARA conspiracy charges (Ukraine/Podesta Group). Manafort: 7.5 years (commuted). FARA charges central to prosecution.

2019
Michael Flynn

Flynn Intel Group retroactively registered under FARA for Turkey-related work (registered after-the-fact). Pleaded guilty to lying to FBI about FARA-adjacent contacts.

2023
Robert Fisk (GRF Media)

DOJ civil action requiring FARA registration for Russia-funded media activities targeting US audiences. Resolved through registration.

2024
Hana Gold (DOJ indictment)

Charged with acting as unregistered agent of China. Alleged to have conducted influence operations at direction of Chinese government officials without registration.

Note: Cases listed are matters of public record. AFNPT does not allege any criminal violations in connection with FARA #7649, #7652, or #7653.

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