Washington Firms Working for Chinese Interests

The Foreign Agents Registration Act, enacted in 1938 and substantially amended since, requires any person acting as an agent of a foreign principal in a political or quasi-political capacity to register with the Attorney General and to disclose the nature of their relationship, the activities they undertake, and the compensation they receive. Filings are submitted semi-annually and are available through the DOJ's FARA database.

FARA registration does not imply wrongdoing. Representing foreign governments and foreign companies in Washington is a legal and common professional activity. American law firms, public affairs consultancies, and strategic advisory firms routinely register under FARA when their work on behalf of foreign clients meets the statutory threshold. The filings are a transparency mechanism, not an accusation.

What FARA filings reveal, in aggregate, is the shape of a foreign government's or foreign commercial sector's engagement with American political and regulatory institutions. For China, the filings document which American firms have been engaged, on behalf of which Chinese principals, to do what kinds of work — lobbying Congress, engaging executive branch agencies, conducting public relations, or providing strategic counsel.

The picture that emerges from Chinese-related FARA filings is one of significant professional engagement, concentrated in a relatively small number of Washington firms with deep institutional relationships, and focused on a recurring set of policy concerns: trade and tariff policy, investment review and CFIUS, technology export controls, and the reputational management of Chinese state-owned enterprises and government-affiliated organizations operating in the United States.

American law firms represent the largest category of FARA registrants working on behalf of Chinese interests. Their work spans regulatory counsel, CFIUS transaction support, export control compliance, trade remedy defense, and congressional engagement on legislation affecting Chinese companies or the bilateral trade relationship.

Covington & Burling, one of Washington's most prominent law firms, has registered under FARA in connection with work for Chinese clients. The firm's China-related practice has included representation of Chinese technology companies navigating U.S. regulatory scrutiny and Chinese state-affiliated entities with Washington policy interests. Covington's FARA filings document contacts with executive branch officials and congressional staff on matters including trade policy and technology regulation.

Akin Gump Strauss Hauer & Feld, a firm with one of Washington's largest lobbying practices, has registered under FARA for work related to Chinese interests. The firm's registered activities have included engagement with Congress and executive branch agencies on trade and investment matters. Akin Gump's China-related work has at various times included representation of entities with connections to Chinese government ministries and state-owned enterprises.

Squire Patton Boggs, which has a significant presence in both Washington and China, has registered under FARA for Chinese-related work. The firm's registered activities have included lobbying on trade and tariff matters and engagement with U.S. government agencies on regulatory issues affecting Chinese commercial interests. Squire Patton Boggs has offices in Beijing and Shanghai, giving it a bilateral presence that distinguishes it from purely Washington-focused registrants.

Beyond legal representation, Chinese government entities and Chinese-affiliated organizations have engaged American public affairs firms to manage their reputational and communications presence in the United States. This work — which can include media relations, stakeholder engagement, and the production and placement of content — is also subject to FARA registration when it meets the statutory threshold.

The China-United States Exchange Foundation (CUSEF), a Hong Kong-based organization with documented ties to the United Front Work Department of the Chinese Communist Party, has engaged multiple American public affairs firms over the years. CUSEF's stated mission is to promote mutual understanding between China and the United States; its critics argue that it functions as a vehicle for Chinese government influence operations. American firms that have registered as CUSEF's agents have conducted activities including arranging meetings between CUSEF representatives and American officials, academics, and journalists.

The work of public affairs registrants for Chinese principals often involves activities that are difficult to distinguish from ordinary public diplomacy: hosting events, facilitating exchanges, producing publications, and engaging media. FARA registration makes these activities transparent; it does not resolve the question of whether they constitute legitimate cultural exchange or something more directed.

The most concentrated area of Chinese-related FARA activity in Washington involves trade and technology policy — the two domains where U.S. government decisions most directly affect Chinese commercial and strategic interests. Tariffs, export controls, investment restrictions, and technology transfer regulations are all subjects on which Chinese principals have engaged American advocates.

Chinese technology companies facing U.S. regulatory scrutiny — including companies on the Entity List, companies subject to investment restrictions, and companies whose products have been restricted from U.S. government procurement — have engaged Washington firms to represent their interests before Congress and executive branch agencies. The work has included direct lobbying, the commissioning of economic studies, and the organization of coalitions of American businesses with interests aligned with the Chinese client's position.

The Semiconductor Industry Association, the U.S. Chamber of Commerce, and other American business organizations have at various times advocated for positions on export controls and technology policy that align with the interests of their Chinese-affiliated members or trading partners. These organizations are not FARA registrants — they represent American members — but their advocacy illustrates the degree to which Chinese commercial interests are embedded in American business coalition politics.

Chinese government engagement with American political institutions is not limited to Washington. Chinese consulates, state-affiliated organizations, and Chinese-funded entities engage with state legislatures, governors' offices, and local governments on matters including trade missions, investment attraction, sister-city relationships, and Confucius Institute agreements with public universities.

State-level engagement is less systematically documented than federal FARA filings. Some states have enacted their own foreign agent registration requirements; most have not. The result is a significant gap in the public record of Chinese government engagement with American political institutions below the federal level.

The National Governors Association and individual governors' offices have been the subject of documented Chinese engagement efforts, including invitations to visit China, meetings with Chinese officials during U.S. visits, and participation in trade and investment forums organized by Chinese government-affiliated entities. These interactions are not inherently problematic — governors routinely engage with foreign governments on economic development matters — but they occur largely outside the transparency framework that FARA provides at the federal level.

FARA enforcement has historically been limited. The Department of Justice brought relatively few FARA prosecutions in the decades following the act's passage, and the registration requirement was widely understood to be loosely enforced. That changed somewhat after 2016, when concerns about foreign influence in American politics prompted renewed DOJ attention to FARA compliance. Several high-profile prosecutions — including cases arising from the Mueller investigation — raised the profile of FARA as an enforcement tool.

For Chinese-related FARA activity, the enforcement picture is mixed. Some individuals and entities that should have registered have not done so, and DOJ has in some cases pursued registration compliance through civil rather than criminal means. The DOJ's FARA Unit has issued letters to individuals and organizations requesting registration; in some cases those requests have been contested.

The broader question — whether FARA as currently structured is adequate to address the scale and sophistication of Chinese government engagement with American political institutions — is actively debated in Washington. Legislative proposals to strengthen FARA, expand its coverage, and increase enforcement resources have been introduced in multiple Congresses. None has yet been enacted into law.