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The technical amendments to the LDA reflected a determination that the FARA standards
are appropriate for lobbying on behalf of foreign governments and political parties, but
that LDA disclosure standards should apply to other foreign lobbying (also refer to the
section in this document entitled "What is New?"). An agent of a foreign commercial
entity is exempt under FARA if the agent has engaged in lobbying activities and registers
under the LDA. An agent of a foreign commercial entity not required to register under the
LDA (such as those not meeting the de minimis registration thresholds) may voluntarily
register under the LDA. The amendments reaffirm the bright line distinction between
governmental and non-governmental representations, and are not meant to shroud foreign
government enterprises. Questions relating to the Foreign Agents Registration Act must
be directed to the Department of Justice Foreign Agent Registration Unit at (202) 5141231.