On September 15th, Partner Josh Rosenstein was quoted in ProPublica regarding whether U.S. Arctic Research Commission chair Thomas Dans’ business ties and activities related to Dutch Company Damen Shipyards implicated the Foreign Agents Registrations Act (FARA). Since his appointment by President Trump last December, Dans has faced scrutiny for potential conflicts of interest stemming from his advocacy for closer U.S.-Russia relations and promotion of foreign commercial interests.
“If Dans was seeking to advance Damen’s interests, he may have been required under the law to register either as a lobbyist or a foreign agent, said Josh Rosenstein, an attorney who is an expert on the Foreign Agents Registration Act. Documents show he’d done neither.
‘It certainly would raise questions…in my mind about what sort of interactions he, on behalf of Damen, had with the U.S. government,’ Rosenstein said. ‘And with whom.'”
On September 24, Partner Joshua Rosenstein will speak on the panel “Contracting with Foreign Principals” at the 2026 FARA Conference alongside Daniel Pickard of Buchanan Ingersoll & Rooney P.C. and Josh Galper of Trident GMG. The panel will focus on the practical realities and considerations facing firms agreeing to do work for foreign principals: due diligence, “know your customer” requirements, contingent fee restrictions, reputational considerations, and more.
The FARA Conference brings together practitioners, government officials, scholars, and journalists shaping the landscape for a full day of substantive discussion in Washington, D.C. Sessions will examine recent enforcement actions, evolving compliance expectations for businesses and nonprofits, FARA’s intersection with the Lobbying Disclosure Act, and where the law is headed. Designed for attorneys, compliance professionals, registrants, and advisors, the conference emphasizes practical insights and meaningful dialogue.
Hosted by the University of Pennsylvania’s Center for Ethics & the Rule of Law and Lawfare, the conference features leading law firms and academic institutions. Sandler Reiff is proud to co-sponser this year’s program.
For more information and to register, visit The FARA Conference’s website here.
Sandler Reiff Lamb Rosenstein & Birkenstock P.C. (Sandler Reiff), a pre-eminent political law boutique in Washington, D.C., is pleased to announce the promotion of Christina Bustos to the position of Partner of the Firm.
Sandler Reiff advises clients involved in the business of politics, including candidates and officeholders, political committees, party committees, nonprofit organizations, advocacy groups, communications, consulting, and government relations firms, as well as major contributors to political and nonprofit groups.
Christina advises clients on political and issue advocacy efforts nationwide. Her practice focuses on voter registration and elections, campaign finance, lobbying and related advocacy efforts, and nonprofit tax law. She combines expertise in a wide range of political law with practical, strategic judgment, making her an invaluable resource for clients navigating complex regulatory requirements.
“Christina’s promotion reflects the exceptional lawyer and trusted advisor she has become. She combines significant expertise across the political law landscape—from voter registration and campaign finance to lobbying and advocacy regulation—with outstanding judgment and an unwavering commitment to client service. Her deep relationships with our clients are a testament to her skill and acumen, and to the fact that she is an indispensable part of the Sandler Reiff team. We are delighted to welcome her to the partnership,” said Joe Sandler, co-founder of the Firm.
Prior to joining Sandler Reiff, Christina practiced trial and appellate level civil litigation at a law firm in Richmond, Virginia. Christina graduated from the Pennsylvania State University Dickinson School of Law.
Joshua Rosenstein shares his opinions of the Manafort indictment and its relation to the Foreign Agents Registration Act (FARA) in Vice News. On the topic, he shares:
“This is sort of like a FARA lawyer’s dream and nightmare,” said Joshua Ian Rosenstein, partner at Sandler Reiff, a Washington, D.C.-based political law firm specializing in the regulation of advocacy. “Even though criminal prosecutions are extraordinary, I have never seen an indictment that relies so heavily on FARA.”
You can read more of Josh Rosenstein’s thoughts on FARA, Manafort’s Indictment, and Sen. Grassley’s bill to reform FARA at the following links:
In a Talking Points article, “The Vise is Tightening on Paul Manafort, The Mueller Probe’s Linchpin,” Rosenstein discusses the possibility of a prosecution of Paul Manafort under the Foreign Agents Registration Act.
Josh Rosenstein, an attorney at Sandler Reiff Lamb Rosenstein & Birkenstock who specializes in FARA, said that although prosecutions under the act are quite rare, it is a “distinct possibility” that Mueller’s team could pursue one against Manafort.
“When FARA becomes a high profile issue as certainly it has been here in and of itself, the risk of prosecution is certainly much higher,” Rosenstein said, noting that FARA charges would likely be brought as a secondary charge to any potential financial crimes.
Sandler Reiff successfully challenged the Federal Aviation Administration’s (“FAA”) denial of a rulemaking petition on behalf of FlyersRights.org. FlyersRights.org petitioned the FAA to promulgate rules governing plane seat size and pitch limitations to ensure that passengers can safely and quickly evacuate a plane in an emergency. “This is the Case of the Incredible Shrinking Airline Seat,” Judge Patricia Ann Millett wrote on behalf of the United States Court of Appeals for the District of Columbia three-judge panel. The Court unanimously agreed that the FAA failed to provide a plausible evidentiary basis for its denial of FlyersRights.org’s rulemaking petition and remanded the case to the FAA.
FlyersRights,org is represented by Joseph E. Sandler and Dara Lindenbaum.
Additional information on the case is available here and here.
The case is Flyers Rights Education Fund, Inc. et al v. Federal Aviation Administration, et al. Opinion available here.
In The Hill’s article “Lobbyists Adjust to Trump’s New Rules,” Joshua Rosenstein discusses Trump’s new proposals and how they will affect lobbyists in Washington.
“While it’s weaker, it’s not just lip service. It does make actual reforms,” said Joshua Ian Rosenstein, a partner at Sandler Reiff Lamb Rosenstein & Birkenstock, specializing in political law and lobbying compliance. “Of course, it’s different than what Trump promised, which is that you won’t be a lobbyist [for five years] — period.”
In The Hill’s article “Primer: What you need to know about Paul Manafort”, Josh Rosenstein explores how the DOJ may want to consider a prosecution of Paul Manafort under FARA.
“Given the larger investigation into Russian meddling, this may actually be one of those rare instances where DOJ might want to consider a prosecution under FARA if they have the evidence,” said Joshua Ian Rosenstein, a partner at Sandler Reiff Lamb Rosenstein & Birkenstock focused on lobbying compliance.
In The Hill’s article “Lobbyists Adjust to Trump’s New Rules,” Joshua Rosenstein discusses Trump’s new proposals and how they will affect lobbyists in Washington.
“While it’s weaker, it’s not just lip service. It does make actual reforms,” said Joshua Ian Rosenstein, a partner at Sandler Reiff Lamb Rosenstein & Birkenstock, specializing in political law and lobbying compliance. “Of course, it’s different than what Trump promised, which is that you won’t be a lobbyist [for five years] — period.”
The Center for Public Integrity sat down with Mr. Sandler for a lengthy interview about campaign-finance, election-law matters, and his work with the DNC. Read the full interview here.
