Josh Rosenstein recently followed-up with the Hill to discuss FARA and the resignation of Paul Manafort further. In the article, Rosenstein explained that part of the reason for FARA’s low prosecution rate is due to the fact that the law primarily hinges on voluntary compliance.

If someone does not file paperwork correctly – or at all – the Justice Department will send a letter to the lobbyist or firm asking them for corrections, to register with the department as a foreign agent, or explain why registration is not necessary.

Simply updating records, even months or years after non properly disclosing work, can be enough to satisfy the DOJ.

“It’s clear that they’re hamstrung in their ability to ensure full compliance. They can’t subpoena, they can’t prosecute on their own,” Rosenstein said. “They’ve got the carrot but not the stick.”

Read the rest of the article here.