Josh Rosenstein shares his thoughts with Open Secrets on LDA exemptions.

The Justice Department’s treatment of the “LDA exemption” has been “less than consistent,” according to Joshua Rosenstein, an attorney with Sandler Reiff Lamb Rosenstein & Birkenstock. “It is clear from most of the Advisory Opinions that simply having a foreign corporation with upstream government ownership isn’t always enough to treat the foreign principal as a governmental entity,” he said.

“The principal beneficiary analysis is perhaps even murkier,” Rosenstein added, “but given DOJ’s positions on lobbying related to foreign banks, trade sanctions, and core national industries, it’s not clear to me that the LDA exemption would be appropriate in this case.”

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