As a result of the U.S. Department of Justice ramping up enforcement of the Foreign Agents Registration Act, Skadden Arps Slate Meagher & Flom LLP’s became one of the agency’s first milestone targets. The law firm’s $4.6 million disgorgement deal with the DOJ marks a new era of enforcement for the political and legal sectors. The firm failed to register its lobbying and public relations work for the Ukrainian government in connection with former Trump campaign chairman Paul Manafort, and then misled DOJ investigators about it, according to the agency. As part of the deal, Skadden will also have to retroactively register as a foreign agent.

“Law firms don’t want to be the cautionary tale, and Skadden is the cautionary tale here,” said Joshua Rosenstein of Sandler Reiff Lamb Rosenstein & Birkenstock PC, another D.C. attorney with FARA expertise. “I think ever since the initial Manafort and [Manafort associate Rick Gates] indictments, most of us who practice this area of law were waiting for the next shoe to drop and wondering where it was going to be.

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