On July 26th, partner Josh Rosenstein was quoted in an American Prospect article discussing unregistered agents working for the Azerbaijani government. The article highlights Rodney Dixon, an international legal expert hired by Azerbaijan to produce a report disputing allegations of genocide against Armenians in Nagorno-Karabakh. Dixon promoted his report through media networks like the BBC and CNN and also met with U.S. congressional staff. However, he did not disclose these activities on behalf of Azerbaijan under the Foreign Agents Registration Act (FARA).

“Josh Rosenstein, a partner at Sandler Reiff Lamb Rosenstein & Birkenstock, which advises clients on FARA compliance, explained in an interview that the Department of Justice might be justified in sending a letter of inquiry to determine whether or not there is a foreign agent registration requirement for Dixon. ‘Coming to the U.S. to present a report’s findings commissioned by and promoting the interests of a foreign government, and representing the interests of that government before the U.S. government, are both regulated. So while there may be some nuance or fact that I’m not aware of, this does on its face seem to trigger the Foreign Agents Registration Act,’ said Rosenstein.”

Read more here.