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Four Laws in Letter and Spirit*

By Sarah Slye

Zichy, Mihaly (1827-1906)

*A layperson’s non-exhaustive analysis of four pieces of foreign agent legislation in Georgia, Russia and the USA



"Incontrovertible evidence has been submitted to prove that there are many persons in the United States representing foreign governments or foreign political groups, who are supplied by such foreign agencies with funds and other materials to foster un-American activities, and to influence the external and internal policies of this country, thereby violating both the letter and the spirit of international law, as well as the democratic basis of our own American institutions of government.” –  H. Rept. No.1381, 75th Cong. 1st Sess., July 28, 1937


Whether the recently proposed Georgian foreign agent laws copied a similar Russian or American foreign agent law is a moot point since Russian officials themselves allege their law was inspired by the U.S. Foreign Agent Registration Act (FARA).[1] Nevertheless, this article presents an analysis of the texts of the Russian foreign agent law of July 2022, which built upon previous legislation, including the Russian foreign agent law of July 2012; the U.S. FARA and the two Georgian foreign agent bills, as well as an overview of the unique contexts of their application, to determine the degree to which the Georgian bills were in fact imitations of Russian or American laws. Although the second Georgian bill certainly copies the American law in letter and the first bill only somewhat resembles the Russian legislation in letter—both Georgian bills reflect the Russian law in spirit.


List of the contents

In Letter

I. Titles

II. Foreign agents & foreign influence

III. Mass media & public relations

IV. Foreign source, principal or power

V. Political Activity

VI. Registration

VII. A public register

VIII. Penalties and methods of compulsion

IX. Monitoring

X. Periodic reporting

XI. Labelling

XIII. Semantics

In Spirit

Securing the Upcoming Elections?

Covering for corruption?

Russia’s anti-reality universe


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Four Laws in Letter and Spirit - Sarah Slye
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[1] “Guram Macharashvili: We are thinking of translating the American law completely, then they will no longer say that it is Russian law - if they still say it, then it turns out that there is Russian legislation in America, so what they have against us?” IPN Interpressnews, 17 February 2023, For the sake of simplicity, I am using the singular form here to refer to a set of related laws which build upon each other not one single law. However, it seems the first “foreign agent” law of 2012 is the one that received the major comparisons to FARA. 

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