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In a June 22, 2015 article, the Organized Crime and Corruption Reporting Project (OCCRP) featured an article on clandestine lobbying by foreign countries through academia and nonprofits. Specifically, the article focuses on a series of nonprofits setup by the country of Azerbaijan to lobby on behalf of their government. The OCCRP article cites an August 18, 2010 article written by Venable partner Ed Wilson and counsel Andrew Bigart on foreign-supported nonprofits and the Foreign Agents Registration Act.

“Many nonprofits are surprised to learn that there is no…exemption for nonprofit, tax-exempt entities,” Wilson and Bigart wrote. “Penalties for failing to comply with… (lobbyist registration requirements) can include a fine of US$ 10,000 or imprisonment for up to five years.” They acknowledged that it is difficult to know what activities require nonprofits to register as foreign agents and that the Justice Department offers little guidance. Commenting specifically on the Azerbaijan Chamber of Commerce mentioned in the OCCRP article, Wilson “concluded that the organization is very probably not obliged to register under current rules.”