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FEATURE

What Regulators Say
“Registration obligations extend to those who facilitate influence operations—whether you’re a consultant, lawyer, or private investigator.
If your work shapes policy, perception, or power on behalf of a foreign interest, the public has a right to know.”
— DOJ official, FARA Unit

In the UK, the Home Office made a similar statement at the Association of British Investigators’ Annual Conference, reinforcing
that FIRS is designed to make foreign influence visible, not to criminalise legitimate work.

FIRS vs. FARA: At a Glance

Aspect FIRS (UK) FARA (USA)

Legal Basis National Security Act 2023 Foreign Agents Registration Act, 1938

Administered By UK Home Office U.S. Department of Justice (DOJ)

Applies To Anyone acting for a foreign power (or specified power) Anyone acting for a foreign principal

Scope Political or any activity for specified powers Political, PR, lobbying, influence-related work

Deadlines 28 days (Political Tier), 10 days (Enhanced Tier) Registration before activity; periodic updates

Criminal Penalties Up to 2 years in prison or fine Up to 5 years in prison and $250,000 fine per offence

Transparency Goal UK public register U.S. DOJ public disclosure database

Why It Matters to Investigators While those initial briefings have now concluded, the Home
As international investigators, we frequently: Office continues to support professionals via:
• Act on behalf of foreign clients (law firms, state entities, offshore trusts) • Sector Toolkits
• Provide strategic litigation support (academia, business, PR, charities, defence, media)
• Conduct reputation or opposition research • Step-by-step registration guidance
• Advise on matters involving government, politics, or public interest • The FIRS Case Management Team

These scenarios may fall within FIRS or FARA scope, especially if the client is Investigators are encouraged to stay up to date by
a foreign government, political party, or an entity tied to one. Non-compliance engaging with their national associations, including
could expose firms to criminal liability, reputational harm, and future regulatory the ABI and WAD, and by monitoring ongoing FIRS
scrutiny. publications.For toolkits and guidance, visit:

Investigator Compliance Checklist https://homeoffice.brandworkz.com/bms/?link=TzLtT1Ad
• KYC/KYCC!!! Screen ALL clients thoroughly - Understand their
ownership and links to foreign powers Conclusion: The New Compliance Frontier
• Assess activity purpose – Could it influence politics, perception,
or government? The message is clear: in today’s climate, if your work involves
• Seek legal advice – When in doubt, consult compliance counsel foreign direction or political influence, transparency is
• Register on time – Don’t wait for an investigation to begin non-negotiable.
• Train your team – Make FIRS and FARA part of internal compliance protocols
• Use official toolkits – Access sector-specific guidance from the Schemes like FIRS and FARA represent a new chapter
UK Home Office and DOJ in regulatory oversight, one where private investigators,
researchers, and litigation support specialists are now
Next Steps: Ongoing Guidance from the Home Office firmly in the frame.

Following its presentation at the ABI Annual Conference, the UK Home Office By staying informed, registering when required, and
delivered a series of webinars in May and June 2025 to explain the implications embedding compliance into your operations, you not only
of FIRS. These sessions focused on: reduce legal risk, but reinforce the professionalism and
• Real-world examples integrity that define our industry at its best.
• Clarification of the scheme’s scope
• Registration timelines Happy Centennial to the
• Enhanced Tier case scenarios World Association of Detectives!

www.wad.net | Ocktober 2025 21