The Foreign Lobbyist Influence Tracker, a joint effort of ProPublica and the Sunlight Foundation, digitizes some information from public disclosure forms required by the Foreign Agent Registration Act (FARA). FARA, passed in 1938, tracks the efforts of individuals and firms hired by foreign governments, political parties and government controlled entities to influence U.S. officials and U.S. political opinion. FARA requires registrants representing such clients (hereinafter, foreign lobbyists) to file a number of different kinds of disclosures with the Justice Department: An initial registration with two accompanying exhibits (one with information on the client, referred to in FARA forms as the foreign principal, the other with information on the services to be rendered or a copy of the agreement specifying them); short form registrations for all individuals who will be representing the foreign principal, and a supplemental statement, which must be filed every six months and provide detailed information on what a foreign lobbyist has done for a foreign principal. The information in the Foreign Lobbyist Influence Tracker is drawn from the supplemental statements filed by foreign lobbyists in calendar year 2008.
Supplemental statements forms are nine pages long, ask 23 separate questions, six of which have multiple parts, requiring foreign lobbyists to disclose everything from changes of address of their employees to the expenses they billed to their clients. The statements also require foreign lobbyists to list the names of government officials—including members of Congress, their staff and executive branch officials—that they contacted and list the lobbying firm hired by a specific foreign client. Lobbyists for foreign clients who register under FARA disclose far more information about what they do to further the interests of their clients than traditional lobbyists, who, under the Lobbyist Disclosure Act of 1995, report to Congress. Under the LDA, lobbyists need only disclose the governmental bodies they contact, and need not specify the number of contacts they have or the dates of those contacts.
Foreign lobbyists submit supplemental statements to Justice either electronically or by mail; many of the forms are filled out using a typewriter—some are even handwritten. FARA records were only available to the public at an office building in downtown Washington, D.C. until May 30, 2007, when Justice began making them available online. However, because so many filings are submitted on paper, FARA records are posted online as non-searchable PDF files. ProPublica and the Sunlight Foundation set out to digitize some information for the forms to make it more accessible to the public and reporters. Since these forms are made available online as image files, all the information in this database was hand-keyed by an outside contractor, ILM Corporation. Once this was completed, the information was fact-checked against the original records and standardized to allow for aggregate functions, such as finding out how much a country spent on lobbying in 2008.
The Foreign Lobbyist Influence Tracker digitizes the name of the foreign lobbyist (question 1a on the supplemental statement), foreign principal names (questions 7, 8 and 9), political activity undertaken (question 12), fees paid by a foreign principal (question 14) and political contributions made by employees of the foreign lobbyist or its political action committee (question 15c).
Users can look up records in the database by the name of foreign lobbyists and of foreign principals. We have assigned countries of origin to all foreign principals—for multinational associations like the Caribbean Tourism Organization, we relied on the address of the foreign principal provided on the supplemental statement to determine the country of origin; where those were omitted, we relied on the initial registration exhibits A and B. This allows users to browse by country.
The FARA supplemental statement describes political activities as “any activity that the person engaging in believes will, or that the person intends to, in any way influence any agency or official of the Government of the United States or any section of the public within the United States with reference to formulating, adopting or changing the domestic or foreign policies of the United States or with reference to the political or public interests, policies, or relations of a government of a foreign country or a foreign political party.” Thus, foreign lobbyists list a wide range of contacts—including government officials, reporters, policy analysts at think tanks, academics and others. We standardized only the names of members of Congress contacted and where possible linked staff members to their bosses to allow users to see which member offices were contacted over which issues.
Foreign lobbyists who engaged in political activity on behalf of foreign principals are supposed to “describe in full detail all such political activity, indicating, among other things, the relations, interests and policies sought to be influenced and the means employed to achieve this purpose.” With varying degrees of detail, foreign lobbyists list the names of the individuals, the date of the contact, the method by which the individual was contacted (phone call, email, in-person meeting) and the policies they are trying to influence. The database provides information on the method of contact where this is revealed, lists the level of contact for congressional contacts (that is, was the meeting with staff or the member), the name of the individual contacted and, for congressional contacts, the office for whom the staffer worked, and a text searchable field that reproduces what registrants disclose. Some entries in the issue field have an asterisk beside them—in those cases, there were no specific issues mentioned for the contact, but rather one overarching description of the political activities that the foreign lobbyist undertook for its client. Thus, when the issues field contains an asterisk, users should note that some of the topics described might not have been raised in that specific contact.
The database also provides information on payments from clients to foreign lobbyists. Supplemental statements require foreign lobbyists to report, for question 14, money they have received from their clients along with funds “from any other source, for or in the interests of any such foreign principal, any contributions, income or money either as compensation or otherwise.” A few entities that register under FARA—including, for example, LISCR LLC, a Virginia company that collects fees owed by ship owners to the government of Liberia for registering under that country’s flag—do collect money for their foreign clients. Foreign lobbyists are supposed to report a date and purpose for each payment they received. In our analysis of the data, we relied on the listed purposes to distinguish between fees paid for lobbying and money collected for a foreign client; we did not include the latter when calculating the total amount spent on foreign lobbying.
When looking up foreign lobbyists, users can see, in addition to the contacts they made on behalf of their clients, the contributions they made to political campaigns, political party committees and political action committees controlled by individual members of Congress (leadership PACs). Similarly, when looking up individual members of Congress, one can see, in addition to the contacts they and their staff members had with foreign lobbyists, any campaign contributions they received from foreign lobbyists.