While this question addresses if a foreign national can donate to a pac, what about having an officer role in a super pac while registered as a foreign agent?

Democratic presidential candidate Joe Biden has a brand new Super PAC in his corner, and it’s being run by a registered foreign agent for the government of Azerbaijan. Larry Rasky, a lobbyist who previously worked as a top campaign operative for Biden, is listed as the treasurer of the PAC, according to records filed with the Federal Election Commission (FEC).

Records filed with the Department of Justice show that Rasky is also a registered foreign agent lobbying on behalf of the government of Azerbaijan.

While U.S. election law prohibits foreign nationals from making political contributions, and seems to be practiced in the breach more than in the observance [the article has a litany of past offenders, Trump, Jeb Bush, and Obama] I haven't seen anything about having an officer role while working as a foreign agent, albeit as a citizen. Is this common over the past 3 presidential election cycles? Is it legal?

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    according to washingtontimes.com/news/2019/oct/29/…, his contract ended last week, and according to politico.com/news/2019/10/29/…, he stopped working for Azerbaijan in aug. he's not a foreign agent anymore.
    – dandavis
    Commented Oct 30, 2019 at 0:46
  • Do you have any reason to believe that Larry Rasky is not a US citizen?
    – phoog
    Commented Oct 30, 2019 at 4:21
  • @phoog no, not really the question though
    – user9790
    Commented Oct 30, 2019 at 11:08
  • In that case perhaps you should remove the words "a foreign national registered as" from the question title. Also, the last paragraph seems to be asking about foreign nationals rather than foreign agents. (In the meanwhile, I looked up Larry Rasky's foreign agent registration, and it indeed states that he is a US citizen.)
    – phoog
    Commented Oct 30, 2019 at 14:11
  • I like this question. A lot We know that foreign money is not supposed to flow into PACS or campaigns, so I'd assume there would be a similar ban on having such a role, but in the sleazy world of US campaign financing, with PACs specifically designed to circumvent other restrictions, I'd face a strong chance of being wrong. +1, because that's the limit of how much I can give. Maybe we need a reputation PAC on this stackexchange.... in the spirit of its subject matter. Commented Oct 30, 2019 at 15:01

1 Answer 1


In U.S. government parlance, the phrase "Foreign Agent" refers to anyone who is working for the interests of a government that is not the government of the United States, regardless of citizenship of person. Lobbies for other nations may represent U.S. Citizens interests in foreign policy with respect to that nation OR that nation's interests with respect to U.S. Foreign policy. While the latter is typically the job of an Ambassador and embassy staff, it's perfectly legal to go to lobby firms, which better know the ins and outs of Washington politics and may help the Ambassador do his or her job. The other common reference to "Foreign Agent" is typically a spy... which is technically true as they are acting on behalf of a foreign government... but it's not in any diplomatic interest.

In both examples, this usually requires a person who is a U.S. Person (typically a citizen, though a U.S. Resident may do) so to distinguish from legal lobby work and illegal espionage work, anyone in the U.S. working for a foreign government must disclose or register as such (Embassy staff typically don't, as there is a very different process that accredits the individual as an ambassador or other staffer). Naturally, spies do not register... at least the ones with a functioning brain, as registering as a spy makes the counter-intelligence agent's life a hell of a lot easier.

It's important to point out that a "Foreign Agent" need not be a "Foreign Citizen" nor is a "Foreign Citizen" necessarily a "Foreign Agent" a German working on a work Visa in the United States and working for a private industry, not the Government of Germany, and is thus not an Agent. Agent in U.S. terminology is "one who works for a government", typically with executive functions but not all government have three branches of government... or divided the same powers among them.

So it is entirely possible for a U.S. Citizen to be a Foreign Agent. Registering only discloses that you are taking money from a foreign government for work done on their behalf, not that you are switching to support them in violation of laws. If you apply for jobs with security clearances with the U.S. Government, it's not an automatic disqualification either, but you should probably not be surprised when you get a lot of questions about what you were doing when you were a foreign agent.

  • "a German working on a work Visa in the United States is not working for a private industry, not the Government of Germany": I think there's one "not" too many here. I suspect the first one should be deleted, but I am not certain. I also note that the "foreign principal" with which a registered agent is associated need not be a government. It can be any foreign person, including corporate persons, or even a US citizen who is domiciled outside the US (for the latter, see 22 USC 611(b)(2)).
    – phoog
    Commented Oct 30, 2019 at 14:13
  • @phoog: Thanks for the catch. Changed to clarify. And you're right, but since the question was about someone who worked for a foreign government interest, I decided to not confuse the matter. There's also a legal term of "U.S. Person" which can apply to people who are not citizens and not physically in U.S. territory.
    – hszmv
    Commented Oct 30, 2019 at 14:28
  • "US person" means different things in different contexts. Compare 31 CFR 560.314, which includes any person in the US regardless of citizenship or residence, 50 USC 1801(i), which excludes nonimmigrant aliens even if they reside in the US, and 26 USC 7701(a)(30), which includes nonimmigrant aliens only if they reside in the US.
    – phoog
    Commented Oct 30, 2019 at 14:56
  • This defines the terms but doesn't really address the heart of the question, but +1 for the additional info
    – user9790
    Commented Oct 30, 2019 at 15:33
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    Not donating, running Pacs
    – user9790
    Commented Oct 30, 2019 at 16:34

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