PAID OFF Act Ends FARA Exemptions for State-Linked Foreign Corporations, Sunsets in Five Years

The “Preventing Adversary Influence, Disinformation, and Obscured Foreign Financing Act of 2025,” or the PAID OFF Act, is taking aim at how certain foreign entities lobby and influence policy in the U.S. In short, this bill closes some loopholes in the Foreign Agents Registration Act (FARA) for agents representing specific foreign governments and their state-owned companies.

Closing the Corporate Loophole

FARA requires agents representing foreign interests to register with the Department of Justice, providing transparency about who is paying whom to influence U.S. policy. However, FARA has several exemptions, including one for agents whose activities are purely commercial or relate to legal representation. This bill (Sec. 2) removes those exemptions for agents representing foreign principals that are either a corporate or government entity owned or controlled by a country designated as a “country of concern” by the State Department. If you’re a lobbyist or PR firm representing a state-owned bank or a major corporation from one of these designated countries, you can no longer rely on those commercial or legal exemptions to avoid registration. This means more paperwork, more transparency, and higher compliance costs for those specific agents, but it also means the public gets a clearer picture of who is being paid by state-linked foreign entities.

The State Department’s New Gatekeeping Role

The bill also sets up a new, highly structured process for updating the list of “countries of concern” (Sec. 3). Currently, this list can be updated, but the PAID OFF Act formalizes the process. The Secretary of State, after consulting with the Attorney General, can propose adding or removing countries from the list. This is the initial gatekeeping power—the Secretary decides who gets nominated for the list.

However, the change doesn't happen automatically. Any proposed modification must be submitted to specific Congressional committees and only becomes law if Congress passes a specific “joint resolution of approval.” This is where things get tricky. The resolution must meet strict requirements—no preamble, specific language, and a mandatory title. This kind of legislative requirement is a high procedural hurdle, meaning that even if the State Department identifies a new threat or decides an old designation is outdated, Congress must actively agree to the change via a specific, non-amendable resolution. For busy people, this means the list of adversarial nations might be slow to update, potentially staying outdated if Congress can’t find the time or political will to pass the necessary resolution.

The Five-Year Timer

One final detail that matters: This entire Act is set to expire five years after it becomes law (Sec. 4). This “sunset clause” means that the tougher FARA rules and the new mechanism for updating the country list will automatically vanish unless Congress passes new legislation to renew them. For the agents and foreign entities affected, this means any new compliance requirements might only be temporary, though five years is a long time in the lobbying world. For the government, it means they’ll have to re-evaluate the effectiveness of the law relatively quickly, or risk letting the provisions lapse.