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Transparency and FARA Compliance in Our Environmental Work

Waxman Strategies has registered under FARA, as the firm receives grant support (including for its work to support Mighty Earth campaigns) from non-profit organizations that are in turn funded by the Norwegian Agency for Development Cooperation (Norad). Our registration was in response to specific instruction from the U.S. government’s FARA Unit.

This funding supports global efforts to protect forests and Indigenous communities as a key defense against climate change. We are proud of the work we have done with this funding, which has helped significantly reduce deforestation in several major industries, and led to the introduction of significant new human rights and livelihood protections for local communities.

While we profoundly respect the mission of the FARA Unit, we don’t believe that FARA was intended to apply to public interest projects like the forest conservation work we’ve done. But in an effort to continue our work, we have followed the clear direction we received from the FARA Unit and registered our work.

As a result of our FARA registration, we are required to file with the FARA Unit some external communications sent from us to US persons that are funded by Norad. It is important to note what FARA does not require: we do not file or disclose any incoming communications or communications with non-US persons, or any work that is funded from US sources. The bulk of our work in the United States is covered by US sources, and in the near future, we will only use US-based funding for US work, meaning that we will no longer retain our FARA registration.

For the part of our work that is affected for the time being, we have strived to notify people we communicate with of our obligation. In a handful of cases that advance communication didn’t happen, leading to unnecessary surprises, and we apologize and take responsibility for that failure.

The government has recently undertaken a massive expansion in the scope of its FARA enforcement, and there is little precedent for how to operationalize compliance. While we have worked to ensure we are compliant with the law, we also want to ensure public interest work is protected, and our partners are respected. We will work hard to uphold that.

We are happy to discuss further with partners if there are any questions; please contact Glenn Hurowitz at [email protected] to arrange a discussion.

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