Sullivan & Cromwell LLP

07/10/2025 | Press release | Distributed by Public on 07/10/2025 19:29

UK Foreign Influence Registration Scheme Goes Live

July 10, 2025

Persons Acting at the Direction of Foreign Powers Required to Disclose Activities in the UK

  • From July 1, 2025, the UK Foreign Influence Registration Scheme requires individuals and organizations to disclose arrangements with foreign powers under which they are directed to carry out certain activities in the UK.
  • The FIRS aims to increase transparency of foreign influence in the UK through a two-tier registration regime. The "political influence tier" requires individuals and organizations to register arrangements under which they are directed by any foreign power to carry out "political influence activities" in the UK. The "enhanced tier" applies only to arrangements with specified foreign powers designated by the Government (currently Iran and Russia). It captures any activity carried out in the UK under such arrangement (regardless of whether the activity is political), including commercial activities.
  • Registration of relevant arrangements under both tiers is made by the person who enters the arrangement with the foreign power and must take place within 28 calendar days (under the political influence tier) or 10 calendar days (under the enhanced tier) from the day the arrangement is entered into. Failure to register a relevant arrangement and carrying out relevant activities without registration are criminal offences, punishable by up to two years' imprisonment (under the political influence tier), or five years (under the enhanced tier), a fine, or both. Given the short registration windows, early detection of relevant arrangements is critical to avoid sanctions under the FIRS.

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