Bergman Introduces Think Tank Transparency Act of 2022, Grassley Introduces Senate Companion

Today, Rep. Jack Bergman introduced legislation to require greater transparency in the rampant foreign funding of think tanks and other public policy-focused non-profit entities, in order for the public and government officials to know the foreign influence behind research or policy recommendations.

The Think Tank Transparency Act of 2022 requires certain non-profits engaged in influencing U.S. policy or public opinion to promptly make available for the American public all funds provided by foreign principals, as well as all contracts and agreements they enter into with foreign principals. Within 90 days of receiving funds from or signing agreements with foreign principals, public policy nonprofits will be required to disclose the funding and contracts to the Department of Justice—who in turn will make such disclosures available for immediate public inspection on an Internet database similar to

“Think tanks have an enormous influence on U.S. public policy, and many receive millions from foreign entities who have a significant interest in how our policy is shaped. Congress and the American people deserve to know what these think tanks are up to, and who they’re working for,” said Bergman regarding the new legislation. “The assumption that they are non-political, academic entities advocating for policies in our national interest is not always accurate, given the increasing amount of funding they receive from foreign governments, often earmarked for specific projects,” Bergman noted.

“Billions of dollars go toward funding policy research, recommendations and expert testimony at public policy non-profits. Much of that comes from foreign powers, including China, Russia, Qatar and others. Those foreign powers clearly have an interest in directing American foreign, domestic and security policy to their benefit. Congress, the executive branch, and the American people deserve to know who’s influencing research and public policy in our country,” Senator Chuck Grassley said.


In June, Rep. Bergman sent a letter to Attorney General Merrick Garland regarding disturbing reports of a potential criminal case against retired four-star Marine General John R. Allen for his role in an apparent foreign lobbying campaign on behalf of Qatar. The court filings indicate that General Allen engaged in aggressive, behind-the-scenes efforts in 2017 to help Qatar influence U.S. policy in the midst of a diplomatic crisis without registering as a foreign agent under the Foreign Agents Registration Act (FARA). This alleged conduct on behalf of Qatar occurred shortly before Gen. Allen was appointed President of the Brookings Institution, whose largest donor over the past 15 years has been the State of Qatar. According to the court filings, General Allen misrepresented his role in the lobbying campaign to officials of the U.S. government, failing to disclose that he was acting in accordance with what the Emir of Qatar, Tamim bin Hamad Al-Thani, asked of him, while also “simultaneously pursuing multimillion-dollar business deals with the government of Qatar.” The FBI says that Allen gave a “false version of events” and that “there is substantial evidence that these FARA violations were willful.”

But it appears that even though Gen. Allen’s alleged conduct was apparently done for the benefit of his employer’s primary benefactor—the State of Qatar—it remains unlikely that DOJ will pursue an investigation into whether or not Brookings Institution violated FARA. This is consistent with the mistaken, but widespread, belief that FARA contains some kind of “think tank exemption.”

No such “think tank exemption” exists in FARA, but the unfortunate reality is that FARA is unlikely to ever be used as a tool to promote transparency regarding the foreign funding of public policy non-profits. This new legislation is designed as a practical, common sense approach to facilitate full transparency regarding the foreign funding of and foreign agreements with think tanks.

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