Over the last few years, a conventional wisdom has developed about the arc of FARA enforcement. It goes a little something like this: In the beginning, Congress created FARA. Then DOJ rested. For nearly 80 years, it was not enforced, carried no penalties, and was largely ignored. Beginning in 2017, the Special Counsel’s Office used the statute to investigate and charge Russian Internet trolls and politically influential Americans alike. Suddenly, this vague statute transformed from an administrative afterthought into an unpredictable source of criminal liability. FARA registrations skyrocketed, and conferences of white collar defense attorneys organized soon thereafter.