Part 4: Foreign Activities and Foreign Influence Registration Scheme Section 70: Meaning of "political influence activity"
Section 70 defines "political influence activity".
	Subsections (1) provides that an activity is political influence activity if it meets both of two conditions: (a) it is of a type of activity that is listed in subsection (2); and (b) the purpose, or one of the purposes, for which it is carried out is to influence a matter (for example, a decision), or a person, listed within subsection (3).
	Subsection (2) lists activities that are capable of being "political influence activity". These activities are: (a) making a communication to an individual in a role that is listed in Schedule 14; (b) making a public communication, except where it is reasonably clear from the communication that it is made by or at the direction of a foreign power; or (c) distributing money, goods or services to UK persons. Subsection (5) provides that the term ‘UK person’ has the same meaning as given by section 2(6).
	Subsection (3) lists the matters and persons that the activity must seek to influence in order to be "political influence activity". The matters or persons are any of the following: a) an election or referendum in the UK (such as the outcome of a general election); b) a decision of a Minister of the Crown (as defined in the Ministers of the Crown Act 1975), a UK government department, a Northern Ireland Minister or department, the Scottish Ministers, or the Welsh Ministers; c) the proceedings of a UK registered political party (such as their manifesto commitments); or d) a Member of either House of Parliament, the Northern Ireland Assembly, the Scottish Parliament or Senedd Cymru when acting in their capacity as such. Activities which seek to influence these individuals in their personal capacity are not considered political influence activities.
	Subsection (4) sets out that the publication or dissemination of information, a document or other article, or production of the same for publication or dissemination, constitutes "making a public communication" under subsection (2).
	Subsection (5) defines a "Northern Ireland minister", "UK person", "UK registered political party" and "Welsh minister", for the purposes of this section.
Example (1): Establishment of a foreign influence arrangement (communication)
A diplomat posted at a UK-based embassy of a foreign government makes contact with a well-established consultant, who has a wide range of senior contacts within the UK Civil Service. The diplomat hosts the consultant at a reception at the ambassador’s residence, and asks him to present a case to senior civil servants for nationals of the foreign country to be granted visa-free status to visit the UK. In return he offers an invitation to attend an all-expenses-paid conference organised by his country’s government, helping the consultant to build his profile among high-ranking businessmen in that country.
The consultant sends an email to a senior civil servant within the Home Office setting out the case for visa-free status for nationals of the foreign country and arranges a follow-up meeting.
The consultant ("P") would be required to register his arrangement with the diplomat (the direction to communicate with senior civil servants to influence the decision of a UK government department) within 28-days, as it involves political influence activities to be carried out at the direction of a foreign power.
Example (2): Establishment of a foreign influence arrangement (public communication)
A UK-based lobby firm enters into a contract with a government department from a foreign country, which hopes to persuade the UK government to impose tougher regulation on the fossil fuel industry.
As part of the contract, the lobby firm is directed by the foreign government department to prepare and publish articles which outline loopholes in an environment focussed Bill which is currently being considered by Parliament. They make suggestions for amendments which MPs should table, and clauses in which MPs should vote against the government.
As the lobby firm ("P") is making public communications at the direction of a foreign power in order to influence MPs, they would be required to register the arrangement (the direction to make public communications to influence MPs) within 28 days of entering into the contract with the foreign government department.
Example (3): Establishment of a foreign influence arrangement (disbursement)
An entrepreneur in the UK is contacted by the Foreign Affairs Office of a foreign country and asked to leverage relationships to influence legislation on trade matters which will affect investment from the foreign country in the UK. The Foreign Affairs Office offer him substantial amounts of money for doing so, which he invests into the construction of a new cultural centre, which has been a long-standing ambition of the local MP. The entrepreneur intends that, by doing so, he will nurture a relationship with the MP in order to influence voting on the matters which concern the foreign country in the legislation, in line with the direction given by the foreign power.
As the entrepreneur ("P") is carrying out disbursement activities in response to a direction from a foreign power to influence an MP, P is required to register the arrangement (the direction to leverage relationships to influence an MP).
Example (4): Registration not required
The UK-based embassy of a foreign country contracts a conference facilitator to organise an event with UK businesses in the financial services industry in order to discuss how to prevent future financial crises.
The conference facilitator organises the event, providing networking facilities and catering services to UK businesses.
Whilst the conference facilitator is providing services to UK businesses at the direction of a foreign power, it is not intended to influence a matter which would trigger a registration requirement, and therefore does not require registration.
Example (5): Registration not required
A state-owned enterprise, which is 25% funded by a foreign government, attends a conference in the UK, which is attended by UK ministers and special advisers. At the conference, the state-owned enterprise speaks to a UK Minister and highlights an issue in UK regulation which adversely impacting the enterprise. Whilst the company is carrying out a political influence activity, it is not doing so at the direction of a foreign power and is therefore not required to register. Being state-owned, or partially funded, by a foreign government does not in itself indicate a direction by a foreign power.