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Foreign Influence Transparency Scheme

The Foreign Influence Transparency Scheme Act 2018 (FITS) intends to make transparent the influence of foreign governments or political organisations where it occurs outside of easily recognised channels.

Under FITS, a person is required to register within 14 days of undertaking a registrable activity where that activity is undertaken on behalf of a foreign principal.

  1. Person includes either a natural person or a body corporate.
  2. Registering means completing or maintaining a record of registrable activities on the Transparency Register, maintained by the Attorney-General’s Department.
  3. Registrable Activity includes:
    1. Parliamentary lobbying - Lobbying a Commonwealth parliamentarian (or their staff) for the purpose of political or governmental influence.
    2. Parliamentary lobbying on behalf of a foreign government - Lobbying a Commonwealth parliamentarian (or their staff) for any purpose.
    3. General lobbying - Lobbying a Commonwealth official or agency, a political party or candidate for political or governmental influence.
    4. Communications activity - Communicating material to the public or a section of the public for the purpose of political or governmental influence.
  4. On behalf of means under some sort of arrangement with, or under the direction or supervision of a foreign principal. This is being interpreted as meaning where a foreign principal has an expectation that an activity will be undertaken on their behalf.
  5. Foreign principal means any of the following:
    1. A foreign government or political organisation.
    2. A foreign government related entity which is an entity other than an individual, who is related to a foreign principal that is a foreign government or a foreign political organisation and includes companies, political bodies and other entities that have a foreign principal that has the ability to exercise some form of control over them.
    3. A foreign government related individual. It does not simply mean a citizen of a foreign country – an individual is a foreign government-related individual if the individual is not an Australian citizen or an Australian permanent resident, and a foreign government, foreign government-related entity or foreign political organisation is able to exercise total or substantial control over the individual.

University Compliance

University staff members engaging in activities with a foreign principal are required to complete the International Compliance Review - Foreign Engagements form and send the form to Legal and Integrity at for advice on any further action that may be required.

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