800.01B11 Registration/9–4249
The Chief of the Foreign Agents Registration Section of the Department of Justice (Foley) to the Amtorg Trading Corporation 1
Gentlemen: The Department has, by letter and in personal conferences, pointed out to representatives of your company the obligations of the Amtorg Trading Corporation to file with the Department of Justice the registration statement required under the terms of the Foreign Agents Registration Act of 1938, as amended. Since the termination of the exemption procedure set forth in Section 3(f) of the aforementioned Act, the Department has continuously received information showing that the activities of the Amtorg Trading Corporation are of such a character as to require registration under the Act and to make unavailable the exemption under Section 3(d) relating to activities which are private, nonpolitical, financial, mercantile, or other activities in furtherance of the bona fide trade or commerce of a foreign principal.
In this connection, your attention is invited to Rule 303 (a) of the Rules promulgated by the Attorney General pursuant to the Foreign Agents Registration Act which states that the exemption provided by Section 3 (d) is not available if the subject engages in any political activity, as that term is defined in Rule 100 (8).
As you have been advised previously, registration is accomplished by the filing of a registration statement, supported by the appropriate number of exhibits, each in duplicate, and by the filing of supplemental statements at six month intervals for as long as the agency relationship continues to exist. Appropriate forms are enclosed herewith for your use. An Exhibit A should be filed for each director and officer of the corporation and for every employee other than stenographers and clerks. Additional copies of the forms may be had upon request.
In view of Section 2 (a) of the Act, and of the long continued agency relationship which has rendered Amtorg Trading Corporation liable [Page 760] to the registration provisions of the Act, immediate compliance is required.
Sincerely yours,
- The copy of this letter was sent by William E. Foley to G. Frederick Reinhardt, Chief of the Division of Eastern European Affairs of the Department of State, in accordance with his request under a covering letter dated September 12, 1949.↩