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Foreign campaigns to influence American officials are supposed to be transparent under the Foreign Agents Registration Act, a law requiring detailed disclosure of foreign influence efforts. But few believe FARA — passed in 1938 to combat Nazi propaganda — has been working well. It is riddled with exemptions. Enforcement is weak. Criminal penalties apply only to willful violations. Lobbying by VTB, a Kremlin-owned Russian bank under sanctions, is a case study in the flaws of FARA. The bank's hired lobbyists failed to disclose a series of meetings with government officials on behalf of the sanctioned bank until months after U.S. law required them to, and one firm did so only after being contacted by the Center for Public Integrity. The bank sponsored an exclusive gala and invited American officials who oversee sanctions through intermediaries, avoiding disclosure requirements.