How to Read a
FARA Exhibit AB
The Exhibit AB is the most important document in a FARA filing. It is the actual contract (or a summary of the agreement) between the foreign agent and their foreign principal. For FARA #7649 (Clock Tower X), the Exhibit AB discloses the contract with Havas Media Germany on behalf of the State of Israel, and later Exhibit ABs show how it changed: from $1.5 million a month to a $9 million budget pool, then monthly digital advertising schedules for 2026.
What is Exhibit AB?
Under FARA regulations (28 CFR 5.201), every registration statement must be accompanied by Exhibit AB — a copy of the contract or agreement between the registrant and their foreign principal, or a detailed summary of the agreement if no written contract exists.
Exhibit AB is where you find: the parties to the agreement, the compensation structure, the duration, and crucially, the specific activities the registrant is being paid to perform. This is the primary document that reveals what the foreign government is paying for.
Key Fields to Examine
Field: “Parties”
Lists the registrant (the foreign agent) and the foreign principal. In FARA #7649: Clock Tower X LLC (registrant) and Havas Media Group Germany GmbH (foreign principal intermediary). Note whether the foreign principal is the government directly or an intermediary — both require registration.
Field: “Compensation Structure”
The dollar amount, frequency, and payment method. FARA #7649: the first Exhibit AB (September 18, 2025) set a budget pool of $1.5 million per month for four months, plus Clock Tower X matching funds. An amendment filed December 26, 2025 replaced that with a $6 million lump sum plus $3 million for digital advertising, a $9 million pool. Exhibit ABs filed June 7 and October 5, 2026 list $4.5 million a month for digital advertising, April through December 2026. Always read the later Exhibit ABs: the first one is rarely the whole contract. Look for whether compensation is fixed, performance-based, or includes expense reimbursements.
Field: “Scope of Activities”
The specific activities contracted. This is the most important section. FARA #7649 lists: anti-antisemitism campaigns, AI-driven content generation, SEO manipulation, and integration with Salem Media Network properties. Each activity may have separate 22 USC 614(b) implications.
Field: “Duration and Termination”
The contract start and end dates. Some contracts auto-renew. Supplemental statements filed after the initial registration update whether the contract is still active.
Field: “Governing Law”
Which jurisdiction's law governs the contract. FARA #7649: Delaware law (reflecting Clock Tower X's Delaware formation). This does not affect FARA's applicability — FARA is federal law.
Field: “Exhibit AB Filing Date”
The Exhibit AB may be filed before the registration statement (the contract is signed, then the agent registers within 10 days). FARA #7649: the services agreement is dated September 8, 2025; its Exhibit AB and the Registration Statement were both stamped September 18, 2025.
FARA #7649 Exhibit AB: Key Findings
Know someone who needs to see this?
Share on X