Key Definitions
Arrangement: An arrangement is any type of agreement, whether formal or informal, to carry out activities in the UK. An arrangement can include contracts, MoUs, an order (or similar) of a good or service to be followed up with a bill or invoice, an informal quid pro-quo agreement.
Direction: A “direction” is an order or instruction to act to which a person is obliged or compelled, whether formally or informally, to comply. This could also take the form of a request, if there is a power relationship between the person and the foreign power which adds an element of control or expectation, for example through a contract, payment, coercion or the promise of future compensation or favourable treatment.
Foreign Power: A foreign power is defined as any of the following:
- the sovereign or other head of a foreign State;
- a foreign government, or part of a foreign government (for example, a ministry or department of a foreign government);
- an agency or authority of a foreign government, or of part of a foreign government,
- an authority responsible for administering the affairs of an area within a foreign country or territory (for example, a local government authority in a foreign country);
- a political party which is a governing political party of a foreign government.
Entities that are owned or controlled by a foreign power, e.g. state-owned universities, labs or research institutes are not by default considered to be part of a foreign state.
Please note, within the context of this Scheme, the Republic of Ireland is exempt.
Political Influence Activities: To meet the definition of a ‘political influence activity’ an activity must meet both of the following criteria:
1. The activity must be carried out in the UK and be one of the following:
- A communication (e.g. emails, letters or meetings) to a senior public official or politician.
- A publication, except where it is reasonably clear that it is made at the direction of a foreign power.
- The provision of money, goods or services to an individual or entity in the UK (for example, providing consultancy services to a UK business).
2. The purpose, or one of the purposes of the activity must be to influence one of the following:
- An election or referendum in the UK;
- A decision of a Minister or Government department (including a Minister or Government department of Wales, Scotland or Northern Ireland);
- The proceedings of a UK registered political party (such as their manifesto commitments);
- A Member of the House of Commons, House of Lords, Northern Ireland Assembly, Scottish Parliament or Senedd Cymru (when acting in their capacity as such).