The US Sanctioned Georgia and Nicaragua for Laws That Copy the US

Reprinted from Covert Action Magazine with the author’s permission.

Politicians in the small Caucasian nation of Georgia have been sanctioned by Washington for “undermining democracy” and depriving Georgian people of “fundamental freedoms,” simply because its parliament has passed a law to control foreign influence over Georgian politics.

Politicians in another small country, Nicaragua, were subjected to U.S. sanctions for doing the same. Although the two countries are very different, there are striking similarities in the ways that Washington and its allies have striven to undermine their sovereignty.

In both cases, legislation to limit foreign influence followed coup attempts against popularly elected governments. The governing Georgian Dream Party, having won three elections since 2012, has survived two U.S.-orchestrated coup attempts since 2020.

Nicaragua’s ruling Sandinista Party had also won three elections in 12 years when a coup was thwarted in 2018 (it has since won another election, in 2021). Both countries’ governments found that non-governmental organizations (NGOs) financed from abroad were heavily involved in these insurrections and moved to control them. And both modeled their legislation – not on Russia as is claimed – but on longstanding U.S. federal law.

The Foreign Agents Registration Act (“FARA”) came into force in the U.S. in 1938. It requires NGOs and other organizations and individuals who receive funding from abroad to register as “foreign agents.” FARA-style legislation now exists in many other countries.

In recent years the U.S. has used FARA to crack down on what The New York Times called “prominent Washington research groups [receiving] tens of millions of dollars from foreign governments,” creating a “muscular arm of foreign governments’ lobbying in Washington.”

The Times article is replete with arguments for taming the influence of foreign governments on U.S. politics. Indeed, Washington’s most recent concern has been to expose what have been dubbed “Trojan horse” charities, those NGOs that have political objectives behind their charitable work.

However, neither Washington nor its allies abroad or in the corporate media approve of countries outside the West adopting similar powers. The reason is, of course, that they might expose the very Trojan horses created by Washington or by European capitals to interfere in those countries’ politics or even to provoke regime change.

Both Georgia and Nicaragua want to protect their sovereignty and try to limit foreign influence over their national affairs – aims that are uncontroversial in Western countries.

Before implementing its equivalent of FARA, Nicaragua’s population of under seven million sustained no less than 7,000 NGOs, most of which were likely to have been dependent on foreign funding. Georgia’s current position is far more extreme: A country of just 3.8 million people hosts around 26,000 NGOs, the vast majority funded from abroad.

Of course, in both countries these non-profits have often been involved in worthwhile humanitarian work. But, again in both cases, Washington and its allies have also been financing bodies that can legitimately be called Trojan horses.

And as Kit Klarenberg points out in The Grayzone, NGOs in Georgia have until now benefited from lax rules about foreign funding – as indeed those in Nicaragua did before its 2020 legislation took effect.

What do Trojan horse NGOs actually do? Their websites typically have mission statements and programs aimed at “promoting democratic values,” “capacity building,” “strengthening civil society,” advocating “good governance,” “raising civic awareness” and finding “a new generation of democratic youth leaders.”

These are essentially labels for what is really pro-Western propaganda, often directed at young people who are simultaneously encouraged to adopt “modern,” “liberal” values and lifestyles and be critical of their governments for failing to toe Washington’s line.

There are prizes: salaried jobs, training courses (perhaps overseas) for NGO recruits, opportunities to learn English, and more. As Jacobin puts it, “working in an NGO is a fast track to high incomes, perks like foreign travel and embassy receptions, and being part of the elite.”

Georgians wave U.S. and Ukrainian flags as they protest the government’s proposed “foreign influence transparency law.” [Source:]

Unmentioned in public documents might be training in organizing “non-violent” anti-government protests and exploiting social media to foster discontent. In the Georgian context, this is called a “color revolution” which, as The Nation puts it, “has become a byword for pro-Western, protest-driven regime change.” In Nicaragua, Yorlis Luna talked to young people who explained how Trojan horse NGOs schooled them to prepare for the “peaceful protests” that quickly became a violent coup attempt in 2018.

When well-funded NGOs join forces with local “human rights” bodies and with local media that are also foreign-funded, the combined effects can be powerful. In Georgia, The Nation quotes labor activist Sopo Japaridze as saying that there does not appear to be a single major foreign-funded civil society or media organization that is not fervently opposed to the elected government. “The entire ecosystem is against them,” he says, “and the NGOs have more power and influence than the government does internationally.” Similar words could have been used to describe Nicaragua in 2018.

While regime change was the U.S. objective in both countries, the motivation differed. Nicaragua was targeted because it poses the “threat of a good example” – a socialist-oriented country in a region which the U.S. views as its “backyard.”

Georgia is being targeted because of its balanced political position, moving toward future membership of the European Union while maintaining peaceful relations with its next-door neighbor, Russia. As its prime minister points out, both Washington and its EU allies want Georgia firmly in the anti-Russia camp, a new “frontline against Russia.”

Where does a Trojan horse NGO get its funding for its regime-change work? The foreign funding of Nicaraguan NGOs was little known-about before the coup attempt in April 2018, but within a month an article in Global Americans, “Laying the groundwork for insurrection,” highlighted Washington’s role.

Then on June 14, Kenneth Wollack, now chairman of the federally funded National Endowment for Democracy (NED), bragged to the U.S. Congress that NED had trained 8,000 young Nicaraguans to take part in the uprising. USAID later launched a specific program aimed at influencing the outcome of the 2021 elections. I have documented the role of U.S.-funded NGOs in the coup attempt and in subsequent regime-change efforts in Nicaragua.


In Georgia, foreign funding of NGOs is out in the open. Jacobin says that 90% of NGOs are financed from abroad, and prominent ones, such as the Economic Policy Research Center, the Europe Georgia Institute and the Institute for Development of Freedom of Information, make no secret of having funding sources such as the NED, the European Union and even NATO. One that receives NED funding, the Shame Movement, is explicit about its aim of drawing Georgia into the European Union.

Klarenberg reports that, in 2023, when Georgian Dream made a previous attempt to bring in a FARA-style law, it had to capitulate when vast, violent crowds, with the Shame Movement “in the vanguard,” threatened to overrun parliament and bring about a color revolution.

Members of Shame Movement speaking outside of Georgia’s parliament. [Source:]

The “outsized role” played by foreign-funded bodies has, according to Jacobin, “led the country into a chronic democratic crisis.” It is therefore hardly surprising that the government continues to push ahead with legislation to control them.

What is such a law and what happens when it is implemented? FARA-style laws generally do not prohibit foreign funding, they simply require it to be declared, so that the way it is used can be documented and made transparent. NGOs that are really Trojan horses can then be identified. Closures of NGOs inevitably result—but usually only a small minority are identified as Trojan horses.

Most closures come about because NGOs cannot or will not comply with more stringent accounting requirements, or the change brings to light redundant NGOs that exist in name only.

In Australia, more than 10,000 non-profits were closed when its FARA-style law was implemented. The equivalent authorities in the U.S. and UK close thousands of NGOs each year for non-compliance or because they cease to operate.

Nicaragua has closed about half of the NGOs it had before its FARA-style law took effect, and while the initial closures were Trojan horses the vast majority have lost their NGO status through non-compliance or because they are effectively defunct.

Protest against NGO law. [Source:]

The Trojan horse role of NGOs was perhaps most obvious in Russia, a developed country which nevertheless had many foreign-funded charities before it introduced a FARA-style law in 2012. Scott Ritter reports that the law “proved to be the death knell for U.S., UK, and EU-funded non-governmental organizations (NGOs) that had spent more than two decades trying to, according to their leaders, shape Russian civil society along Western lines.”

In 2015, Russia blacklisted the National Endowment for Democracy but nevertheless, in 2021, the NED still had more than 60 Russia-oriented projects, valued in the millions of dollars, but presumably now based outside the country.

When the foreign funding of NGOs comes under threat from an equivalent to FARA, it is hardly surprising that the NGOs protest.

This happened in the U.S. when it toughened foreign agent rules in 2022, provoking a response from NGOs across the political spectrum.

It happened in Australia in 2018 and in the UK in 2023 when they announced similar laws. Protests from NGOs in Georgia were to be expected, just as they were in Nicaragua, because the NGO sectors are heavily dependent on foreign funding and fear its loss, job cuts and possible closures.

What distinguishes the protests in Georgia and Nicaragua, and indeed other non-Western countries such as Thailand where controls on NGOs have been tightened, is that the threat of FARA-style legislation is used to create a sort of moral panic by human rights bodies, the corporate media and the spokespeople for Western governments.

According to this narrative, such a law would not just bring over-zealous regulation of one sector of society, but threaten the whole society’s freedom of expression and its democratic values. This claim is used to justify the mobilization of well-publicized anti-government protests, ostensibly non-violent, but which can rapidly provoke a response from police that can justify violence in return.

As political scientist Glenn Diesen points out, “the media shows some pictures of protests and we are ready to redefine democracy as the rule of a loud Western-backed minority to support intimidations, sanctions and a coup.”

While the cases of Georgia and Nicaragua differ somewhat, because in Georgia “non-violent” protests responded to the impending legal changes while in Nicaragua they were ostensibly about minor changes in state-funded pensions, in both cases the regime-change motivation of the protesters quickly became apparent.

Diesen notes that the same occurred in Ukraine in 2014: Western governments and NGOs “backed an unconstitutional coup against a democratically elected government and the coup was only supported by a minority of Ukrainians. Yet, it was sold to us as ‘pro-Ukrainian’ and a ‘democratic revolution’ so we supported it without any critical debate.”

The unconstitutional coup in Ukraine was, from Washington’s viewpoint, a success. But similar actions in Georgia and Nicaragua have – so far – been counterproductive. To alleviate the damage being done by US sanctions, Nicaragua is developing close relations with both China and Russia. Meanwhile, after passing the legislation to control NGOs this month, the Georgian Dream party is reported to be “actively working” to restore the country’s diplomatic relations with Russia.

One final intriguing connection between Georgia and Nicaragua is the presence of a global NGO called the Center for Applied NonViolent Actions and Strategies (CANVAS), headed by Slobodan Djinovic, which claims to have trained regime-change activists in 52 countries. CANVAS, supported by USAID, had been training activists in Georgia at the end of 2023 when the “color revolution” appeared to be imminent.

Whether CANVAS had a role in Nicaragua’s 2018 insurrection is unclear, but the NGO has certainly been active in Venezuela and a CANVAS official visited Nicaragua in the aftermath of the coup attempt. Djinovic uses Nicaragua’s failed coup as a case study in a course on “non-violence” that he teaches at Harvard.

Sanctions imposed by the White House on Georgian officials who are promoting FARA-style legislation mirror the steps taken against the Nicaraguan government when it did the same in 2020. Instead of admitting that laws to oversee the foreign funding of non-government organizations have been adopted by many Western-aligned countries, Georgia’s plan has been dubbed “Russian Law,” just as—at the time—Nicaragua’s equivalent was labeled “Putin Law.”

Corporate media such as the BBC have repeated Washington’s line and quote Secretary of State Antony Blinken at length, without pointing out his hypocrisy in criticizing a country for adopting legislation that is, in reality, based on U.S. law, not Russia’s.

The irony is that FARA was originally sold as a means of defending democracy when it was introduced in the U.S. more than 80 years ago. But if a similar law is used by a country which Washington or its allies regard as disobedient, such use is painted as an attack on democracy and as a step on the road to authoritarian government.

Dubbing the legislation as “Russian law” or “Putin law” makes the message clear.

John Perry is based in Masaya, Nicaragua and writes for the Council on Hemispheric Affairs, London Review of Books, FAIR, and elsewhere. John can be reached at or by his twitter handle @johnperry21.