American or Russian Model? Who are the Actors Demanding Governmental Control over the NGOs?

Reading Time: 7 minutes

Reading Time: 7 minutes


On November 18th, 2022, “People’s Power” – the movement that seceded from the incumbent “Georgian Dream” – issued a statement, noting that the largest part of the aid allocated by the US to Georgia is directed at NGOs, stressing that the money is not used for the development of the country, but is wasted on US’s own “intelligence agencies”. The statement outscored that foreign funding poses a threat to the sovereignty of Georgia, and therefore, the current practice of financing non-governmental organizations should be brought under a strict legal framework. “People’s Power” announced that it will prepare a respective legislative proposal in the near future.

The statement also touches upon media and judiciary, noting that “according to the dictionary of pseudo-liberals”, “independent” is synonymous with “directed from the outside,” and according to this model, the court should be run by “parties controlled by them or NGOs funded by them.” People’s Power further asserted that independent media, according to the model of “pseudo-liberals” is only the one “controlled by agents of foreign influence.”

Irakli Kobakhidze, the Chairman of theGeorgian Dream,” commented on the mentioned statement, noting that the mentioned initiative will be discussed after it is registered in the parliament. Prior, Kobakhidze responded to the speech of the US Senator, Jeanne Shaheen, in which she talked about the setback in terms of reforms in Georgia and the revision of the budget and strategy in relation to Georgia. Kobakhidze stated that the largest part of funding allocated by the US goes to NGOs, and therefore NGOs should be the ones worrying about the possible reduction of US funding.

Countries that Restrict Foreign Funding of Non-Governmental Organizations

Various actors have used Russia’s experience as a preferred model for limiting, controlling or completely banning the funding of non-governmental organizations from abroad. According to the law adopted in Russia in 2012, which was extended in 2022, a person or organization who receives any kind of support from abroad, be it financial or otherwise, and whom the authorities consider being under foreign influence, is declared a foreign agent. “Foreign agents” are prohibited from receiving state funding, teaching at universities, working with children, etc. In addition, the right to block their websites is given to the Russian Communications Agency. According to Russian legislation of 2017, any legal entity that distributes printed or audio-visual material in Russia may be declared a foreign agent, even if it does not have a branch or representation in Russia. From 2021, any media that receives funding from outside Russia may be declared a foreign agent and must indicate this in its publication, as well as on its website, as well as in all video and audio materials and posts.

In 2017, a similar law was introduced in Hungary, according to which any non-governmental organization that received more than 20,000 EUR of funding from foreign sources per year had to be registered as “foreign funded”. In 2020, the Court of Justice of the European Union found this decision inconsistent with EU law, and as a result, the Hungarian government repealed the law in 2021.

In 2018, George Soros’s Open Society Foundation ceased operations in Turkey due to accusations made against them by the country’s government. The Turkish authorities accused the foundation of being connected with the 2013 protests, which was denied by the organization. Since then, Turkey has tightened laws against NGOs. The law adopted in 2021 limited the right of non-governmental organizations in terms of business partnerships, association creation and fundraising. In addition, the country’s Ministry of Internal Affairs was given the right to replace the head of any non-governmental organization accused of terrorism. The authorities often use such charges against activists, journalists, artists and lawyers. The law allowed the government to conduct annual inspections of foundations, especially foreign organizations.

India also has a Foreign Contribution Regulation Act, which is frequently used by the country’s government against NGOs.

Since 2017, China has implemented the Foreign Non-Governmental Organizations Law, which allows the Chinese government to control the activities of NGOs.

After years of labelling NGOs as agents of the West, Venezuela drafted a law in 2022 that would create a new agency, forcing the existing NGOs to register and share information about beneficiaries and activities. The agency will create a fund where all international donations will be collected and it will be decided which non-governmental organization will receive funding. The law has not yet been approved.

Similar to Russia, strict restrictions on non-governmental organizations are in place in Egypt, where the law on the registration of non-governmental organizations was tightened in 2019, on the basis of which many organizations were unjustifiably denied registration. In 2021, at least 46 non-governmental organizations were closed in Belarus due to unfounded accusations.

As can be seen from the list above, the countries where non-governmental organizations face strict restrictions are not characterized by a high degree of democracy.

American or Russian model?

Notably, the members of “People’s Power”, Sozar Subari and Davit Kartvelishvili, noted that they wanted to adopt a US-like model of the foreign agents registration law. The same argument was used by Russia when passing the foreign agents law, claiming that it was similar to that of the US. In fact, Russian and American laws are rather different. According to the analysis of the famous Russian journalist and oppositionist Vladimir Kara-Murza, except for the name, Russian law has nothing in common with the US Foreign Agents Registration Act (FARA), which was passed in 1938 to stop the spread of Nazi and Communist propaganda in the country. Davit Kartvelishvili called the changes in the act “insignificant,” asserting that the spirit remained the same.

In fact, significant changes were made to the act between 1966 and 1995. For instance, the 1966 amendment shifted the focus from propaganda to political lobbying and narrowed the definition of “foreign agents”. The US Department of Justice had an increased burden of proof because, after these changes, FARA only included organizations or individuals that the government could prove acted at the direction, request, direction, or control of a foreign country and engaged in political activities in foreign interests. As of today, such organizations are registered in the FARA list, which are declared to be in the interest of another country, including for the promotion of tourism, etc. As Vladimir Kara-Murza notes, NGOs are not the target of US law, and NGOs that receive foreign funding are not required to register as foreign agents as long as they do not pursue foreign political interests.

In a 2013 article, Kara-Murza emphasized the fact that Russian non-governmental organizations operating in the US and funded by Russian sources, such as the Institute for Democracy and Cooperation and the Center on Global Interests, were not registered as foreign agents by this act. Organizations listed as agents of Russia engaged in lobbying activities and served the interests of the Russian government, Gazprom and those in power. In contrast, the targets of Russian law were non-governmental organizations, the opposition and the media. According to Kara-Murza, Russian law resembles Stalin’s rule more than US law.

Actors that have been demanding the control of NGOs before ‘People’s Power’

Statements about the aid allocated by the US and the West being mostly used not for the interests of Georgia, but for non-governmental organizations are not novel. There have been a number of calls to limit or ban foreign funding of NGOs. From 2016 to 2020, reports prepared by the Media Development Foundation on anti-Western propaganda have highlighted calls from various groups to restrict or ban funding from foreign-funded NGOs. The reports reflect the cases identified as a result of the monitoring and maps the actors behind the calls, among which were:

  • Pro-Russian media (Georgia and World, Saqinform);
  •  Pro-Russian political parties (Alliance of Patriots of Georgia, Conservative Movement, Georgian March);
  • Clergy (Giorgi Razmadze, Davit Isakadze);
  • Various anti-liberal groups (Zviad Tomaradze – Organization “Nation and State,” Soso Manjavidze – former deputy at the City Assembly, Rezo Amashukeli – Poet).

Selected examples of such cases are illustrated below:

Parties Irma Inashvili, “Alliance of Patriots“: “Now the pseudo-liberals want the Georgian Church to no longer have a patriarch, and they are fighting against the patriarch as well. Such conglomerates can be found in many countries today. This is neither surprising nor shocking. The surprising thing here is that this entire conglomerate is financed by the West. Besides, it finances them and no one else! It is also interesting that this conglomerate acts everywhere and always on behalf of the West and, above all, the United States. It is interesting that this conglomerate was actively supported and is still being supported by the US Embassy in Georgia and the American USAID, IRI, NDI, IREX and others”.

Zura Makharadze, “Conservative Movement“: “Any media outlet is a tool to influence politics, same goes for the non-governmental sector, and, therefore, tools to influence politics from the outside are created inside the country, the security of the country requires that this process must be controlled.”

“[Russia’s] TV channel “Dozhd” is an oppositional one, and if you go to its website, the first thing you notice on the website is that the mentioned media is a foreign agent financed from abroad… Let’s implement that in Georgia.”

Giorgi Kardava, “Conservative Movement“: “When we come to power, we will definitely introduce a legislative change, where TV channels and media will be prohibited from receiving external funding.”

Shota Martinenko, “Conservative Movement”: “The West function so efficiently here and governs us not because of the fact that the people choose it; people have the opportunity to choose their government, but the whole system of the media direction, NGO direction and political parties is being financed from the West. If these sources of financing from the West are closed, political forces and media forces acting as agents of the West will no longer have the opportunity to exist in this direction, and the influence of the West will literally be close to zero. 

 Apart from political parties, similar claims have been voiced by a number of local actors, including pro-Russian media outlets (1,2), clerics (1,2) and other stakeholders (1,2).

False and manipulative information about the aid allocated to Georgia by the West has been disseminated repeatedly over the years. Notably, this is not the first time that the position of government representatives on this issue coincided with the opinion of pro-Russian, anti-Western groups. Read more about this topic in the Myth Detector articles:

The article has been written in the framework of Facebook’s fact-checking program. You can read more about the restrictions that Facebook may impose based on this article via this link. You can find information about appealing or editing our assessment via this link.

Read detailed instructions for editing the article.
Read detailed appeal instructions.



Emzar Kvitsiani


Alliance of Patriots party



Last News

Welcome Back!

Login to your account below

Retrieve your password

Please enter your username or email address to reset your password.

Add New Playlist