Muhammad Zulfikar Rakhmat - Yeta Purnama
Muhammad Zulfikar Rakhmat and Yeta Purnama argue that researchers and policymakers working on foreign influence should pay closer attention to how their own concepts travel once they leave the seminar room.
Researchers who study foreign influence campaigns have a well known problem. When a local journalist, activist, or politician repeats a message that also appears in Russian or Chinese state media, it is tempting to conclude that this person must be secretly working for a foreign government. Sometimes that is true. But often it is not. People can agree with a foreign government’s message for their own reasons, without taking orders from anyone.
This is a genuine puzzle for people who study information manipulation. But it has stopped being only an academic puzzle. In a growing number of countries, from Georgia to Indonesia, this same shortcut, treating foreign-sounding views as proof of foreign control, has been written directly into law or proposed as one. And it is being used, or could soon be used, to jail journalists, shut down charities, and silence critics of the government.
Georgia is the clearest recent case. In August, its law on Transparency of Foreign Influence came into force, requiring any media outlet or civil society group that receives more than a fifth of its funding from abroad to register as an organisation serving foreign interests. Journalist federations warned the law could be used to brand ordinary reporters as agents of a foreign power simply because part of their funding came from outside Georgia.
Georgia is not alone. El Salvador passed its own Foreign Agents Law in 2025, and Kyrgyzstan passed a Foreign Representatives Law in 2024. Both were closely modeled on a law Russia passed back in 2012, one that has since been used to brand independent newspapers, election monitors, and human rights groups as instruments of foreign powers, forcing many of them to close.
In Uganda, a bill working through parliament in 2026, the Protection of Sovereignty Bill, would let a government minister decide who counts as an “agent of foreigners.” Journalists who report critically on the economy, foreign policy, or elections could face up to twenty years in prison. India has also tightened its own foreign funding rules this year, making it harder for civil society groups to receive money from abroad at all.
Indonesia shows how this can start even before a law is passed. In June 2025, President Prabowo Subianto accused foreign powers of funnelling money to local NGOs to stir up unrest. A draft bill has since circulated that would criminalise the spreading of what it calls “foreign propaganda” and would let the government restrict “foreign capital” to guard against so-called foreign agents. Analysts have warned that many Indonesian civil society groups depend on exactly this kind of overseas funding to pay staff and keep running, and that a vaguely worded bill like this could be used against them regardless of what the money was actually spent on.
These laws do not look like censorship at first glance. They are usually written in the calm language of financial disclosure and national security, not the language of political persecution. A group simply has to register, or report where its funding comes from. That is what makes them so effective. They do not need to arrest anyone to work. Once a law like this exists, journalists quietly avoid sensitive stories, charities scale back their work, and citizens become wary of accepting any support connected to the outside world. The damage happens before a single prosecution.
This is where the debate among researchers and the reality on the ground meet, and where the stakes become much higher than an argument over definitions. When experts studying foreign influence blur the line between a person who agrees with a foreign narrative and a person who is controlled by a foreign government, that blurring is a flaw in an analysis. When a government writes the same blurred logic into a law, it becomes a tool for punishing anyone whose funding, travel, or opinions happen to cross a border.
The argument that local voices deserve scrutiny is not wrong on its own. Foreign governments really do fund media outlets, train commentators, and quietly shape narratives abroad, and that deserves serious attention. But the difference between exposing a hidden funding relationship and criminalising an ordinary one matters enormously. A journalist who receives a grant from a foreign foundation to cover elections is doing journalism. A government-run television channel secretly paying an anchor to repeat state talking points is doing something else entirely. Foreign agent laws, as currently written in most of these countries, rarely bother to tell the two apart.
This is not only a problem for authoritarian states. Once a law like this exists on the books anywhere, including in long established democracies, it becomes a template other governments can borrow. Officials facing criticism at home now have a ready made playbook: point to a critic’s foreign funding, however small or well documented, and use it to question their loyalty rather than answer their argument.
There is a way to take foreign interference seriously without handing governments a tool to silence their own citizens. It starts with insisting on real evidence rather than resemblance. A payment record, a set of instructions, or a documented chain of coordination is evidence of foreign control. A shared opinion, a foreign grant used for its stated purpose, or an inconvenient question about government policy is not. Laws that fail to make this distinction are not tools against foreign manipulation. They are tools against dissent that happen to borrow its language.
Researchers and policymakers working on foreign influence should pay closer attention to how their own concepts travel once they leave the seminar room. An idea built to protect open societies from outside manipulation can, with only a small shift in wording, become a legal weapon against the very journalists and civic groups that keep those societies open. The people writing the next generation of these laws are already watching how the argument is made. It would help if those making the argument watched just as closely.
*Dr Muhammad Zulfikar Rakhmat is a co-author, serves as Director of the China-Indonesia Desk at CELIOS, and is also affiliated with positions at the Middle East Institute at the National University of Singapore, the London School of Economics’ IDEAS, and Busan University of Foreign Studies.
**Yeta Purnama is a researcher at Center of Economic and Law Studies (CELIOS), whose work focuses on the evolving dynamics of China–Indonesia relations.
