Firewalls and foreign-agent laws in China, Russia and beyond

Series: How minds are moved · Censorship, enforced and invisible · 5 of 7

In November 2023 a court in St Petersburg sentenced an artist, Alexandra Skochilenko, to seven years in prison. Her crime: replacing five supermarket price tags with small notes about Russian strikes on Ukraine. She was convicted under a law passed in March 2022 that punishes “knowingly false information” about the armed forces with up to 15 years. “Knowingly false” in practice meant anything that contradicted the Defence Ministry.

That is censorship in its oldest form: a law, a court and a cell. This post covers the two big tools that still work that way, national firewalls and “fake news” laws, and a third that is spreading fast in Europe, the foreign-agent law. Documented cases only, and the arguments their defenders make.

Contents · 10 sections

TL;DR #

• China’s Great Firewall blocks Google, Facebook, X, YouTube and every language edition of Wikipedia. Research shows it targets collective action more than criticism, and works mainly through friction and distraction.
• Russia’s March 2022 law made contradicting the army a crime. OVD-Info counted more than 1,288 people prosecuted for anti-war speech or actions by 1 November 2025.
• Foreign-agent laws spread from Russia (2012) to Georgia (2024 and 2025), Hungary (2023; parliament voted to abolish its office in 2026) and a softened version in Slovakia (2025).
• Defenders cite the US FARA (1938), Australia’s 2018 scheme and the UK’s 2025 scheme. The difference that matters is the trigger: acting at a foreign principal’s direction, or simply receiving foreign money.

China: the firewall that mostly does not need to arrest #

China’s system, built from the late 1990s under the “Golden Shield” project, blocks foreign platforms outright. Facebook and Twitter went dark in July 2009 after riots in Urumqi. Wikipedia has been blocked in all languages since April 2019. Unapproved VPNs have been illegal since 2017.

Two pieces of research show how it actually works. In 2013 Gary King, Jennifer Pan and Margaret Roberts of Harvard published a study of millions of Chinese social media posts in the American Political Science Review. They found that posts criticising the government or local officials were often left up. Posts that could lead to people gathering, even in support of the government, were removed. The censors were not hunting criticism; they were hunting crowds.

In 2017 the same authors used leaked emails from a county propaganda office to estimate that the government fabricates about 448 million social media comments a year. The comments rarely argue. They cheer, change the subject and fill the feed. Margaret Roberts later summed up the method as fear, friction and flooding: punish a few, make the rest inconvenient, and drown what remains.

The few still get punished. Zhang Zhan, a former lawyer who filmed in Wuhan in early 2020, was sentenced to four years in December 2020 for “picking quarrels and provoking trouble”. She was released in May 2024, detained again that August, and on 19 September 2025 sentenced to another four years on the same charge. The UN human rights office and the EU’s diplomatic service called for her release.

Russia: from blocks to sentences #

Russia blocked Facebook and Instagram in March 2022 and labelled Meta “extremist”. The bigger change was criminal. Article 207.3 of the criminal code, adopted on 4 March 2022, punishes spreading “knowingly false information” about the armed forces. A companion article punishes “discrediting” them.

Documented cases include:

• Alexei Gorinov, a Moscow municipal councillor, sentenced in July 2022 to seven years for calling the war a war at a council meeting.
• Ilya Yashin, an opposition politician, sentenced in December 2022 to eight and a half years for a YouTube stream about the killings in Bucha.
• Vladimir Kara-Murza, sentenced in April 2023 to 25 years, partly under this article and partly for treason.
• Alexandra Skochilenko, the price tags, seven years.

Yashin, Kara-Murza and Skochilenko were freed in the US-Russia prisoner exchange of 1 August 2024. Gorinov was not. By one count based on OVD-Info’s court data, Russian courts had heard 337 cases under Article 207.3 by 1 January 2026.

Russia’s foreign-agent law dates from 2012. It began with NGOs that received foreign money and did “political activity”, and was extended to media, individuals and, since 2022, to anyone deemed “under foreign influence”, with no foreign money required. Labelled people must put a long disclaimer on everything they publish.

Laws modelled on them: Georgia, Hungary, Slovakia #

Georgia #

In May 2024 Georgia’s parliament passed a law requiring organisations that receive more than 20% of their funding from abroad to register as “pursuing the interests of a foreign power”. Tens of thousands protested. The president vetoed it; parliament overrode the veto on 28 May 2024. In April 2025 the governing party went further, adopting a near-copy of the US Foreign Agents Registration Act, in force from 31 May 2025, with up to five years in prison for failing to register. Under the 2024 law, according to Human Rights Watch, 385 of 3,987 active non-commercial organisations had registered as serving a foreign power by 1 January 2026; the registry under the 2025 FARA copy listed 12 agents. The government says it is simply copying American law.

Hungary #

Hungary’s 2017 law on foreign-funded NGOs was struck down by the EU Court of Justice in 2020. In December 2023 parliament passed a Sovereignty Protection Act and created a Sovereignty Protection Office, which began work in 2024, with broad powers to investigate organisations and journalists and no judicial review of its reports. The European Commission took Hungary to the EU Court. On 12 February 2026 Advocate General Juliane Kokott advised that the law breached EU law. Then politics overtook the courts: after the April 2026 election, the new government under Péter Magyar promised to scrap the office, and on 30 June 2026 parliament voted 135 to 44 to abolish it.

Slovakia #

Slovakia’s governing coalition proposed in 2024 that NGOs with foreign funding be labelled “organisations with foreign support”, modelled on Hungary. After protests and warnings from the European Commission, the version adopted in 2025 dropped that label, though it kept new reporting duties that civil-society groups still criticise.

The defenders’ argument #

Supporters of these laws make a real point: democracies do require foreign influence to be disclosed. The US has had FARA since 1938, and it has teeth. Enforcement rose sharply after 2017; the US required the company producing RT America and Chinese state media outlets to register; and wilful failure to register carries up to five years in prison, the same maximum as Georgia’s copy. Australia created a Foreign Influence Transparency Scheme in 2018. The UK’s Foreign Influence Registration Scheme started on 1 July 2025. The European Commission itself proposed in December 2023 a directive requiring disclosure of lobbying for non-EU governments, which some NGOs called an “EU foreign agents law”.

Critics answer that the difference is the trigger. FARA covers anyone acting at the “order, request, direction or control” of a foreign principal, which can be a government, a party, a company or an individual, and the UK scheme works on a similar basis. Receiving a foreign grant is not enough on its own. Georgia’s 2024 law and Hungary’s office used funding or vague “foreign influence” as the test, and paired it with stigmatising labels. Readers can compare the texts; they are public.

What it feels like from the inside #

Under a firewall, most people never feel censored. They use the domestic apps, and the blocked world simply is not there. Under a “fake news” law, the feeling is the opposite: everyone knows the rule, nobody knows where the line is, so they stay far from it. Under a foreign-agent label, the feeling is isolation. Donors back off, partners stop answering, and every article you publish carries a sign that says “do not trust me”.

What these tools can and cannot do #

They can make speech expensive, which is enough for most people. They cannot make it impossible: VPN use in Russia surged after the 2022 blocks, and Chinese users route around the firewall daily. They also cannot buy belief. Research on Chinese fabricated posts suggests they work by distraction, not persuasion.

How to notice it #

• Watch the trigger words. “Knowingly false”, “discrediting”, “foreign influence” and “interests of a foreign power” are elastic terms. Ask who defines them.
• Check the test. A transparency law asks “are you acting at a foreign principal’s direction?”. A stigma law asks “did you get foreign money?”.
• Look for judicial review. If an office can investigate and publish findings with no court able to check it, that is a warning sign.
• Count the cases. OVD-Info, Human Rights Watch and court databases publish numbers. Laws that are never used and laws with hundreds of convictions are different things.
• Apply the same test at home. If you would object to the law in Tbilisi, read your own country’s version with the same eyes.

Frequently asked questions #

Is Georgia’s law really a copy of the US FARA? #

The 2025 law closely copies FARA’s text. Critics say the context differs: it came on top of the 2024 law, which used a 20% funding test rather than foreign direction, and alongside other new limits on foreign grants that Human Rights Watch has criticised.

Is the Great Firewall effective? #

At scale, yes. Most Chinese users use domestic platforms. But determined users get around it, and research suggests its main power is making foreign information inconvenient, not unreachable.

Can these laws be reversed? #

Yes. Hungary’s parliament voted to abolish its office in 2026 after a change of government, and its 2017 NGO law was struck down by the EU Court.

Do democracies prosecute speech too? #

Yes, under laws on incitement, terrorism, hate speech and official secrets, and those cases are debated elsewhere in this series. The difference to look for is in the definitions, the size of the sentences and whether an independent court can say no.

The lesson #

The firewall, the “fake news” article and the foreign-agent label work by making speech costly, not impossible. Most people adjust before anyone knocks on their door. The record also shows these tools are not permanent: a court can strike them down, and an election can abolish them. Whether a law is transparency or stigma is in its text, and the text is public.