Just think of the recent Russia-Georgia outreach not just in the US but in the UK and elsewhere around the world. A firm based in the US, given the global nature of media, could well be doing outreach overseas on behalf of all sorts of foreign entities, with media articles making their way back to US readers via the omnipresent Internet, for example.
"Voluntary" means many firms are naturally likely to limit the information they provide on their Brussels work, for competitive or other reasons. For the foreseeable future, the public's understanding what work PR firms are doing on behalf of foreign governments will remain very patchy.
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