President Donald Trump did not fulfill his pledge to ban foreign lobbyists from raising money for American elections.

As a 2016 presidential candidate, Trump said that on his first day in office, his administration would seek to "clean up the corruption and special interest collusion in Washington, D.C." One way to achieve that would be a complete ban on foreign lobbyists raising money for American elections, his 100-day action plan said.

The promise came after a chain of Clinton campaign emails were hacked and released online in October 2016. Some emails showed campaign aides debating whether to accept donations from U.S. citizens who are registered foreign lobbyists. Ultimately, they agreed that the campaign would take the money and deal with possible public criticism.

Trump in his first week in office issued an executive order prohibiting executive branch appointees from lobbying for five years after their service. But that executive order did not include a ban on foreign lobbyists raising money for U.S. elections.

In December 2017, watchdog groups that advocate for government transparency told PolitiFact they had seen no action from Trump to advance his pledge. We asked again three years later. The answer was the same: no movement on that promise.

"Trump has made no effort at all to ban fundraising by lobbyists who represent foreign interests. No such restriction was included in Trump's ethics executive order — which is largely unenforced, anyway — and no such effort was offered in the form of legislation," said Craig Holman, Public Citizen's Capitol Hill lobbyist on ethics, lobbying and campaign finance rules.

It is already illegal for foreign nationals to donate in American elections. But U.S. citizens can lobby on behalf of a foreign entity (foreign governments, political parties, corporations, individuals, and nongovernmental organizations). They must disclose their relationships and financial activity under the Foreign Agents Registration Act.

The Daily Beast in October reported that lobbyists representing foreign governments had bundled nearly $2 million for Trump's re-election campaign. An analysis by the Center for Responsive Politics said that political donations made by foreign agents acting on behalf of Saudi Arabian interests exceeded $1.6 million in the 2018 election cycle.

Trump pledged to place a lifetime ban on foreign lobbyists raising money for American elections. No efforts were made to satisfy this pledge.

We rate this a Promise Broken.

President Donald Trump still hasn't delivered on a campaign promise he said would be addressed within his first 100 days in office: a complete ban on foreign lobbyists raising money for American elections.

Trump outlined that promise in his 100-day action plan to" Make America Great Again," claiming it would "clean up the corruption and special interest collusion in Washington, D.C."

But there's no sign Trump has moved on this pledge in the 11 months he has been in the White House.

Trump issued an executive order on Jan. 28, a few days into his presidency, prohibiting executive branch appointees from lobbying for five years after their service, partially addressing a separate campaign promise. But that had no effect on foreign lobbyists raising money for U.S. elections.

The Sunlight Foundation, an organization that advocates for open government, told PolitiFact it also had seen no action from the Trump White House on this promise. Project on Government Oversight, a nonpartisan watchdog group, also told PolitiFact it was unaware of any push to extend provisions in the January order to others.

To prevent foreign money flowing into American elections would also require closing up certain legal loopholes allowing people to donate through shell companies and political nonprofits, the Sunlight Foundation's executive director John Wonderlich previously told us.

Pending action from the Trump administration, this promise rates Stalled.

Among President Donald Trump's six-point plan to change the way politicians raise money was a pledge to prevent foreign lobbyists from raising money in United States elections, which he said he would accomplish in his first 100 days in office.

The promise came after a chain of Clinton campaign emails were hacked and released online in October 2016. Some emails showed campaign aides debating whether to accept donations from U.S. citizens who are registered foreign lobbyists. Ultimately, they agreed that the campaign would take the money and deal with possible public criticism.

Days later, Trump vowed at a campaign rally in Green Bay, Wisc.: "I'm going to ask Congress to pass a campaign finance reform that prevents registered foreign lobbyists from raising money in American elections and politics."

It is already illegal for foreign nationals to donate in American elections, but U.S. citizens can lobby on behalf of a foreign entity. Under the Foreign Agents Registration Act (FARA), lobbyists representing foreign interests must disclose their relationship to the foreign governments as well as disclose any financial activity.

Whether FARA is actually enforced is an entirely different matter. A 2016 Department of Justice audit found that prosecutions and enforcement of the act are rare. From 1966 to 2015, the department only brought seven criminal cases relating to FARA. In a notable recent case, Trump's former campaign manager, Paul Manafort, retroactively registered as a foreign agent after news reports linked him to lobbying done on behalf of a Ukrainian governing party.

Because FARA enforcement is sparse, it's tough to get a true sense of how many lobbyists raising funds for campaigns or political causes are lobbying on behalf of foreign interests, according to Lydia Dennett, an investigator with the Project on Government Oversight. A simple ban on foreign lobbyist fundraising would likely make the campaign funding process less transparent.

"This kind of lifetime ban sounds good on its surface, but it could deter people from registering" as a foreign agent, Dennett said.

If Trump really wants to limit foreign money going toward elections, it would also mean closing up certain legal loopholes that allow people to donate in elections through shell companies and political nonprofits, said John Wonderlich, the executive director of the Sunlight Foundation, an organization that advocates for open government. Portions of the Citizens United Supreme Court case would have to be overturned and enforcement of lobbying laws would need to increase.

In a Jan. 28 executive order, Trump partially met other government ethics promises. The order prohibited White House Administration officials from lobbying for five years after their service, which was another goal in his six-point plan. No action on the promise to ban foreign lobbyist fundraising has been taken so far.

Until we see some movement on this, we'll continue to leave it unrated.