United States v. John Peter McGoff

BORK, Circuit Judge,

dissenting:

In 1986, the United States filed a criminal information in district court charging appellee McGoff with having been an agent of a foreign principal, the Republic of South Africa, without filing with the Attorney General the registration statement required by the Foreign Agents Registration Act. This case proceeds on the assumptions that McGoff was last an agent for South Africa in 1979, and that he' never registered as an agent under the Act. It is undisputed that the statute of limitations governing McGoff’s offense is five years, 18 U.S.C. § 3282 (1982), and that, if it has begun to run, the statute has not been tolled. Prior to trial, McGoff argued that the limitations period on his offense under the Act began to run in 1979, when he had last acted as agent, so that the 1986 information was time-barred. The United States argued that the statute of limitations would not begin to run until McGoff filed a registration statement covering his activities as agent. The district court agreed with McGoff and dismissed the information.

The plain, unambiguous language of the Act demonstrates that the district court erred: the statute of limitations for a criminal prosecution of an agent's failure to register under the Act does not begin to run until the agent registers. This unavoidable conclusion, perhaps odd at first blush, is upon reflection not only compelled by the statutory language but consistent with the declared purposes and legislative history of the Act. The majority, by misreading the clear language of the Act, significantly curtails the government’s ability to enforce the fundamental obligation the Act imposes on agents of foreign principals to disclose their connections and activities as agents.

I.

A.

The true issue in this case does not concern the statute of limitations. Rather, this case turns on the precise definition of the offense with which McGoff was charged. The Supreme Court's decision in Toussie v. United States, 397 U.S. 112, 90 S.Ct. 858, 25 L.Ed.2d 156 (1970), provides the framework for analysis. Toussie, who was convicted of failing to register for the military draft, argued on appeal that since his failure to register was complete when he was first required to register and did not do so, the five-year limitations period barred his prosecution eight years after that time for non-registration. Id. at 114, 90 S.Ct. at 860. The government conceded that Toussie had first rendered himself liable to prosecution eight years before, but argued that his offense continued until his *1097registration. Id. The Court summarized the issue: “If the offense is a continuing one the prosecution was timely, but, if not, the District Court erred in not dismissing the indictment.” Id.

The Court held that Toussie’s offense did not continue. It began by stating that , a court should find that an offense continues only if either “the explicit language of the substantive criminal statute compels such a conclusion, or the nature of the crime involved is such that Congress must assuredly have intended that it be treated as a continuing one.” 397 U.S. at 115, 90 S.Ct. at 860. The Court found that the draft statute, which required registration “at such time or times and place or places” as the President may prescribe, id. at 113, 90 S.Ct. at 859, contained no language “that clearly contemplate[d]” a continuing offense, and that a regulation under the Act referring to a continuing duty to register was insufficient, of itself, to establish a continuing offense. Id. at 120-21, 90 S.Ct. at 863. With only a “highly equivocal” implication that this “somewhat ambiguous” statute established a continuing offense, the Court ordered the prosecution dismissed as time-barred. Id. at 122-23, 90 S.Ct. at 864.1

The issue in this case is analogous to that in Toussie. Although here both sides concede that the failure to register under the Act is a continuing offense, they disagree over how long it continues. If the offense continues only so long as the agent continues his agency, prosecution of McGoff is time-barred. If the offense continues so long as the agent fails to register, prosecution of McGoff is timely. To answer the question of how long McGoff’s offense continues, I rely on Toussie’s criteria for deciding whether an offense continues at all. In the words of Toussie, I believe it evident that under the “explicit language” of the Foreign Agents Registration Act McGoff’s offense continues until he registers. To demonstrate this conclusion, I turn to the provisions of the Act.2

B.

Any person who subordinates himself to a foreign principal and in its behalf engages in certain enumerated activities, or anyone who agrees, or represents himself, to be such a person, is an “agent of a foreign principal” under the Act. 22 U.S.C. § 611(c) (1982). If not exempt, see id. §§ 611(d), 612(f), 613, every such agent is subject to the Act’s registration requirement. Id. § 612(a).

The terms of section 612(a) are decisive of this case. The section describes an agent’s registration requirement as follows:

No person shall act as an agent of a foreign principal unless he has filed with the Attorney General a true and complete registration statement ... as required by subsection[ ] (a) ... or unless he is exempt from registration____ Except as hereinafter provided, every person who becomes an agent of a foreign principal shall, within ten days thereafter, file with the Attorney General ... a registration statement____ The obligation of an agent of a foreign principal to file a registration statement shall, after the tenth day of his becoming such agent, continue from day to day, and termination of such status shall not relieve such agent from his obligation to file a registration statement for the period during which he was an agent of a foreign principal.

22 U.S.C. § 612(a) (1982).

I discuss the elements of the registration requirement in the order of their statutory presentation. The first sentence bars an *1098agent from acting as such without having filed a registration statement. The second sentence requires a person who becomes an agent to file a registration statement within ten days of assuming the status of agent. These two sentences are not redundant or contradictory of one another. See Frank v. United States, 262 F.2d 695, 696 (D.C.Cir.1958) (reversing on procedural grounds criminal conviction for failing to register as an agent under the Act and acting as agent without registration); United States v. Peace Information Center, 97 F.Supp. 255, 258 (D.D.C.1951). Read together, they provide that though one has ten days to file a registration statement after entering into a covered agency arrangement with a foreign principal, the agent may not act on that arrangement without already having filed. This two-fold statutory scheme dovetails with the Act’s purpose — the Act seeks disclosure of both relationships with foreign principals and the acts that arise from them. See Meese v. Keene, — U.S. -, 107 S.Ct. 1862, 1865, 95 L.Ed.2d 415 (1987).3

With these two duties laid out, we are now in a position to examine the third sentence of section 612(a). That sentence divides itself into two parts. In its first part, the statute says that the agent's obligation to file a registration statement upon becoming an agent does not cease at the end of the tenth day after he becomes an agent, but “continue[s] from day to day.” The reader now knows without doubt that an agent is not relieved of this obligation to file as soon as the ten-day period has ended. But the reader does not yet know when the agent is relieved of his duty to file. The exact wording of the second half of the third sentence, fairly read, unambiguously answers that question.

C.

I conclude the explication of section 612(a) by first summarizing what to this point the section has said — and not said. The first two sentences affirmatively state the agent’s two duties and when they begin. The statute next extends one of the two duties, the obligation to register upon becoming an agent, beyond the initial moment when registration is required. The statute is silent on when the duty not to act as an agent without having registered ends; given that silence, one might reasonably presume that just as the obligation begins when the agent begins to act as an agent, so also the obligation ends when the agent ceases acting as an agent.

One might similarly presume that the agent’s obligation to file, which begins ten days after he becomes an agent, also ends when the agent is no longer an agent. But section 612(a) is not silent on this point, and squarely rejects any such presumption. The second half of its third sentence says: “termination of such status [i.e., one’s status as agent of a foreign principal] shall not relieve such agent [i.e., an agent of a foreign principal] from his obligation to file a registration statement for the period during which he was an agent of a foreign principal.” 22 U.S.C. § 612(a) (1982). There can be no doubt about what this language means. The first phrase means that an agent who has relinquished his agency and who has not registered at any point before or after that time is still under an obligation to register. The next phrase describes the bounds of what the former *1099agent is to register — an account of his agency relationship and the acts he performed while an agent. The two phrases read together render a former agent in continuous violation of the Act until he discloses the required information. The language is simple, and it is clear.

It is helpful, though not necessary, to see how this result is required by the Act’s purpose. See Viereck v. United States, 139 F.2d 847, 849 (D.C.Cir.1944). The Act is not meant to penalize agents of foreign principals for being agents, or to deter persons from becoming agents, but simply to cause persons to disclose information about their agency to the public. Accordingly, there is no reason to expect the Act to hinge the disclosure obligation on the continuation of the agency. Cessation of agency does not eliminate the evil the Act seeks to remedy, which is the failure to disclose; only disclosure itself, i.e., registration, puts an end to that evil. Indeed, one might argue that, regardless of the statutory language, the “substantive evil Congress sought to prevent” is “renewed” by each day’s failure to register, Toussie, 397 U.S. at 122, 90 S.Ct. at 864, so that the nature of that failure “is such that Congress must assuredly have intended that it be treated as a continuing [offense].” Id. at 115, 90 S.Ct. at 860. See United States v. Bailey, 444 U.S. 394, 413-14, 100 S.Ct. 624, 636, 62 L.Ed.2d 575 (1980) (discussed infra Section I.D.).

Usually, no doubt, agents will obey the law and register when they are first required to do so. Usually, therefore, disclosure will occur while the agent is still an agent. But “usually” does not mean “always,” as this case illustrates. An agent who never registers but completes his agency with impunity still has not disclosed the information that the Act says the public needs. Congress has seen fit to hold the Act’s obligation over his head until he discloses that information. McGoff, under the facts before us in this case, is consequently at this moment under an obligation to register. Therefore, even apart from the Act’s express reference to the statute of limitations, which I discuss later, see infra Section I.D., the government’s prosecution of McGoff is unquestionably timely, since the limitations period for suit on a breach of a duty necessarily only begins to run when the duty ends, and McGoff’s duty to file has not ended. See Toussie, 397 U.S. at 114-15, 90 S.Ct. at 860; see also In re Corrugated Container Antitrust Litig., 662 F.2d 875, 886 (D.C.Cir.1981) (commencement of limitations period for conspiracy coincides with conspiracy’s end).

The majority of this panel, however, holds that the agent’s obligation to file under section 612(a) ceases when the agent ceases activities for his foreign principal. This holding is based on a strained reading of the Act. First, the language of the statute before us is not aimed at when the agent’s obligation not to act without registering ends, but rather when the agent’s obligation to file ends — that is the issue of statutory construction in this case. An agent who has acted for his principal in the past but has ended his activities and yet maintains his agency relationship, for example by contract, still maintains his agency “status” and must register under any reading of the Act. Indeed, even an agent who simply “holds himself out” as acting or having acted would seem obliged to register. See 22 U.S.C. § 611(c)(2) (1982).4

Second, the majority remarkably finds the second half of section 612(a)’s third sentence ambiguous. I quote the pertinent language again, adding its immediate sequel and emphasizing the words the majority believes generate ambiguity: “termi*1100nation of such status shall not relieve such agent from his obligation to file a registration statement for the period during which he was an agent of a foreign principal. The registration statement shall include the following____” 22 U.S.C. § 612(a) (1982) (emphasis added). In fact, all the majority’s ambiguity is generated not by the phrase but solely by its first word, “for.” I think it obvious that “for” means “covering,” and that the phrase modifies the term “registration statement,” indicating the dates that define the statement’s coverage. See Note, The Foreign Agents Registration Act: When is Registration Required?, 34 S.C.L.Rev. 687, 693-94 (1983) (summarizing section 612(a)’s obligation in this way). That is, the agent must file a registration statement providing the requested information regarding the time he was an agent, and need not provide information regarding times before or after his agency.

The majority concedes that this is the “more natural” reading of the Act’s language. I would add that this reading is so “natural” as to be a straightforward application of “one of the simplest canons of statutory construction,” the rule of the last antecedent, which provides that “qualifying phrases” are ordinarily “to be applied to the words or phrase immediately preceding and are not to be construed as extending to others more remote.” United States v. Pritchett, 470 F.2d 455, 459 & n. 9 (D.C.Cir. 1972). The majority nonetheless rejects this “normal reading of the language of the statute.” Id. It instead claims that this natural reading would render the phrase “surplusage” because a registration statement required by the Act “can, in logic, relate to no period other than ‘the period during which’ the individual acted as an agent.” Maj. op. at 1083. Even if this court were charged simply with “logical” rather than statutory interpretation, the majority’s position would be mistaken. There would be nothing illogical about requiring a person who becomes an agent of a foreign principal to disclose information about himself from either before or after the time he had become an agent. Public appraisal of the “statements and actions” of agents “in the light of their associations and activities,” which is the Act’s fundamental purpose, Keene, 107 S.Ct. at 1865, could quite logically comprise the appraisal of agents’ “statements and actions” in light of their past and present “associations and activities” both within and without the agency relationship. It might “logically” assist the public’s appraisal of the activity of the chief lobbyist for a foreign government, for example, to know that he was formerly the chief lobbyist for an American corporation that dealt extensively with that nation. Indeed, it would be “logical” for McGoff’s belated initial registration statement to disclose not only his activity as agent for South Africa but also his subsequent activity as, to put a hypothetical example, a member of the U.S. Civil Rights Commission. That surely might assist the public appraisal of all of McGoff’s actions and statements.

As a matter of “logic,” therefore, the Act’s registration statement could well require disclosure of information regarding the periods before or after the agency. There are also, of course, strong “logical” reasons why Congress would reject such a requirement, which would amount to the surveillance of the perfectly legal activities of now-ordinary Americans who were formerly agents. To indicate Congress’ rejection of this logical but unacceptable result, the language of section 612(a) expressly restricts the temporal reach of the registration statement to the period during which the agent was an agent. See Viereck v. United States, 318 U.S. 236, 243, 63 S.Ct. 561, 564, 87 L.Ed. 734 (1943) (holding, under later-amended language of 1938 version of section 612(b) of the Act, that six-month supplemental registration statement need cover only activities “as agent,” and not all activities in any capacity during the six months while an agent). It was necessary for Congress to address this point specifically here, since none of the items to be included in the registration statement, which the Act lists immediately after the third sentence of section 612(a), specifies a time period that relates to the period of agency, and most of the items could easily *1101encompass periods outside the period of agency. See 22 U.S.C. § 612(a)(l)-(ll) (1982). Thus, far from being mere “surplusage,” the phrase “for the period during which he was an agent of a foreign principal” provides a vital fact regarding the statement’s coverage to every agent who must register, and especially to the agent who registers, as the preceding clause of the same sentence expressly contemplates, after “termination of [his agency] status.”

The majority offers an alternative reading of the statute that is, to say the least, forced. The majority believes that the phrase beginning “for the period” modifies “obligation,” and would rewrite the statute as follows: termination of agency status shall not relieve the agent “from his obligation for the period during which he was an agent of a foreign principal to file a registration statement.” Under this reading, agents who wish to do their duty and register have no guidance from the statute, but only from the majority’s “logic,” on what time period their statements should cover. Moreover, by adopting this reading, it is the majority that renders the language of the Act “surplusage,” at best. According to that reading, the statute provides that termination of one’s agency does not relieve the agent of his duty to register while he was an agent. This says nothing. It would be bizarre to suppose that an agent’s duty to file a registration statement, which in the majority’s view is owed to the government only so long as he is an agent, might be somehow retroactively excused (absent the passage in question) immediately upon termination of the agency relationship. The majority apparently believes that it would be plausible to regard an obligation arising from and existing only during a relationship, as somehow being dissolved during the relationship by the relationship’s subsequent termination. I find this proposition odd, to say the least. No criminal statute works this way. Yet the only function this passage in the Act has under the majority’s reading is to dispel that proposition with the truism that even if the agent later ceases to be an agent, he remains liable while an agent to perform his duty as an agent. This is surplusage of a very high order.5

Perhaps the simplest, but most compelling, proof that the majority reads section 612(a) erroneously is this: removal of the word “not” from the statute would give the majority exactly the sense it wants. The statute then would say, “termination of [the agent’s] status shall relieve [the] agent from his obligation to file a registration statement for the period during which he was an agent of a foreign principal.” I am confident that the majority and I would agree that this language would end the agent’s duty with his agency. Unfortunately for the majority, this is the exact opposite of the statute Congress did write. It is obvious that the majority’s reading of the real statute is completely untenable.

As I have shown, section 612(a) clearly requires the conclusion that the agent’s obligation to register continues beyond the termination of his agency. The language is unambiguous, it comports with the section’s structure, and promotes the Act’s purpose. In contrast, the majority’s reading of the section leaves a gaping hole in the statute, blunts its purpose, and is, on its own terms, incoherent. McGoff today remains obliged under section 612(a) to file a registration statement as an agent of a foreign principal, and may be prosecuted for his failure to do so.

D.

Section 618 of the Act grants the government the power to enforce in various ways *1102all of the obligations imposed by the Act. 22 U.S.C. § 618 (1982 & Supp. Ill 1985). Section 618(a) imposes criminal penalties for violations of “any provision” of the Act. Id. § 618(a). It therefore renders liable for prosecution any person who breaches the obligations under section 612(a) discussed above by acting as an agent of a foreign principal without registering or by becoming such an agent but failing to register within ten days thereafter. As does section 612(a), however, section 618 singles out the failure to file a registration statement for additional attention. 22 U.S.C. § 618(e) (1982). Section 618(e) complements the discussion of the obligation to file in section 612(a) by establishing a correlative liability for breach of that obligation.6 Just as the obligation to file “continues from day to day,” id. § 612(a), so also liability for the breach of that obligation, i.e., the failure to file, “shall be considered a continuing offense.” Id. § 618(e). And just as the obligation to file does not end with the “termination of [one’s agent] status” but continues until he files, id. § 612(a), so also liability for the failure to file continues “for as long as such failure exists, notwithstanding any statute of limitation or other statute to the contrary.” Id. § 618(e). Since the statute of limitations limits not an obligation but the prosecution of its breach, it is unsurprising that the Act explicitly address the limitations period here rather than in section 612(a).7

By correlating a liability to the obligation to file, section 618(e) completes the work begun in section 612(a). But it also does more. Without section 618(e), and knowing that any violation of the Act’s provisions is subject to prosecution under 618(a), a court might be reluctant to find that the section 612(a) duty to register continues until the agent registers. The court would base its reluctance on the tension between the continuation of offenses and the policy of repose expressed through statutes of limitation. See Toussie, 397 U.S. at 114-15, 90 S.Ct. at 860. In my view, as previously discussed, the explicit language of section 612(a) overcomes this reluctance, as Toussie permits. See 397 U.S. at 115, 90 S.Ct. at 860. But, in addition, section 618(e) completely dispels the tension discussed in Toussie, and hence eliminates the sole basis for any legitimate reluctance about the proper result in this case. United States v. Bailey, 444 U.S. 394, 100 S.Ct. 624, 62 L.Ed.2d 575 (1980), makes this plain. In Bailey, the Court construed a statute criminalizing escape from federal custody, 18 U.S.C. § 751(a) (1982), as establishing a continuing offense that ends only when the escapee turns himself in, so that “an escapee can be held liable for failure to return to custody as well as for his initial departure.” 444 U.S. at 413, 100 S.Ct. at 636. The Court acknowledged that there should *1103be “restraint” in finding continuing offenses, due to the tension set out in Toussie between statutes of limitation and continuing offenses. Id. at 413-14, 100 S.Ct. at 636. But the Court found that tension “wholly absent” from the case before it because another federal statute, 18 U.S.C. § 3290 (1982), suspended the statute of limitations as long as the escapee remained at large. 444 U.S. at 414 & n. 10,100 S.Ct. at 636 & n. 10.

The parallel between this case and Bailey dictates the result here. In each case, there is a continuing offense of omission— failure to turn oneself in, failure to register oneself — that ends only with the end of the proscribed omission. In each case, there is a separate express statutory provision that suspends the operation of the statute of limitations for that offense of omission. In Bailey, the statutory suspension of the limitations period enabled the Supreme Court to find without hesitation that the offense did indeed continue until the omission was remedied. In this case, the express language of section 618(e) should equally dispel any hesitation over finding liability for the failure to file under the Act to continue until one has filed.8

E.

To sum up, the explicit language of sections 612(a) and 618(e) of the Act have established an obligation and a corresponding liability on every agent of a foreign principal to file a registration statement or be subject to legal liability. The duty to file, and the offense by omission of failing to file, only cease when the agent files. I close my discussion of the statutory language and structure by noting that the issue in this case, and the majority’s mistaken disposition of that issue, reach beyond the Act’s provision for criminal prosecutions. Criminal prosecutions under the Act have been rare. See Attorney General v. Irish People, Inc., 684 F.2d 928, 945 (D.C.Cir.1982). But the civil injunctive remedy available to the United States for “any acts ... [in] violation of[,] ... or [any failure] to comply with[,] any of the provisions of [the Act],” 22 U.S.C. § 618(f) (Supp.III 1985), also now will be unavailable to compel anyone to file a registration statement once his agency has ended. If the obligation to file ends with the termination of the agency relationship, then regardless of what the statute of limitations may be, the United States will be unable to use an injunction to compel registration, since the agent is no longer under any obligation to register. The disclosure the Act seeks to compel is consequently hindered even more than it might seem at first glance. This result reinforces my conviction that the majority’s holding is mistaken.9

II.

The legislative history of the Act strongly, although not conclusively, supports the government’s position in this case. Together with the statutory language, the legislative history makes it undeniable that McGoff remains under an obligation to register as a foreign agent, and that the government’s prosecution of him is, therefore, timely.

*1104Since the majority has rehearsed in detail the legislative materials pertinent to this case, and since I find the language of the statute decisive in any event, I will only highlight those parts of the legislative history I find most important.

A.

Legislation containing the language of section 618(e), which made the failure to register a “continuing offense,” was introduced on January 18, 1949. 95 Cong.Rec. 440-41 (1949). This bill did not purport to modify section 612(a). See 95 Cong.Rec. at 441. Thus the bill, of itself, simply relied on the then-existing section 612(a), which had no language of continuing obligation, see supra note 3, for the view that the agent had a continuing obligation to file after the expiration of the ten-day window; the bill made explicit only the continuing liability to prosecution of such a person. See 95 Cong.Rec. at 442 (letter from Attorney General Clark). By forgoing any explicit language of obligation, Congress apparently thought that the continuing character and ultimate end-point of the obligation to file would be decided by the courts, with reference to the nature of the obligation itself and to the bill’s express language ultimately embodied in section 618(e). See Bailey, 444 U.S. at 413-14,100 S.Ct. at 636 (finding escape a continuing offense for these reasons); see also Toussie, 397 U.S. at 122, 90 S.Ct. at 864 (finding nothing inherent in draft registration to render it continuing). •

But Congress decided to state explicitly how long the obligation to file under section 612(a) continued. Consequently, separate legislation was introduced, initially in the House, to amend section 612(a). See 95 Cong.Rec. 5207 (1949) (introduction of H.R. 4386). The bill was approved by the Judiciary Committee of each House, with accompanying reports, each of which incorporated a letter from Assistant to the Attorney General Peyton Ford.10 H.R.Rep. No. 1775, 81st Cong., 2d Sess. (1950); S.Rep. No. 1900, 81st Cong., 2d Sess. (1950).

The Reports, tracking the explanation in the Justice Department’s letter, stated that the bill changed section 612(a) to dispel doubt on two points: First, did the limitations period for prosecution of registration violations begin when the agent first was obliged to register or on the last day on which the unregistered agent had acted? H.R.Rep. No. 1775, supra, at 1; S.Rep. No. 1900, supra, at 1. Second, what was the liability of an agent to file a registration statement for the period during which he was acting as an agent if he had since ceased this activity? Id.

While the first doubt might seem to be the one relevant to this case, this case is, as I said earlier, not really about the statute of limitations but rather about the extent of the obligation to register. The second doubt about section 612(a) that the bill addressed, which goes beyond the first doubt, is the one responsive to McGoff’s situation: Given that McGoff is no longer an agent, what is McGoff’s liability, i.e., his obligation to file a registration statement for the period during which he was an agent? Both committee reports refer on this point to “several instances” in which “an unregistered agent has resisted registration on the ground that his agency had terminated prior to the time when the Department [of Justice] was demanding his registration.” H.R.Rep. No. 1775, supra, at 2; accord S.Rep. No. 1900, supra, at 1-2, U.S.Code Cong.Serv. 1950, p. 2887. The Congressmen wanted to “remove all doubt as to the *1105registrability of these [persons],” for which the Justice Department was “considering the evidence as to prosecution.” H.R.Rep. No. 1775, supra, at 2. This discussion seems almost to have been written with McGoff in mind.

I find it most reasonable, then, to read these committee reports, and the Justice Department letter that prompted them, as answering two connected questions, or “doubts,” about an agent’s obligation to register under section 612(a). First, does the agent’s obligation continue beyond the end of the ten-day window throughout his agency? Second, does the agent’s obligation continue beyond the end of his agency? As asked, the questions are distinct, and therefore asked separately, but since the answer to each is “yes,” the second answer subsumes the first.

The majority reads the second of these questions as relating to an “affirmative defense” (a term nowhere used in the committee reports) by the former agent that the end of his agency ended his obligation to file. Maj. op. at 1087,1088,1089. While the reports are certainly by no means clear, so that the majority’s reading is not obviously mistaken, upon analysis I can see no reasonable basis to sustain this reading. I assume that the majority is referring to a prosecution against a former agent brought by the government within five years after he ended his agency. Such a prosecution could proceed in two ways. First, it could charge the agent simply with having failed to register while he was an agent. But as I have indicated earlier, it is not tenable to maintain that a later cessation of agency could relieve the agent of the duty to file he owed the government while previously an agent; an amendment to the Act was not needed to make that point clear. Moreover, references in the reports to the government's “demanding,” and the former agent’s “resisting,” registration after he ceased to be an agent, H.R.Rep. No. 1775, supra, at 2; S.Rep. No. 1900, supra, at 1-2, show clearly that Congress was here contemplating a prosecution on an agent’s obligation that continued after the end of his agency. That is the second way the prosecution of a former agent could proceed: the agent could be charged with the failure, after he was an agent as well as during that period, to register as required by law. That is how McGoff is being prosecuted, and that is the prosecution Congress intended by its amendments to authorize. But if the obligation to register continues after agency ends, a former agent not only has no “affirmative defense” to such a prosecution, but, since to invoke the statute of limitations itself is an “affirmative defense,” e.g., United States v. Wild, 551 F.2d 418, 421-22 (D.C.Cir.1977), a fortiori the statute has not yet even begun to run on the agent’s breach of this still-continuing obligation.9

B.

There is additional legislative history that supports the government’s position in this case. The McCarran-Hanson correspondence directly addressed the question of whether it was good policy “in effect [to] abolish[ ] all statutes of limitations” for the failure to register under the Act. 95 Cong.Rec. 9749 (1949) (letter from Elisha Hanson); see id. at 9750 (in response, rejection by Sen. McCarran of limitation on prosecuting this omission offense to “some named period of time”); 96 Cong.Rec. 12,-069 (1950) (same). The Senate Report on the Internal Security Act of 1950 described the amendment to section 618(e) in that Act as meant “to provide that failure to register under the [Foreign Agents Registration A]ct shall be considered a continuing offense, thus removing it from the statute of limitations.” S.Rep. No. 2369, 81st Cong., 2d Sess. 9-10 (1950). It concluded *1106that the amendment would “permit the prosecution of an offender at any time during the period he continues to disregard the statute and not merely within a 3-year period from” when “he first became subject to the law and should have registered but failed to do so.” Id. at 10.

I must briefly comment on the majority’s reading of this legislative history. The majority fails to take seriously the McCarranHanson correspondence. It dismisses it as an individual legislator’s, albeit sponsor’s, comment, maj. op. at 1092, which does of course lessen its persuasiveness. But the majority then says that the correspondence cannot mean what it says, for the “remarkable result” that meaning would necessitate “would be more clearly manifested [in the legislative history] than in an oblique reference.” Id. at 1092. In other words, Congress failed to write its reports and conduct its debates on what it meant with all the attention the court thinks such a “remarkable result” required; therefore Congress did not mean what it said. This view might be justifiable when there is no statement by a Member of Congress anywhere in the legislative history that supports a given reading of an unclear statute, see Kelly v. Robinson, — U.S.-, 107 S.Ct. 353, 361-62 & n. 13, 93 L.Ed.2d 216 (1986), but that is hardly the situation here. The majority’s conclusion is “especially true,” it continues, because Congress later said, in the reports on the amending of section 612(a), that the limitations period begins when agency ends. Id. But, as I have discussed, those reports by no means show what the majority thinks they show.

The majority simply has overlooked the Senate Report, which it neither cites nor quotes on this point. The content of Senator McCarran’s individual statement, which anticipated the Report by stating that the failure-to-file offense was “remove[d] ... from the statute of limitations,” compare 96 Cong.Rec. 12,068 (1950) with S.Rep. No. 2369, supra, at 10, is thus not “the statement of a single legislator that ... accomplishes] a more drastic result” than the statute or the rest of its history supports. Maj. op. at 1092.12

I do not mean to suggest by my discussion of the legislative history of the Act that the history, standing alone, is conclusive one way or the other. But I think it harmonizes with the language of the statute, and contains more support for the government’s position than the majority indicates.13

III.

Since I find that McGoff's prosecution is authorized under the Act, I must address the question of whether the constitutional objections McGoff raises bar his prosecution. They do not.

*1107McGoff argues that a continuation of his obligation to file until he does file is a violation of due process. His rationale for this position, otherwise obscure, cites Justice Jackson’s famous concurrence in Krulewitch v. United States, 336 U.S. 440, 457, 69 S.Ct. 716, 725, 93 L.Ed. 790 (1949), which questioned the constitutionality of continuing the conspiracy offense as long as its concealment, which is merely collateral to the offense, continued. In the Act before this court, of course, concealment of information by the agent is itself the offense from the beginning. I think it sufficient to state that in Bailey the Court was wholly untroubled by any constitutional problem with continuing the offense of flight from justice for as long as the fugitive remained at large. See 444 U.S. at 412-14, 100 S.Ct. at 635-37. Correspondingly, it is clear that Congress has plenary authority to establish, or abolish, statutes of limitation for federal offenses. See United States v. Marion, 404 U.S. 307, 322-24, 92 S.Ct. 455, 464-65, 30 L.Ed.2d 468 (1971) (distinguishing between “legislative assessments” of presumptive prejudice embodied in statutes of limitation and due process clause’s protection against actual prejudice from pre-indictment delay); United States v. Levine, 658 F.2d 113, 126-27 (3d Cir.1981) (distinguishing statutory right to limitations period from constitutional rights); United States v. Ganaposki, 72 F.Supp. 982, 983-84 (M.D.Pa.1947). Nothing in the continuation of McGoff’s obligation to file until he does file offends the due process clause.

McGoff also urges that hinging the end of his obligation to file in his filing results in unconstitutional self-incrimination by putting him to a choice between admitting facts in the registration statement that would reveal his past failure to register or being prosecuted if he continues not to register. This argument, although of slightly more weight than his due process claim, also lacks merit.

First, McGoff’s registration would not have resulted in any incrimination whatsoever if he had registered within ten days after becoming an agent, as the Act permits. “One able to make a timely registration with noncriminal consequences but failing to make any registration at any time is hardly in a position to challenge the constitutionality of the [Act].” United States v. Melekh, 193 F.Supp. 586, 592 (N.D.Ill.1961); see United States v. Toussie, 410 F.2d 1156, 1159 (2d Cir.1969) (distinguishing other cases as involving the claim that disclosure at any time would be incriminatory), rev’d on other grounds, 397 U.S. 112, 90 S.Ct. 858, 25 L.Ed.2d 156 (1970).

Second, McGoff is in the same position now that he was in, even under his reading of the Act, for the five years after he ceased to be an agent, and indeed at any time after he failed initially to register. That is to say, McGoff’s self-incrimination argument would apply to any continuing offense of any duration whatever, and addresses nothing peculiar to the Act. But however characterized, the argument is patently erroneous. McGoff failed to register when he was initially required to do so. He then became liable for his failure. His liability today remains precisely the same. Consequently, McGoff’s “inaction did not give rise to the threat of punishment beyond that he had already risked,” and the continued obligation to register and suspension of the statute of limitations “attaches to merely continuing to exist at all, having once committed the crime.” Toussie, 410 F.2d at 1160. The “unpleasant consequence here of [McGoff’s] doing nothing” is not compulsory incrimination under the Constitution. Id.; accord Toussie, 397 U.S. at 134, 90 S.Ct. at 870 (White, J., dissenting); United States v. Martin, 733 F.2d 1309, 1311 (8th Cir.1984) (en banc).14

IV.

This case presents a clear example of how a court can, with the best of intentions, step out of its proper role as interpreter of the legislature’s intent and into the role of reviser of that intent. The majority makes it evident throughout its opinion that it finds the Act “Draconian” if *1108understood, as it must be, to end the obligation to file only with the agent's filing. I doubt that the continuation of the obligation to register is quite so outrageous as the majority believes. If the Act were ambiguous, however, the rule of lenity might well nonetheless bestow legal relevance on the majority’s finding. But although not easy to construe, the Act is not ambiguous, not even arguably, and whether it would have been Draco’s choice or not, the Act is Congress’ choice, to be enforced as written. Because the Act’s language, structure, purpose, and legislative history all support the conclusion that prosecution of McGoff is timely, and because the majority has significantly narrowed the scope of the agent's obligation to register, which is the cornerstone of the Act,

I respectfully dissent.

. The Court also found that there was "nothing inherent” in the offense itself to render it continuing, because, unlike conspiracy (a concededly continuing offense), the failure to register each day did not "bring a renewed threat of the substantive evil Congress sought to prevent.” 397 U.S. at 122, 90 S.Ct. at 864.

. The language, structure, purpose and legislative history of the Act, all pointing to this conclusion, distinguish this case from Toussie, where those factors, at best ambiguous, prompted the Court to find that the offense of failing to register for the draft did not continue at all. Here, of course, everyone agrees that McGoff s obligation continues to some degree, but the parties disagree about when it ends.

. The Act in its original 1938 version (known as the McCormack Act), ch. 327, 52 Stat. 631 (1938), provided only that every person who "shall ... become an agent of a foreign principal shall forthwith file” a registration statement. Id. § 2, 52 Stat. at 632. The distinct prohibition of acting as an agent without filing was added in 1942. Ch. 263, § 1, 56 Stat. 248, 251 (1942). The House Report on this amendment explained that the change "eliminates any doubt that may exist as to more than one possible venue of action under the present statute. Prosecution will now be possible in any district wherein an agent of a foreign principal acts without having [registered].” H.R.Rep. No. 1547, 77th Cong., 1st Sess. 3 (1941). As the Report notes, the addition of the prohibition on acting without filing "effected] only a theoretical enlargement of the existing statute,” since "proof of violation" of either prohibition "is practically identical." Id. Indeed, the grant of ten days in which to file after becoming an agent, also added by the 1942 amendment, works a contraction of the statute, which formerly had required filing "forthwith.”

. These situations seem to represent the “certain ambiguities" regarding the ending of the obligation to file that were addressed by the 1966 amendments to the Act. H.R.Rep. No. 1470, 89th Cong., 2d Sess. 8 (1966); see Pub.L. No. 89-486, § 2(1), 80 Stat. 244, 245 (1966). Before that amendment, the Act had stated that the "discontinuance of [an agent’s] activity” as such did not relieve him of the obligation to file "for the period during which he acted within the United States" as an agent. Ch. 524, § 1, 64 Stat. 399, 400 (1950). By referring only to the discontinuance of "activity,” the statute might have exempted those agents not currently acting who nonetheless maintain the status of agent. The 1966 amendment, by basing the end point of the obligation to file on one's status as agent, eliminated this possible interpretation.

. The majority points out that under its reading, an agent who failed to register could be prosecuted at any time up to five years after termination of the agency relationship. I do not doubt that. But this does not "vindicate[ ] the express purpose articulated by the Department of Justice," as the majority claims. Maj. op. at 1089 n. 27. The reports indicate, see infra pp. 1104-05, that the Justice Department had experienced instances in which an ex-agent had resisted registration, not prosecution, on the ground that his agency had terminated. One of the express purposes articulated by the Department of Justice was thus to insure the registrability of ex-agents. The majority’s interpretation extinguishes the agent’s obligation to register upon termination of agency and is thus directly contrary to an express purpose of the legislation.

. The majority understands the government to argue that "section 618(e), standing alone, creates an offense that continues until actual registration regardless of the duration of the section 612(a) obligation.” Maj. op. at 1079. While the structure and rhetoric of the government's briefing and argument gave less than full attention to § 612(a), I do not believe the government suggests that § 612(a) is irrelevant. Rather, the government acknowledges that one must in reading § 618(e) “refer to the obligation that is provided by’ § 612, Reply Brief for Appellant at 5-6, but insufficiently explains the precise meaning of that obligation.

. Nothing in the Act addresses the limitations period for prosecution of one who acts without registering in violation of § 612(a), or for prosecution of any other violation of the Act’s provisions. This also is unsurprising, for the Act designates none of those violations as continuing offenses, and they presumably are uncontroversially governed by the five-year catch-all statute of limitations.

I note at this point that the majority, mistakenly following McGoffs brief. Brief for Appellee at 35-36, thinks that failure to file under § 612(a) of the Act also gives rise to “prosecution and stiff criminal penalties," maj. op. at 1093, under 18 U.S.C. § 951 (Supp. Ill 1985). The provision at issue, stemming from 1917 and wholly independent of the Act, penalizes one who “acts in the United States as an agent of a foreign government without prior notification to the Attorney General.” Id. Nothing in the statute suggests that its purpose is public disclosure or that the offense it creates is continuing. It seems obvious that the usual five-year limitation period would begin to run for this offense as soon as the agency ceases acting as such. But in any event, the statute is simply irrelevant to this case. See United States v. Melekh, 193 F.Supp. 586, 591 (N.D.Ill.1961).

. The majority also rejects this view of the Act because it would “virtually eliminate" the limitations period for the failure to file, and then says that "on the one occasion Congress actually intended to eliminate a statute of limitations, it did so explicitly" as to capital crimes. Maj. op. at 1093. But to "virtually eliminate” is not to "eliminate." Section 618(e)’s “virtual” elimination is no different from that in 18 U.S.C. § 3290 (1982), for example, which the Bailey Court relied on without hesitation — in each instance, the statute’s running is not eliminated but merely suspended until the offender rectifies his omission. And the majority's emphasis on the relative triviality (to it) of the malum prohibitum involved in violating a disclosure statute, maj. op. at 1093-94, is surely equally implicated by a statute that suspends the limitations period for anyone “fleeing from justice,” 18 U.S.C. § 3290 (1982), whether felon or misdemeanant, and however trivial his offense.

. The majority passes too easily over this point. The majority correctly indicates that civil enforcement mechanisms were added to offer a fly swat for cases in which that would be a more appropriate weapon than a howitzer. The majority then argues that the disarming of the fly swat is no cause for concern since the government can always use the howitzer.

. Ford’s letter provided in pertinent part:

In its present form, section 2 of the act provides for registration with the Attorney General of all persons acting as agents for foreign principals. However, as the section presently reads there is room for doubt as to whether the statute of limitations against prosecution of an agent for failure to comply with the registration provisions of the act commences to run from the date on which he was first required to register or from the last day on which such unregistered agent has acted. Doubt has also arisen as to the liability of an agent to file a registration statement for the period during which he was acting as an agent of a foreign principal if he has since ceased such activity. This Department has encountered several instances of an unregistered agent’s resisting registration on the ground that his agency had terminated prior to the time when the Department was demanding his registration. Clarification of the intendment of the section on these questions is considered desirable.

H.R.Rep. No. 1775, 81st Cong., 2d Sess. 3 (1950).

. The Senate Report says that the amendment to § 618(e) in the internal security bill, S. 595, pending simultaneously with H.R. 4386’s amendment of § 612(a), "duplicate[d H.R. 4386] in part.” S.Rep. No. 1900, 81st Cong., 2d Sess. 2 (1950). I believe this indicates a duplication insofar as the continuing obligation of § 612(a), together with the Act’s general enforcement provision in § 618(a), would necessarily imply that a violation of that obligation is a continuing offense absent § 618(e). Otherwise Congress could not have believed it possible to resolve a doubt about the statute of limitations for the Act’s enforcement without amendment of § 618, the Act’s enforcement provision. What is not duplicated by § 618(e) is § 612(a)’s express extension of the agent’s obligation to file beyond his tenure as an agent.

. That the Report and McCarran’s statement both err "as a matter of law” by suggesting that continuing offenses generally are removed from the statute of limitations, maj. op. at 1092, is hair-splitting. The point of course is that this continuing offense of omission is removed from the statute's operation so long as the omission continues.

. 1 briefly dispose of the other reasons the majority gives for its reading of the Act. It finds the idea "passing strange" that an agent may be indefinitely prosecutable for an offense of relatively little gravity. Maj. op. at 1094. As I have already indicated, there is nothing "strange,” illogical, or the like about this idea.

The majority is also troubled by the fact that deficient filings, not just omitted filings, might subject the agent to liability. Yet seriously deficient filings might well be important enough to justify prosecution — that is a decision for the executive branch to make. And the executive has other tools at his disposal to handle deficient filings of lesser seriousness. See 22 U.S.C. § 618(f), (g) (1982 & Supp. Ill 1985).

The fact that McGoff raises constitutional arguments does not prevent a proper reading of the statute. At least some of those arguments, if not all of them, hardly qualify as “not insubstantial,” see infra Section III, as they must be to play a role in the reading of statutes. See Commodity Futures Trading Comm'n v. Schor, — U.S.-, 106 S.Ct. 3245, 3252, 92 L.Ed.2d 675 (1986). And in any event, the presence of such constitutional questions does not permit a judicial rewrite of the statute. If the statute as written is unconstitutional, we may not save it by transforming it into something different from what Congress enacted. See id.

Finally, I do not think that the rule of lenity comes into play here. The rule cannot override common sense, statutory purpose, or the fair meaning — the the narrowest meaning — of statutory language. United States v. Turkette, 452 U.S. 576, 588 n. 10, 101 S.Ct. 2524, 2531 n. 10, 69 L.Ed.2d 246 (1981). The rule is irrelevant absent statutory ambiguity, see, e.g., Bifulco v. United States, 447 U.S. 381, 387, 100 S.Ct. 2247, *11072252, 65 L.Ed.2d 205 (1980), and there is no ambiguity in this case.

. McGoff claims that the Act as applied to him somehow violates the first amendment. He says that the continued threat of prosecution *1108due to his continued failure to register "chills" his activities as writer and publisher because he must "worry about being second-guessed on the motivations for his publications and writings literally for the rest of his life." Brief for Appellee at 43-44. This claim is frivolous. Any "chill” on McGoffs present activities due to the possibility that he might be prosecuted for his failure to disclose his past activities as an agent is no different from that of any person who commits a crime and who also happens to be a publisher and writer. It has no first amendment significance.