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Is AIPAC a foreign agent (are they required to register with the US government as such)?

De facto, yes. There is substantial evidence that AIPAC and the broader Israel lobby coordinates closely with a foreign government.

However, due to their enormous influence, they have avoided de jure registering as such.

By your logic, the Romanian dark horse can't possibly be a Russian op because they never officially registered as a Russian agent.

I was very careful in my wording: someone who is required to register by law may choose to not do so.