I think they are...
The law in question is the domestic dissemination prohibition of the Information and Educational Exchange Act of 1948 (Public Law 402), the Smith-Mundt Act. It bans the broacaster from spreading propaganda aimed at US citizens. However, in the last few weeks, op-eds by Radio Free Europe/Radio Liberty executives, clearly designed to propagandize American readers, have appeared in both the Washington Post--RFE/RL chief Jeffrey Gedmin's column headlined "Reporting Among Gangsters"--and the New York Times--Daniel Kimmage's op-ed "Fight Terror With YouTube" (no, not an Onion parody).
It's not that the articles are misguided, dishonest, and misleading--it is that their publication violates both the spirit and the letter of the Smith-Mundt Act. Radio Free Europe and Radio Liberty should not be propagandizing readers of the Washington Post and New York Times.
Except as provided in section 1461 of this title and this section, no funds authorized to be appropriated to the United States Information Agency shall be used to influence public opinion in the United States....