Compliance with Ban on Contributions from Foreign Nationals

Federal law prohibits contributions and expenditures made “directly or indirectly” by foreign nationals “in connection with a federal, state, or local election.” 52 U.S.C. § 30121; 11 C.F.R. § 110.20. It is also unlawful to provide substantial assistance to help foreign nationals violate that ban, or to solicit, receive, or accept contributions from foreign nationals. 11 C.F.R. § 110.20(h). Violations of this prohibition may lead to fines or imprisonment. While companies are generally familiar with the prohibition, there are several issues which deserve particular attention.