Lobbying and Campaign Finance Internal Investigations

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After a series of high profile scandals involving lobbyists, gifts to government officials and campaign finance violations, many corporations have expanded the focus of their compliance programs to include government relations risk. When problems are detected, Covington frequently is engaged to conduct internal investigations aimed at understanding what happened, why it happened, and what step the company needs to take to remediate any political law violations.

Increasingly, corporations proactively engage our Election & Political Law group to conduct audits or reviews of their Washington offices and their overall government affairs compliance.

The typical politically active corporation faces a variety of potential compliance risks in the political law area. Examples include:

Illegal reimbursement of campaign contributions through the corporate expense reimbursement process.
Illegal bundling or “facilitation” of campaign contributions by corporate employees and lobbyists.
Failure to register lobbyists.
Failure to accurately quantify and report lobbying activity.
Violation of corporate policies or laws governing gifts to public officials.
Mishandling of PAC funds.

We understand that investigations of this kind are necessarily extraordinarily sensitive in nature. Our lawyers are able to marshal not only the investigative skills and professional discretion necessary to learn the facts but also the specialized knowledge of the election and lobbying laws needed to spot and understand the issues.

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Congress Amends LDA Forms to Require Reporting of Lobbyist Convictions

The recent passage of the Justice Against Corruption on K Street Act of 2018 (“JACK Act” or the “Act”) imposes new requirements on those registering and filing reports under the Lobbying Disclosure Act (“LDA”). The Act amends the LDA to require that LDA registrants disclose listed lobbyists’ convictions for criminal offenses involving bribery, extortion, ...

Foreign Lobbying Overhauls Stall as Manafort Trials Approach

Robert Kelner is quoted in Roll Call regarding legislation to overhaul the Foreign Agents Registration Act. Mr. Kelner says, “They [lawmakers] are all are focused on ‘toughening’ the statute, which is a political approach, but not an approach that will make it more effective. FARA has been in need of a major overhaul for decades. It’s an extremely vague statute, ...

Fight Against Sexual Misconduct Bringing Regulations, Protections for Lobbyists

As sexual abuse, assault, harassment, and other misconduct have dominated national headlines, state capitols and lobbyists have not escaped scrutiny. Amidst a spate of allegations and member resignations, some state legislatures and ethics commissions are taking action. While a variety of measures are being considered, including tightening gift rules, it is ...

The Top Three Political Law Risks for Hedge Funds, Private Equity Funds, and Investment Firms

Perhaps no industry faces more scrutiny and regulation of its political activities than the financial services industry. Even though these rules are often not intuitive, failure to comply with them can result in big penalties, loss of business, and debilitating reputational consequences. In this advisory, we describe three sometimes overlooked political law ...

Avoiding State and Local Lobbying Compliance Violations

Corporate legal and compliance departments are usually well aware of the laws regulating lobbying the federal government. Recent news reports, however, indicate that companies have more trouble with state and local lobbying laws. A few features of state and local lobbying make it a tricky blind spot. This increases the risk of failing to properly...… Continue ...

Virginia Makes Key Adjustments to Law Governing Gifts to Officials, Adds New Lobbyist Gift Notification

Organizations represented by lobbyists in Virginia should be aware of a new law enacted today. The law eliminates a controversial exception to the state’s $100 limit on lobbyist gifts to legislators and officials, adds a key new exception to that law, and also includes an additional gift notification requirement for lobbyists. The changes represent ...

2016 GAO Annual Lobbying Disclosure Act Compliance Report Issued

On Friday, the Government Accountability Office (“GAO”) released its tenth annual report on compliance with and enforcement of the federal Lobbying Disclosure Act (“LDA”). The report summarizes the results of GAO’s random audits of lobbyists’ quarterly LD-2 activity reports and semi-annual LD-203 contribution reports, and provides a snapshot of the current ...

New Executive Order on Ethics in Missouri Includes Lobbyist Gift Ban, Revolving-Door Provision; Legislature Considering Additional Restrictions

Earlier this month, newly-installed Missouri Gov. Eric Greitens issued Executive Order 2, applying strict ethics rules to executive branch employees in that state. The order includes a ban on gifts from lobbyists, conflicts of interest rules, and a “revolving door” provision that prohibits employees who leave Greitens’ office from later lobbying his ...

The 2017 Presidential Inauguration: Ethics and Compliance Issues

With Election Day 2016 in the books, the political world turns to the transition of power and the January 20, 2017 Inauguration of President-elect Donald Trump and Vice President-elect Mike Pence. With the swearing in of the new President and Vice President will come the traditional balls, parties, and receptions. The inauguration and related events...… Continue ...

Guidelines for Interacting with President-Elect Trump’s Transition Team

Over the next nine weeks, the Trump Presidential Transition team will formulate policy and staffing recommendations for the new administration. This alert gives a broad overview of the Transition and the laws that regulate interactions with Transition team members on issues related to appointments and policy recommendations. Persons interested in this topic may ...

House Clerk’s Office Apparently Sends Out Late Lobbyist Report Notices In Error

Earlier this afternoon, the House Clerk’s Office sent out emails to a number of registered federal lobbyists and lobbyist organizations alerting them to a missing 2016 Mid-Year LD-203 contribution report (due on August 1, 2016). It appears that this email was sent in error to a batch of registrants who properly filed their reports on...… Continue Reading The ...