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Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.
Chambers USA describes Mr. Parks as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to outside attorney for election law, campaign finance, pay-to-play and PAC issues.” Mr. Parks is also a leading lawyer in the emerging corporate political disclosure field, regularly advising corporations on these issues.
Mr. Parks' expertise includes the Federal Election Campaign Act, the Lobbying Disclosure Act, the Ethics in Government Act, the Foreign Agents Registration Act, and the Securities and Exchange Commission’s pay-to-play rules. He has also helped clients comply with the election and political laws of all 50 states. Mr. Parks also frequently leads political law due diligence for investment firms and corporations during mergers and acquisitions.
He routinely advises corporations and corporate executives on instituting political law compliance programs and conducts compliance training for senior corporate executives and lobbyists. He also has extensive experience conducting corporate internal investigations concerning campaign finance and lobbying law compliance and has defended his political law clients in investigations by the Federal Election Commission, the U.S. Department of Justice, Congressional committees, and in litigation.
Mr. Parks is also the founder and chair of the J. Reuben Clark Law Society’s Political and Election Law Section.
Mr. Parks also has extensive complex litigation experience, having litigated major environmental claims, class actions, and multi-district proceedings for financial institutions, corporations, and public entities.
From 2005 to 2006, Mr. Parks was a law clerk for Judge Thomas B. Griffith on the United States Court of Appeals for the District of Columbia.
Election and Political Law
- Represented Qualcomm in first-of-its-kind litigation brought by New York State Common Retirement Fund to compel production of internal books and records concerning political contributions. New York State Common Retirement Fund v. Qualcomm Incorporated (Del. Ch., 2013) (No. 8170-CS).
- Represented prominent political candidate in connection with high-profile “pay-to-play” investigation.
- Successfully defended nationally known television personality in investigation by the Federal Election Commission.
- Spearheaded political law compliance review for global natural resources company.
- Led internal lobbying disclosure compliance review for leading international financial services firm.
- Represented major manufacturer in Government Accountability Office audit of its compliance with the Lobbying Disclosure Act.
- Served as on-site First Amendment counsel for national political party convention.
- Represented the Republican National Committee in investigations by the House Judiciary Committee and House Committee on Oversight and Government Reform relating to the use of RNC email accounts by White House officials.
- Conducted internal investigation for the National Republican Congressional Committee concerning one of the largest ever embezzlements by a political committee treasurer.
- Prepared pharmaceutical company CEO for testimony before U.S. House committee panel.
Complex Litigation
- Represented leading financial institution in multiple consumer protection class actions, including a major multi-district class action, all of which were successfully settled.
- Represented a leading financial institution in antitrust class action brought against eight banks. The case was successfully settled as to Mr. Parks’ client.
- Won dismissal of fraud claims and favorably settled multi-million dollar arbitration for sellers of a United States software company.
Pro Bono
- Counsel of record in Supreme Court amicus brief on behalf of family members of soldiers named on the Peace Cross in American Legion v. American Humanist Association (No. 17-1717).
- Prepared Supreme Court amicus brief on behalf of 207 Members of Congress in Zubik v. Burwell (No. 14-1418).
- Prepared Supreme Court amicus brief on behalf of 88 Members of Congress in Sebelius v. Hobby Lobby Stores, Inc. (No. 13-354).
- Represented Lincoln Center for the Performing Arts as regulatory compliance counsel.
- Won unanimous reversal of Maryland resident’s firearms and controlled substance convictions. Carrero-Vasquez v. Maryland (Md. Spec. App. 2013) (No. 1443).
October 29, 2019, Inside Political Law
In a rare case, a so-called “dark money” group has now publicly released the names of its donors. Under federal law, if an organization has as its “major purpose” the nomination or election of federal candidates, the organization may be a “political committee” required to report its receipts and disbursements with the Federal Election Committee. ...… Continue ...
July 27, 2019, Covington Alert
In 1938, Congress enacted the Foreign Agents Registration Act ("FARA"), requiring "foreign agents" to register with the Attorney General. As amended over the years, it applies broadly to anyone who acts on behalf of a "foreign principal" to, among other things, influence U.S. policy or public opinion. Until recently, it was a backwater of American law—and a ...
June 20, 2019, Global Policy Watch
The U.S. Court of Appeals for the D.C. Circuit yesterday issued a long-awaited opinion upholding, on the merits, a recent update to the SEC’s pay-to-play rule. While the case involved only a narrow piece of the rule, the decision’s logic is worded more broadly and could apply to the SEC rule as a whole, making...… Continue Reading
June 19, 2019, Inside Political Law
The U.S. Court of Appeals for the D.C. Circuit yesterday issued a long-awaited opinion upholding, on the merits, a recent update to the SEC’s pay-to-play rule. While the case involved only a narrow piece of the rule, the decision’s logic is worded more broadly and could apply to the SEC rule as a whole, making...… Continue Reading The post In Major Blow To Its ...
June 19, 2019, Covington Alert
The U.S. Court of Appeals for the D.C. Circuit yesterday issued a long-awaited opinion upholding, on the merits, a recent update to the SEC's pay-to-play rule. While the case involved only a narrow piece of the rule, the decision's logic is worded more broadly and could apply to the SEC rule as a whole, making future challenges to the rule much more difficult, ...
April 9, 2019, Global Policy Watch
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, ...
April 8, 2019, Inside Political Law
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, ...
April 8, 2019, Covington Alert
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”).
March 11, 2019, Covington Alert
Covington issued several client alerts in recent years warning of a rising tide of enforcement of the once-obscure Foreign Agents Registration Act of 1938 (“FARA”). Signs of this trend emerged long before the recent, high-profile Special Counsel’s Office investigation.
March 4, 2019, Inside Political Law
During the diligence process that precedes a merger or acquisition, investment firms and corporations should pay careful attention to political law risks. Political laws are notoriously complex, are often not intuitive, and even seemingly minor or technical violations of these rules can result in significant penalties and reputational harm. These risks are ...
February 11, 2019, Covington Advisory
The Federal Election Commission has announced contribution limits for 2019-2020. The new “per election” limits are effective for the 2019-2020 election cycle (November 7, 2018 – November 3, 2020), and the calendar year limits are effective January 1, 2019.
October 15, 2018, Global Policy Watch
With less than one month to go before the 2018 elections, the ground is shifting for major political donors. Developments over the last several years, and especially in the last few months, show that the rules of the road are changing with respect to many of the common election law issues faced by high net...… Continue Reading
October 11, 2018, Inside Political Law
With less than one month to go before the 2018 elections, the ground is shifting for major political donors. Developments over the last several years, and especially in the last few months, show that the rules of the road are changing with respect to many of the common election law issues faced by high net...… Continue Reading The post Election Law Compliance ...
October 11, 2018, Covington Advisory
With less than one month to go before the 2018 elections, the ground is shifting for major political donors. Developments over the last several years, and especially in the last few months, show that the rules of the road are changing with respect to many of the common election law issues faced by high net worth individuals.
October 9, 2018, Covington Alert
As the midterm elections rapidly approach, contributions to nonprofits and other politically active organizations that support candidates and ballot initiatives will draw greater scrutiny from state and federal campaign finance regulators.
October 5, 2018, Inside Political Law
On September 18, the Supreme Court left in place the district court decision in CREW v. FEC, a case that dramatically increased the disclosure obligations for nonprofits and other entities that spend money on public communications that encourage people to vote for or against specific candidates. We previously described the anticipated effects of the CREW...… ...
August 15, 2018, Global Policy Watch
As the Foreign Agents Registration Act continues to receive national attention, an article in this quarter’s PLI Current journal describes the Justice Department’s increased focus on the statute. The article, authored by Covington’s Rob Kelner, Zack Parks, and Alex Langton, discusses the shifting FARA enforcement landscape, analyzes how the statute works, and ...
August 15, 2018, Inside Political Law
As the Foreign Agents Registration Act continues to receive national attention, an article in this quarter’s PLI Current journal describes the Justice Department’s increased focus on the statute. The article, authored by Covington’s Rob Kelner, Zack Parks, and Alex Langton, discusses the shifting FARA enforcement landscape, analyzes how the statute works, and ...
Summer 2018, PLI Current: The Journal of PLI Press
August 9, 2018, Inside Political Law
Companies doing business with state and local governments or operating in regulated industries are subject to a dizzying array of “pay-to-play” rules. These rules effectively prohibit company executives and employees (and in some cases, their family members) from making certain personal political contributions. Even inadvertent violations can be dangerous: a ...
August 6, 2018, Covington Alert
Companies doing business with state and local governments or operating in regulated industries are subject to a dizzying array of “pay-to-play” rules. These rules effectively prohibit company executives and employees (and in some cases, their family members) from making certain personal political contributions. Even inadvertent violations can be dangerous: A ...
July 18, 2018, Global Policy Watch
In a significant and unexpected development, the U.S. Treasury Department announced yesterday that certain nonprofits — including trade associations and 501(c)(4) social welfare organizations — would no longer be required to disclose the names and addresses of their donors on the annual “Form 990” they file with the Internal Revenue Service. Although the IRS ...
July 18, 2018, Inside Political Law
In a significant and unexpected development, the U.S. Treasury Department announced yesterday that certain nonprofits — including trade associations and 501(c)(4) social welfare organizations — would no longer be required to disclose the names and addresses of their donors on the annual “Form 990” they file with the Internal Revenue Service. Although the IRS ...
July 17, 2018, Covington Alert
In a significant and unexpected development, the U.S. Treasury Department announced yesterday that certain nonprofits — including trade associations and 501(c)(4) social welfare organizations — would no longer be required to disclose the names and addresses of their donors on the annual "Form 990" they file with the Internal Revenue Service.
New Tactic Emerges in Fight to Compel Companies to Disclose So-Called “Dark Money” Contributions
June 25, 2018, Inside Political Law
A new corporate political disclosure trend is coming. For years, those advocating increased corporate political disclosure have looked for ways to force companies to publicly reveal the names and amounts of corporate contributions to so-called “dark money” 501(c)(4) social welfare nonprofits and 501(c)(6) trade associations. To date, these initiatives have had, ...
New Tactic Emerges in Fight to Compel Companies to Disclose So-Called “Dark Money” Contributions
June 25, 2018, Covington Advisory
A new corporate political disclosure trend is coming. For years, those advocating increased corporate political disclosure have looked for ways to force companies to publicly reveal the names and amounts of corporate contributions to so-called “dark money” 501(c)(4) social welfare nonprofits and 501(c)(6) trade associations.
May 21, 2018, Covington Advisory
The scenario is all too common: After months of searching for the right candidate and weeks negotiating duties and compensation, a company finally hires a new employee to a position that will entail work on certain government policy issues. The employee seems to be a perfect fit, but after a few days on the job, someone asks whether “revolving door” rules ...
March 28, 2018, Covington Advisory
President Trump’s decision to impose tariffs on imported steel and aluminum has set off a “stampede” of lobbying, according to the New York Times.
March 16, 2018, Global Policy Watch
In recent months, Congress’s efforts to reform dramatically the Foreign Agents Registration Act (“FARA”) have picked up steam. As we explained in our recent FARA guide, FARA is a complex and broadly worded criminal statute that requires any “agent of a foreign principal” to register with the Department of Justice and file detailed public reports...… Continue ...
March 15, 2018, Covington Alert
In recent months, Congress’s efforts to reform dramatically the Foreign Agents Registration Act (“FARA”) have picked up steam.
Handling Investigations of Members of Congress and Congressional Staff
February 28, 2018, Covington Report
In the highly politicized world of investigations involving Members of Congress and congressional staff, taking the right steps in the first hours and days can mean the difference between a swift resolution and a years-long crisis.
January 12, 2018, Covington Alert
Buried in the 2018 National Defense Authorization Act (NDAA) is an obscure, and quite significant, change to the post-employment restriction on U.S. Department of Defense (DoD) civilian and uniformed personnel. This new provision could have a substantial impact on defense contractors and others who recruit DoD personnel to work on policy and procurement matters ...
November 29, 2017, Global Policy Watch
There is one very important political law provision to watch as the tax bill moves to a final vote in the Senate, and potentially a conference committee reconciles the House and Senate versions. This amendment will remove the ban on partisan political activities by charitable entities, churches, educational institutions and all other organizations exempt ...
November 28, 2017, Covington Alert
There is one very important political law provision to watch as the tax bill moves to a final vote in the Senate, and potentially a conference committee reconciles the House and Senate versions. This amendment will remove the ban on partisan political activities by charitable entities, churches, educational institutions, and all other organizations exempt from ...
November 7, 2017, Covington Alert
With the Foreign Agents Registration Act (“FARA”) in the news and public awareness of this formerly obscure statute at an all-time high, Senator Charles Grassley (R-Iowa), the influential chairman of the Senate Judiciary Committee, introduced legislation last week to revise the statute significantly, including reversing a decision Congress made in 1995 to remove ...
September 27, 2017, Global Policy Watch
For years, the Center for Political Accountability’s annual CPA-Zicklin Index of corporate political practices has touted marked year-over-year increases in corporate political disclosure practices. Look at the subtitles for its recent reports: How Leading Companies are Strengthening Their Political Spending Practices (2013), How Leading Companies are Making ...
September 22, 2017, Global Policy Watch
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 ...
September 21, 2017, Covington Alert
Perhaps no industry faces more scrutiny and regulation of its political activities than the financial 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. This primer describes three sometimes overlooked risk areas for investment firms: ...
September 14, 2017, Global Policy Watch
The universe of those covered by the SEC’s pay-to-play restrictions is expanding. If a newly proposed SEC rule is adopted as expected, pay-to-play restrictions will now extend to cover the recently created class of broker-dealers called Capital Acquisition Brokers (“CABs”). In this advisory, we discuss the background on the proposed rule and its implications ...
September 13, 2017, Covington Alert
The universe of those covered by the SEC’s pay-to-play restrictions is expanding. If a newly proposed SEC rule is adopted as expected, pay-to-play restrictions will now extend to cover the recently created class of broker-dealers called Capital Acquisition Brokers (“CABs”).
August 7, 2017, Covington Alert
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.
February 2, 2017, Covington Alert
The Federal Election Commission has announced contribution limits for the 2017-2018 election cycle. The new limits are effective January 1, 2017.
January 31, 2017, Covington Alert
President Donald Trump this weekend signed his promised “drain the swamp” Executive Order, which imposes ethics restrictions on incoming and outgoing Trump Administration appointees. Incoming appointees would, of course, do well to carefully review the provisions of the Executive Order. But companies that deal with the Administration—whether by lobbying the ...
January 10, 2017, Covington Alert
“Call the office asap!” Those may be the most feared words in the English language for Chiefs of Staff to Members of Congress. This primer covers what to do when that call reveals that a Member or staffer is under federal investigation.
November 23, 2016, Covington Alert
Corporations, trade associations, and others who interact with federal executive branch employees should be aware of the Office of Government Ethics’ (OGE) recent amendments to the executive branch gift rules, which go into effect on January 1, 2017. Seeking to encourage transparency and advance public confidence in the integrity of federal officials, OGE ...
November 17, 2016, Covington Alert
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 are costly, ...
November 15, 2016, Covington Alert
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 ...
November 10, 2016, Covington Alert
With the election over, the process of selecting and vetting individuals to fill the next administration’s key appointed positions is quickly shifting into high gear. For those who are called to serve in such positions, the decision to enter the process may be one of the most important and life-changing decisions they will make. Accordingly, it is critical for ...
August 30, 2016, Covington Alert
As election season enters full swing, with political candidates at all levels actively soliciting campaign donations from individuals and companies, it is an ideal time for all companies to review the policies and procedures in place for political donations. While the SEC’s pay-to-play rules governing registered investment advisers and their “covered associates” ...
August 25, 2016, Covington Advisory
This month, the Foreign Agents Registration Act (FARA), an obscure, almost 80-year old, statute has rocketed to national headlines. FARA, a sweeping federal criminal statute, requires certain individuals and companies acting on behalf of foreign principals to register with the Department of Justice and file regular detailed reports of their activities. As we ...
June 9, 2016, Covington Alert
On Friday, three Federal Election Commission (FEC) Commissioners provided a clear description of their understanding of the facts and law that led them to oppose opening an investigation into whether Murray Energy coerced its employees into making political contributions. Statement of Reasons of Chairman Petersen and Commissioners Hunter and Goodman, FEC MUR ...
May 23, 2016, Covington Alert
As we move toward the 2016 general election, campaign activity at the federal, state, and local levels continues to heat up. Super PACs again promise to play a prominent role in federal races, while at the same time impacting a wider range of non-federal races further down the ballot.
April 13, 2016, Covington Alert
Federal Election Commission (“FEC”) regulations permit a corporation to communicate with its “restricted” or “solicitable class” on any subject, including electoral advocacy and political fundraising. See 11 C.F.R. § 114.3(a). This includes solicitations of contributions to the corporation’s PAC. We frequently see questions arising about who falls within the ...
April 4, 2016, The Wall Street Journal
Zack Parks is quoted in this Wall Street Journal article regarding political spending and disclosure. According to Parks, "Companies need to think strategically about these issues.” He adds, “Companies that ignore disclosure initiatives have been the target of shareholder resolutions, bad press and lawsuits. But kitchen-sink disclosure isn't risk free.”
Covington Announces New Counsel
April 1, 2016
WASHINGTON, DC — Covington has promoted eight lawyers to of counsel and eight to special counsel, effective April 1, 2016. The new of counsel are as follows: Stefanie Doebler (Washington) focuses her practice on health care compliance matters for pharmaceutical and medical device clients. She provides advice related to advertising and promotion, fraud and abuse, ...
October 8, 2015, Covington Alert
March/April 2015, The Corporate Governance Advisor
January 30, 2015, The Harvard Law School Forum on Corporate Governance and Financial Regulation
August 18, 2014, LXBN TV
Covington's Zack Parks was interviewed by The Lexblog Network regarding the Obama Administration loosening its ban on having lobbyists sit on federal committees, boards and commissions.
August 13, 2014, Covington E-Alert
January 7, 2014, Covington Advisory
October 2013, The Banking Law Journal
August 15, 2013, The Hill's Congress Blog
Covington Announces Eight New Counsel
April 5, 2013
WASHINGTON, DC, April 4, 2013 — Covington & Burling is pleased to announce the promotion of one lawyer to of counsel and seven lawyers to special counsel, effective April 1, 2013. Muftiah McCartin, the new of counsel, is a member of the public policy and government affairs practice. Ms. McCartin’s distinguished public service career spans 34 years on Capitol ...
The Senate Permanent Subcommittee on Investigations Reportedly Plans Campaign Finance Investigation
April 4, 2013, Covington Advisory
January 3, 2013, Covington E-Alert
February 13, 2012, Covington E-Alert
February 6, 2012, Covington E-Alert
Clerk of the House and Secretary of the Senate Finally Go Live with HLOGA Semi-Annual Certification
July 1, 2008, Covington E-Alert
- Chambers USA, Government: Political Law (2015-2017)
- Washington DC Super Lawyers, Legislative & Governmental Affairs "Rising Star" (2014-2017)
Survey of the Pay-to-Play Laws of the United States
Available for purchase in its entirety or by region, Covington's 50-state survey can help in-house lawyers and compliance professionals make sense of the complex regulatory framework surrounding political contributions.
Practices
Education
Brigham Young University, J. Reuben Clark Law School, J.D., 2004
- magna cum laude
- Elected Order of the Coif
- Law Review, Lead Articles Editor
Brigham Young University, B.A., 2001
- magna cum laude