Zachary G. Parks

March 2021

As the legal, regulatory, and commercial implications of coronavirus COVID-19 continue to evolve, our lawyers and advisors are helping clients navigate the complex considerations that companies around the world are facing and develop plans and strategies in response. Reach out to our COVID-19 task force at COVID19@cov.com. Below is a compendium of resources ...

March 18, 2021, Covington Alert

Even corporations with careful political law compliance practices can be caught off guard when they learn that an employee is running for public office. The corporation may have a good understanding of what the corporation's obligations and restrictions are in the political arena, but not fully know how to handle the compliance issues stemming from an employee's ...

March 17, 2021, Covington Alert

With a growing chorus of support across the progressive landscape, the For the People Act of 2021 has emerged as a key legislative priority for congressional Democrats in the 117th Congress. Envisioned as a “transformational anti-corruption and clean elections reform package,” the bill would enact sweeping changes to federal election laws along with important ...

March 10, 2021, Covington Alert

With a growing chorus of support across the progressive landscape, the For the People Act of 2021 has emerged as a key legislative priority for congressional Democrats in the 117th Congress. Envisioned as a “transformational anti-corruption and clean elections reform package,” the bill would enact sweeping changes to federal election laws along with important ...

March 8, 2021, Covington Alert

With a growing chorus of support across the progressive landscape, the For the People Act of 2021 has emerged as a key legislative priority for congressional Democrats in the 117th Congress. Envisioned as a “transformational anti-corruption and clean elections reform package,” the bill would enact sweeping changes to federal election laws along with important ...

March 5, 2021, Covington Alert Series

With a growing chorus of support across the progressive landscape, the For the People Act of 2021 has emerged as a key legislative priority for congressional Democrats in the 117th Congress. Envisioned as a "transformational anti-corruption and clean elections reform package," the bill would enact sweeping changes to federal election laws along with important ...

March 5, 2021, Covington Alert

With a growing chorus of support across the progressive landscape, the For the People Act of 2021 has emerged as a key legislative priority for congressional Democrats in the 117th Congress. Envisioned as a “transformational anti-corruption and clean elections reform package,” the bill would enact sweeping changes to federal election laws along with important ...

February 8, 2021

WASHINGTON—Covington is advising Veritas Capital on the acquisition of Cubic by Veritas and Evergreen Coast Capital for $2.8 billion. The transaction is expected to close during the second quarter of 2021. Cubic is a technology-driven provider of integrated solutions that increase situational understanding for transportation, defense C4ISR, and training ...

January 27, 2021

WASHINGTON—Covington is advising Veritas Capital on the acquisition of Perspecta Inc. by Veritas portfolio company Peraton for $7.1 billion. The transaction is expected to close in the first half of 2021. Following closing, Perspecta will be combined with Peraton, a trusted provider of highly differentiated space, intelligence, cyber, defense, homeland security ...

January 22, 2021, Global Policy Watch

The ethics rules that apply to Presidential appointees shifted Wednesday, in some ways significantly, as President Biden, just hours after being sworn in, signed an “Executive Order on Ethics Commitments by Executive Branch Personnel” and President Trump, just hours before his term expired, revoked his Executive Order on Ethics. While the Biden and Trump ...

January 22, 2021, Inside Political Law

The ethics rules that apply to Presidential appointees shifted Wednesday, in some ways significantly, as President Biden, just hours after being sworn in, signed an “Executive Order on Ethics Commitments by Executive Branch Personnel” and President Trump, just hours before his term expired, revoked his Executive Order on Ethics. While the Biden and Trump ...

January 22, 2021, Covington Alert

The ethics rules that apply to Presidential appointees shifted Wednesday, in some ways significantly, as President Biden, just hours after being sworn in, signed an “Executive Order on Ethics Commitments by Executive Branch Personnel” and President Trump, just hours before his term expired, revoked his Executive Order on Ethics. This alert summarizes the key ...

December 8, 2020

WASHINGTON—Covington is assisting Veritas Capital and its portfolio company Peraton with their pending acquisition of the federal IT and mission support services business of Northrop Grumman for $3.4 billion. The transaction is expected to close in the first half of 2021. Peraton is a trusted provider of highly differentiated space, intelligence, cyber, defense, ...

November 16, 2020

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 ever make. Accordingly, it is critical for ...

November 11, 2020, Global Policy Watch

With control of the U.S. Senate at stake, hundreds of millions of dollars are expected to flow into Georgia over the next two months as voters decide the outcome of two U.S. Senate run-off elections.  Donors seeking to make contributions to support their preferred candidates in these run-offs should be mindful of a variety of...… Continue Reading

November 11, 2020, Inside Political Law

With control of the U.S. Senate at stake, hundreds of millions of dollars are expected to flow into Georgia over the next two months as voters decide the outcome of two U.S. Senate run-off elections.  Donors seeking to make contributions to support their preferred candidates in these run-offs should be mindful of a variety of...… Continue Reading The post ...

November 9, 2020, Covington Alert

With the election over, attention now turns to the transition and the upcoming inauguration of the new Biden-Harris Administration. In this alert, which will be of interest to chief compliance officers and many others across the country, Covington’s Election and Political Law Practice Group provides insight into what promises to be a transition and inauguration ...

November 5, 2020, Global Policy Watch

As both presidential and down-ticket candidates gear up for post-election recounts and related litigation in several states, they and their political parties will be raising new funds to finance these efforts. As with campaign contributions made before the election, there are a variety of rules that apply to contributions to support post-election disputes. The ...

November 5, 2020, Inside Political Law

As both presidential and down-ticket candidates gear up for post-election recounts and related litigation in several states, they and their political parties will be raising new funds to finance these efforts. As with campaign contributions made before the election, there are a variety of rules that apply to contributions to support post-election disputes. The ...

November 5, 2020, Covington Alert

As both presidential and down-ticket candidates gear up for post-election recounts and related litigation in several states, they and their political parties will be raising new funds to finance these efforts. As with campaign contributions made before the election, there are a variety of rules that apply to contributions to support post-election disputes. The ...

November 5, 2020, Politico

Robert Kelner, Zachary Parks, and Brendan Parets’ article, “Guidance Regarding Contributions to Recount and Election Dispute Funds,” was quoted in Politico.

September 24, 2020, Covington Alert

In the midst of the COVID-19 pandemic, voting in the 2020 general election is likely to look different than we have seen in recent times. Election officials across the country are working through in-person voting and vote-by-mail procedures and individual voters are deciding how best to cast their ballots. At the same time, many corporations are recognizing this ...

July 27, 2020, Covington Alert

On 21 July 2020, the UK Intelligence and Security Committee (the “Committee”) published a long-awaited report regarding evidence of Russian threats against the United Kingdom. In addition to setting out the nature and extent of what the Committee considered to be hostile activities on the part of operatives with ties to Russia, the report addressed the powers ...

Updated July 2019, Covington Guide

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 ...

May 12, 2020, Covington Alert

So-called "pay-to-play" rules can be a source of substantial anxiety for companies and investment firms doing business with state or local governments. Due to these pay-to-play rules, the personal political contributions of company executives, directors, employees, and even family members of employees can cause their investment firm employers to lose millions of ...

May 1, 2020, Global Policy Watch

As the impact of the COVID-19 pandemic spreads through every industry, companies that previously steered clear of Washington, D.C. may find themselves contacting the federal government for assistance. From communicating with Members of Congress about potential provisions of the CARES Act to requesting new forms of assistance from federal agencies that oversee ...

May 1, 2020, Inside Political Law

As the impact of the COVID-19 pandemic spreads through every industry, companies that previously steered clear of Washington, D.C. may find themselves contacting the federal government for assistance. From communicating with Members of Congress about potential provisions of the CARES Act to requesting new forms of assistance from federal agencies that oversee ...

April 30, 2020, Covington Alert

As the impact of the COVID-19 pandemic spreads through every industry, companies that previously steered clear of Washington, D.C. may find themselves contacting the federal government for assistance. From communicating with Members of Congress about potential provisions of the CARES Act to requesting new forms of assistance from federal agencies that oversee ...

April 8, 2020, Inside Political Law

The 2020 annual report from the Government Accountability Office (“GAO”) provides new details regarding the state of Lobbying Disclosure Act (“LDA”) compliance and enforcement.  By statute, the GAO is charged with conducting random audits of LDA compliance and submitting reports reflecting the results to Congress.  This year’s audit reviewed approximately 100 ...

March 24, 2020, Inside Political Law

The consequences of the COVID-19 pandemic are reverberating in every sector of the global economy, from life sciences to transportation, retail to manufacturing, financial services to sports and entertainment. As federal, state, and local governments attempt to blunt the pandemic’s public health and economic effects, many companies are frantically working with ...

March 24, 2020, Covington Alert

The consequences of the COVID-19 pandemic are reverberating in every sector of the global economy, from life sciences to transportation, retail to manufacturing, financial services to sports and entertainment. As federal, state, and local governments attempt to blunt the pandemic’s public health and economic effects, many companies are frantically working with ...

March 10, 2020

WASHINGTON—Covington is assisting Veritas Capital with its acquisition of DXC Technology’s U.S. State and Local Health and Human Services business in a deal valued at $5 billion. The transaction is expected to close no later than December 2020, subject to the satisfaction of customary closing conditions. DXC Technology’s U.S. State and Local Health and Human ...

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 ...

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 22, 2019, Law360

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, 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.

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 ...

Summer 2018, PLI Current: The Journal of PLI Press

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 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.

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.

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 ...

December 18, 2017, Compliance Week

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 ...

October 5, 2017, Law360

September 27, 2017, Law360

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 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 15, 2016, The Hill

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, Law360

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.”

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

February 5, 2015, Law360

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

July 31, 2014, Law360

April 2, 2014, Covington E-Alert

February 6, 2014, Covington E-Alert

January 7, 2014, Covington Advisory

October 2013, The Banking Law Journal

August 15, 2013, The Hill's Congress Blog

June 2013, Wall Street Lawyer

May 16, 2013, Covington E-Alert

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 ...

April 4, 2013, Covington Advisory

January 8, 2013, Law360

January 3, 2013, Covington E-Alert

November 13, 2012, Law360

February 13, 2012, Covington E-Alert

February 6, 2012, Covington E-Alert

November 22, 2010, Covington E-Alert

July 1, 2008, Covington E-Alert

Covington Alert

The ethics rules that apply to Presidential appointees shifted Wednesday, in some ways significantly, as President Biden, just hours after being sworn in, signed an “Executive Order on Ethics Commitments by Executive Branch Personnel” and President Trump, just hours before his term expired, revoked his Executive Order on Ethics. This alert summarizes the key ...