Pay-to-Play

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Pic1Sitting state office holders often run for federal office. As a recent decision from the FEC reminds us, it is important that resources from the state campaign not be used in the federal campaign, unless the federal campaign pays fair-market-value for those resources. Indeed, this same principle applies when other types of related organizations seek …

When we talk about pay-to-play, we often think about making sure that executives do not make inadvertent contributions that run afoul of a state’s pay-to-play rules and make the company ineligible for contracts. We might also think about tracking contributions from certain employees so that pay-to-play certifications are truthful and accurate. But a recent criminal…

Significant campaign finance reform legislation cleared the Maryland House of Delegates Thursday, and is now under consideration by a committee of the Maryland Senate. The Campaign Finance Reform Act of 2013 (HB 1499 and SB 1039) responds to recommendations of the recently convened Maryland Commission to Study Campaign Finance Law. The bill addresses…

We hope you will join us for a webinar on February 27 at 1:00, called Political Law 101. We will cover all the major topics you need to be thinking about as you ramp up for lobbying the new Congress and state legislatures, host site visits and other events, and prepare for the next election…

Last week the Commodity Futures Trading Commission (“CFTC”) issued a No-Action Letter that helps harmonize the CFTC’s pay-to-play rules for swap dealers (Regulation 23.451) with both the SEC and Municipal Securities Rulemaking Board (“MSRB”) pay-to-play regulations. The Letter also provided guidance regarding the two-year “look back” period, during which time swap dealers may be prohibited…

The landmark Supreme Court ruling in the Citizens United case paved the way for explosive growth in political spending during the 2012 election cycle.  However, for government contractors and their principals, a growing number of “pay-to-play” laws restrict political contributions and fundraising, and can result in severe penalties, including the loss of contracts. Venable has…

On November 2, 2012, the District Court for the District of Columbia, two days after oral argument, upheld the long-standing ban on political contributions from federal government contractors. In Wagner v. Federal Election Commission, three independent contractors with various federal agencies argued that the ban on federal contractor contributions in section 441c of the…

Prominent Wall Street firm Goldman Sachs will pay almost $12 million to settle charges that one of its investment bankers made undisclosed campaign contributions to a state official responsible for awarding government contracts.

The case is the first SEC action for pay-to-play violations based on “in-kind” – meaning, non-cash – contributions to a political campaign.…

Last week the SEC’s Office of Compliance Inspections and Examinations issued a National Examination Risk Alert for brokers, dealers and municipal securities dealers regarding compliance with Municipal Securities Rulemaking Board (MSRB) Rule G-37. The Risk Alert noted that recent SEC examiners have observed practices that raise concerns whether firms are adequately complying with all of…

In the wake of the corruption scandal involving former Governor Rod Blagojevich, Illinois adopted its first-ever limits on campaign contributions. Individuals could give candidates up to $5,000 per election, and corporations could give candidates up to $10,000. At a signing ceremony for the bill, held on the one-year anniversary of Blagojevich’s arrest, Governor Pat Quinn…