Compliance Notes, Vol. 6, Issue 18

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RECENT LOBBYING, ETHICS & CAMPAIGN FINANCE UPDATES


Campaign Finance & Lobbying Compliance

President Donald Trump signed a memorandum Thursday, August 27, 2025, directing Attorney General Pam Bondi to investigate whether federal grant funds are being used for illegal lobbying or partisan activity, citing his administration’s funding reviews that “revealed that taxpayer funds are being spent on grants with highly political overtones.” The order notes federal law bars grant money from being used for lobbying or political advocacy and gives Bondi 180 days to deliver findings and recommend enforcement actions. It follows an earlier executive order requiring agencies to tighten oversight of discretionary grant programs. (Christian Datoc, Washington Examiner & Fact Sheet)

A federal judge ruled Elon Musk and America PAC must face a breach of contract claim over unpaid signature-gathering bounties promised during the 2024 presidential election. Plaintiffs allege they fulfilled the terms of a campaign encouraging swing-state voters to support First and Second Amendment petitions, but were not paid. The Eastern District of Pennsylvania was deemed a proper venue because plaintiffs viewed advertisements and accepted the offer in that state, even though the program was administered from Texas. Claims for promissory estoppel and wage violations under Pennsylvania law were dismissed without prejudice, but the breach of contract claim was allowed to proceed. (Bernie Pazanowski, Bloomberg Law) (subscription required)

Puerto Rico: Former Puerto Rico Gov. Wanda Vázquez pleaded guilty Wednesday, August 2, 2025, to a federal campaign finance violation, becoming the first ex-governor of the U.S. territory convicted of a crime. Prosecutors said she accepted a foreign donation pledge during her 2020 campaign, tied to Venezuelan banker Julio Herrera Velutini and former FBI agent Mark Rossini, who allegedly funneled more than $300,000 to her consultants in exchange for regulatory favors. Initially facing bribery and wire fraud charges carrying up to 20 years, the case was reduced earlier this year to a single campaign finance violation with a maximum one-year sentence. Vázquez will be sentenced October 15, 2025; Herrera Velutini and Rossini also pleaded guilty and face sentencing December 10, 2025. (AP News)


Government Ethics & Transparency

Michigan: Michigan Rep. David Martin (R-Davison) voted for new House ethics rules banning grants to for-profit entities, but in April 2025, he requested a $2.5 million earmark for renovations at Flint’s Dort Financial Center through the nonprofit Flint Firebirds Foundation. Businessman Rolf Nilsen’s for-profit corporations own the arena and hockey team. The request, later excluded from the GOP-led House budget, highlights a loophole in the new rules since taxpayer funds would have indirectly benefited a for-profit entity. Campaign finance records show Nilsen contributed $1,000 to Martin’s reelection committee a month after the request. (Ben Solis, Michigan Advance)


Ballot Measures & Legislation

South Dakota: A federal judge struck down South Dakota’s nine-month petition deadline for ballot measures, ruling it unconstitutional under the First Amendment. The law, passed in 2025 and signed by Gov. Larry Rhoden, was challenged by Dakotans for Health co-founder Rick Weiland, who argued the deadline could not ensure the timely resolution of petition challenges given appeals and litigation timelines. U.S. District Judge Camela Theeler issued a permanent injunction restoring the filing period to six months before Election Day, rejecting the state’s defense that the longer window was needed to allow challenges. The state has until Sept. 29 to appeal to the Eighth Circuit. (Marissa Brunkhorst, KELOLAND & (Opinion)

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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