Compliance Notes, Vol. 6, Issue 9 - May 2025

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RECENT LOBBYING, ETHICS & CAMPAIGN FINANCE UPDATES


Campaign Finance & Lobbying Compliance

The Federal Election Commission (FEC) will soon lose its ability to enforce and regulate campaign finance laws, NOTUS reported Friday, April 25, 2025. Republican Commissioner Allen Dickerson resigned Wednesday, April 30, 2025, leaving the FEC without the quorum of four commissioners it needs to operate, according to three government sources. The FEC was already down two commissioners, after one commissioner resigned and President Donald Trump removed a Democratic member in February 2025. Dickerson’s departure will drop the number of active commissioners to three. Without a quorum, the FEC cannot fine violators, issue rules or guidance, conduct audits, vote on investigations or hold formal meetings. The shutdown could last weeks or months, depending on how quickly Trump nominates replacements and the U.S. Senate confirms them. (Dave Levinthal, NOTUS)

President Donald Trump targeted Democratic fundraising group ActBlue and other online fundraising platforms with a presidential memorandum aimed at cracking down on illegal foreign contributions in U.S. elections. The memo, which Trump signed Thursday afternoon, April 24, 2025, directs Attorney General Pam Bondi to investigate and “take appropriate action concerning allegations regarding the use of online fundraising platforms to make ‘straw’ or ‘dummy’ contributions and to make foreign contributions to U.S. political candidates and committees, all of which break the law,” according to a White House statement. The memo cites a congressional investigation that “revealed significant fraud schemes using ActBlue” and notes that foreign donations using prepaid cards were detected during a 30-day period in the 2024 election. The memo directs Bondi to report the results of the probe to Trump. ActBlue, which says it has raised billions of dollars online since 2004, called the move an attack on democracy. (Jeff Mason and Steve Holland, Reuters & April 24, 2025 Memo)


Government Ethics & Transparency

California: The Fair Political Practices Commission (FPPC), California’s leading political watchdog, launched a three-part panel series this month to explore the intersection of artificial intelligence, ethics and political transparency. The series, entitled “Effectively Leveraging and Regulating AI in the Political Process,” is being held by the FPPC’s Public Outreach and Technology Committee. Each panel will bring together leading experts in emerging technology and public policy to examine how AI is impacting transparency, enforcement and the future of public trust in government. The first panel, “Detecting AI in Campaign Advertisements,” was held on Tuesday, April 22, 2025. (California FPPC & April 22, 2025 Agenda)

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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