Is it Illegal "Pay-to-Play" for a Government Contractor or National Bank to Contribute to a Super PAC?

A new complaint was filed with the Federal Election Commission yesterday alleging that Chevron USA violated campaign finance laws and corollary “federal pay-to-play” laws by contributing $2.5 million to the Congressional Leadership Fund, a Super PAC tied by press reporting and former staffers to House Speaker Boehner. While the FEC complaint was filed by organizations likely more interested in “poking the bear” because of Chevron’s environmental footprint than its politics (Public Citizen, Friends of the Earth, Greenpeace, and Oil Change International, hereinafter referred to as “The Usual Suspects”), the complaint has facial merit and needs to be on the radar screen of government contractors, national banks, and foreign nationals everywhere.

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Advice for General Counsel and Boards of Directors on Pay-to-Play Compliance

The Conference Board was kind enough to share the following link to portions of a webinar they hosted a few weeks back on best practices for corporate political spending. It is about 20 minutes long and focused on some of the issues those tasked with pay-to-play compliance lay awake worrying about (yes, those people do exist).

I hope it is helpful and entertaining (hey, one out of two wouldn’t be bad either).