It’s a common scenario: An employee receives a text from a friend asking them to contribute to the campaign of a candidate the friend supports. Without thinking much about it, the employee makes a $500 contribution. Though the employee has been trained on their company’s political contributions policy, it doesn’t occur to the employee to check with compliance before contributing. But the employee’s seemingly routine political contribution could jeopardize the company’s contracts with public entities, trigger investigations, or even result in enforcement actions and substantial penalties.

As the 2026 election season accelerates, now is a good time for companies that do business with government entities to emphasize pay-to-play compliance and remind employees of the consequences that can result from their personal political contributions. In this alert, we outline pay-to-play risks, compliance measures, and common pitfalls, as well as how to prepare for the possibility of an exemption application.

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Photo of Zachary G. Parks Zachary G. Parks

Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.

Chambers USA describes Zachary as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to…

Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.

Chambers USA describes Zachary as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to outside attorney for election law, campaign finance, pay-to-play and PAC issues.” Zachary is also a leading lawyer in the emerging corporate political disclosure field, regularly advising corporations on these issues.

Zachary’s expertise includes the Federal Election Campaign Act, the Lobbying Disclosure Act, the Ethics in Government Act, the Foreign Agents Registration Act, and the Securities and Exchange Commission’s pay-to-play rules. He has also helped clients comply with the election and political laws of all 50 states. Zachary also frequently leads political law due diligence for investment firms and corporations during mergers and acquisitions.

He routinely advises corporations and corporate executives on instituting political law compliance programs and conducts compliance training for senior corporate executives and lobbyists. He also has extensive experience conducting corporate internal investigations concerning campaign finance and lobbying law compliance and has defended his political law clients in investigations by the Federal Election Commission, the U.S. Department of Justice, Congressional committees, and in litigation.

Zachary is also the founder and chair of the J. Reuben Clark Law Society’s Political and Election Law Section.

Zachary also has extensive complex litigation experience, having litigated major environmental claims, class actions, and multi-district proceedings for financial institutions, corporations, and public entities.

From 2005 to 2006, Zachary was a law clerk for Judge Thomas B. Griffith on the United States Court of Appeals for the District of Columbia.

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Photo of Meredith Rolfs Severtson Meredith Rolfs Severtson

Meredith is an associate in the Washington, DC office. She is a member of the Election and Political Law Practice Group and advises corporations, political committees, nonprofits, and individuals on compliance with federal and state lobbying, campaign finance, and government ethics laws. She…

Meredith is an associate in the Washington, DC office. She is a member of the Election and Political Law Practice Group and advises corporations, political committees, nonprofits, and individuals on compliance with federal and state lobbying, campaign finance, and government ethics laws. She also represents clients in congressional investigations and other matters before government agencies.

Meredith maintains an active pro bono practice with a focus on voting rights.

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