More than one billion dollars were spent in 2024 elections supporting or opposing state and local ballot measures. With high-profile and contentious issues expected to be on the ballot, such as congressional redistricting, AI regulation, minimum wage increases, and more, that number promises to be even larger in 2026. As
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Andrew Garrahan
Andrew Garrahan represents and counsels clients at the intersection of law and politics. He guides them through both regulatory compliance issues and government investigations on matters including state and federal campaign finance, ethics, lobbying, and corruption, as well as in congressional investigations.
Andrew’s prior career in political fundraising gives him a unique perspective on the challenges faced by his clients, which include corporations, candidates, government officials, political and nonprofit organizations, and private individuals.
Andrew’s counseling and advisory practice includes:
guiding clients on structuring of and compliance for their state and federal lobbying and grassroots advocacy campaigns;
representing campaigns, Super PACs, corporations, trade associations, and individuals on the applicability of the Federal Election Campaign Act (FECA) and state campaign finance law;
counseling on Foreign Agents Registration Act (FARA) registration and disclosure, and its interaction with the Lobbying Disclosure Act (LDA);
helping companies comply with state and federal ethics laws, particularly on gifts and conflicts of interests, and domestic anticorruption; and
auditing corporate political law compliance practices.
Andrew’s investigations and defense work includes:
representing clients in Congressional investigations, including responding to letter requests and subpoenas;
preparing company officers and other individuals for testimony in Congressional investigative hearings;
defending clients in Department of Justice matters related to campaign finance, lobbying, ethics, and public corruption; and
representing clients before the FEC and state campaign finance, lobbying, and ethics regulators.
Is a Political Law Shareholder Proposal Under Your Tree? Strategies for Responding in the New Year
The 2025 proxy season saw significant developments with respect to proposals calling on companies to disclose information about their political contribution activity and lobbying activity, including an increase in support for political contribution proposals. That stronger support, particularly against the backdrop of reduced support for socially-oriented shareholder proposals, may lead…
Continue Reading Is a Political Law Shareholder Proposal Under Your Tree? Strategies for Responding in the New YearCorporate and Industry “Mega PACs”: The Next Frontier for Super PACs
Since the landmark Citizens United decision in 2010, super PACs have become a fixture of U.S. political campaigns. But despite the initial anticipated boom in corporate influence in elections, most super PAC funding to date has come from wealthy individuals, closely-held corporations, and nonprofits, not from large for-profit corporations.
However…
Continue Reading Corporate and Industry “Mega PACs”: The Next Frontier for Super PACsForming and Operating Super PACs: A Practical Guide for Political Consultants in 2026
In the 2024 election cycle, super PACs spent a reported $2.7 billion at the federal level, up from roughly $1.4 billion in 2022. And in 2025, super PACs poured tens of millions into state and local races, including the New Jersey gubernatorial race and the New York City mayoral…
Continue Reading Forming and Operating Super PACs: A Practical Guide for Political Consultants in 2026Practical Advice for Nonprofits and Donors After the Presidential Memorandum on “Countering Domestic Terrorism and Organized Political Violence” and Reported IRS Enforcement Changes
- On September 25, 2025, President Trump issued National Security Presidential Memorandum/NSPM-7, Countering Domestic Terrorism and Organized Political Violence. The memorandum
Administration Targets Lobbying by Federal Grantees with New Presidential Memorandum
Federal contractors, grantees, borrowers, and others receiving federal funds face a variety of restrictions on their use of those funds for political purposes, including for lobbying. A new presidential memorandum issued last week by President Trump highlights one of those restrictions, 31 U.S.C. § 1352, also known as the…
Continue Reading Administration Targets Lobbying by Federal Grantees with New Presidential MemorandumCorporate Political Disclosure Shareholder Proposals Draw Surprising Support
Shareholder proposals on political issues—particularly lobbying spending disclosure and campaign finance issues—have been a common part of the proxy landscape for some time now. This proxy season, proposals seeking greater transparency around corporate political spending had surprising success compared to the past. Especially given this development, companies should be aware…
Continue Reading Corporate Political Disclosure Shareholder Proposals Draw Surprising SupportCovington Announces Political Law Survey (2025 Edition)
Covington is pleased to announce that it has revised and updated its comprehensive 50-state survey of political laws for 2025.
Corporations, trade associations, non-profits, other organizations, and individuals face significant penalties and reputational harm if they violate federal or state laws governing corporate and personal political activities, the registration of…
Continue Reading Covington Announces Political Law Survey (2025 Edition)Covington Announces Pay-to-Play Survey (2025 Edition)
Covington is pleased to announce that it has revised and updated its comprehensive 50-state survey of pay-to-play laws for 2025.
Companies doing business with the federal government or state and local governments and companies operating in regulated industries are subject to a dizzying array of “pay-to-play” rules. These rules effectively…
Continue Reading Covington Announces Pay-to-Play Survey (2025 Edition)California Updates Pay-to-Play Law Regulations to Reflect Recent Law Changes
Important changes to California’s pay-to-play law took effect January 1, 2025, and now the state’s regulations have caught up to the law.
The state’s Fair Political Practices Commission adopted the new regulations late last month, following statutory revisions to California’s complex pay-to-play law found at California Government Code § 84308…
Continue Reading California Updates Pay-to-Play Law Regulations to Reflect Recent Law Changes