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.
Mr. Garrahan’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.
Mr. Garrahan is a member of the Virginia and District of Columbia bars.
Last year, we blogged about a new and highly restrictive disclosure law in New Jersey that took aim at so-called “dark money” spending by nonprofit and political organizations. In response to a series of lawsuits, a federal court has issued an order permanently prohibiting the state from enforcing the law against “independent expenditure committees” as … Continue Reading
Amid ongoing focus on how social media and other companies approach online advertising, California’s latest effort to require disclosure of online advertising will take effect January 1. We blogged on these revisions to the California DISCLOSE Act, sometimes called the Social Media DISCLOSE Act, when they passed back in 2018. Absent federal action, we expect … Continue Reading
Earlier this week, California Gov. Jerry Brown approved the Social Media Disclose Act, to take effect in 2020. We previously blogged about the Social Media DISCLOSE Act, which will place new disclosure obligations on social networks like Facebook and Twitter; advertising platforms like Google; and anyone who engages in online political advertising. Covered platforms in … Continue Reading
In a case with interesting ramifications, a federal court this week struck down major parts of Colorado’s campaign finance enforcement system as unconstitutional.The system at issue, which was created through a ballot initiative, generally allowed any person who believed there had been a violation of the state’s campaign finance laws to file a written complaint … Continue Reading
As sexual abuse, assault, harassment, and other misconduct have dominated national headlines, state capitols and lobbyists have not escaped scrutiny. Amidst a spate of allegations and member resignations, some state legislatures and ethics commissions are taking action. While a variety of measures are being considered, including tightening gift rules, it is apparent that lobbyists and … Continue Reading
On Saturday, California Gov. Jerry Brown signed the California DISCLOSE Act, AB249, into law. We posted a detailed analysis of the law when it passed the legislature, but the key points bear repeating as it will be of interest to anyone who gives or spends money in California elections. The law requires that some form … Continue Reading
The U.S. House Committee on Appropriations is considering a major change to the way trade associations are allowed to raise money into their political action committees (PACs). Currently, if a trade association wants to solicit money from its member companies’ employees, it must first get advance approval from the company, and each company can authorize … Continue Reading
The new chairman of the House Committee on Oversight and Government Reform, Representative Trey Gowdy (R-S.C.), outlined his plans for the Committee last week. As we expected, Mr. Gowdy said that he would pursue more methodical investigations. Noting that hearings are “an inefficient way to gather facts,” Mr. Gowdy said that the Committee would pursue … Continue Reading
Last summer there was much ado about the two parallel efforts of a “Dream Team” of attorneys to “end Super PACs.” Their goal was to get the Supreme Court to overturn the decision of the D.C. Circuit in SpeechNow v. FEC, and similar decisions in other circuits, which led to the creation of Super PACs. … Continue Reading
The Trump administration’s efforts to curtail congressional oversight of executive branch agencies by individual Members of Congress, including ranking Democratic Members of Committees, ran into significant opposition from an unlikely source: Senator Chuck Grassley (R-Iowa), the Republican Chairman of the Senate Judiciary Committee. Sen. Grassley’s strong reaction is consistent with his role as perhaps Congress’s … Continue Reading
With the announcement by Rep. Jason Chaffetz (R-Utah) that he plans to resign from Congress on June 30, it appears increasingly likely that Rep. Trey Gowdy (R-S.C.) will become the next Chairman of the House Committee on Oversight and Government Reform, the House’s powerful watchdog committee that has very broad investigative jurisdiction. Although a final … Continue Reading
The start of 2017 brings two changes to the federal Office of Government Ethics (“OGE”) rules for executive branch officers and employees. First, important changes to the executive branch gift rules went into effect this week. We detailed those changes in this alert. Second, OGE’s overhaul of the Executive Branch Ethics Program regulations (5 C.F.R. … Continue Reading
Over the next nine weeks, the Trump Presidential Transition team will formulate policy and staffing recommendations for the new administration. This alert gives a broad overview of the Transition and the laws that regulate interactions with Transition team members on issues related to appointments and policy recommendations. Persons interested in this topic may also wish … Continue Reading
Companies are increasingly hiring out of the federal workforce, only to find that their new hires are restricted by “revolving door” rules that prohibit their participation in certain matters – sometimes for a limited time, sometimes permanently. New rules issued recently by the U.S. Office of Government Ethics (“OGE”) serve as a reminder that, even … Continue Reading
The Ferrari carrying former Virginia Governor Bob McDonnell appears to have made a U-turn this week on its way to the federal penitentiary. Covington released today a Client Alert on the Supreme Court’s decision in McDonnell v. United States, a decision which vacated Governor McDonnell’s conviction and redraws the lines for corruption prosecutions. The Court held a public … Continue Reading
On Friday, the Government Accountability Office (GAO) issued its ninth annual report on compliance with the federal Lobbying Disclosure Act (LDA), covering from mid-2014 through mid-2015. As in the past, the report is based on random audits of lobbyists’ filings and analysis of enforcement by the U.S. Attorney’s Office for the District of Columbia. We … Continue Reading
New Jersey is well-known for having strict, comprehensive, and complex pay-to-play laws. Two new changes to an annual pay-to-play filing required of some government contractors will only enhance that reputation.State law requires a company that receives $50,000 annually through government contracts in New Jersey to file a report by March 30 of the following year … Continue Reading
California is already home to some of the most complicated and searching political regulations in the country, especially in its efforts to expose “dark money” and other undisclosed political spending. A newly-amended lobbying regulation and proposed campaign finance law will enhance that reputation. The practical effect of each is to invite deeper scrutiny of not … Continue Reading
As Super PACs and campaigns continue to edge closer to the legal line between “independence” and “coordination,” it has become common to hear calls for the FEC to take a stricter role in enforcing the law. Yet as recently reported by BNA, the FEC has not found a single violation of its coordination rules in … Continue Reading
In the past week, the Association of Government Relations Professionals (formerly the American League of Lobbyists) announced its endorsement of tougher disclosure requirements for lobbyists, and Senators Michael Bennet (D-CO) and Jon Tester (D-MT) introduced the Close the Revolving Door Act of 2014, which would permanently ban former Members of Congress from becoming lobbyists. This … Continue Reading
Last week, the Government Accountability Office (GAO) released its 2013 report on compliance with the Lobbying Disclosure Act of 1995 (LDA), summarizing the audits of 104 lobbyist reports and information from the U.S. Attorney’s Office for the District of Columbia. We see several trends in this year’s report. First, registrants are reporting more difficulties complying … Continue Reading