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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.

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.

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Understanding H.R. 1 (Part 2): Changes to the Lobbying Disclosure Act and Foreign Agents Registration Act

By Robert Kelner, Robert Lenhard, Brian D. Smith, Derek Lawlor and Andrew Garrahan on Posted in Compliance Issues, Foreign Agents Registration Act
With a growing chorus of support across the progressive landscape, the For the People Act of 2021 has emerged as a key legislative priority for congressional Democrats in the 117th Congress. Envisioned as a “transformational anti-corruption and clean elections reform package,” the bill would enact sweeping changes to federal election laws along with important changes … Continue Reading

Understanding H.R. 1 (Part 1): Corporate & Trade Association Campaign Activity

By Robert Kelner, Robert Lenhard, Derek Lawlor, Perrin Cooke and Andrew Garrahan on Posted in Campaign Finance
With a growing chorus of support across the progressive landscape, the For the People Act of 2021 has emerged as a key legislative priority for congressional Democrats in the 117th Congress. Envisioned as a “transformational anti-corruption and clean elections reform package,” the bill would enact sweeping changes to federal election laws along with important changes … Continue Reading

Contributions-for-Pardons Opinion Reveals DOJ Efforts, and Challenges, Prosecuting Lobbying Violations

By Andrew Garrahan on Posted in Compliance Issues
An opinion by Chief Judge Beryl Howell of the U.S. District Court for the District of Columbia unsealed yesterday has generated much attention for its discussion of contributions-for-pardons allegations in a case that is still largely obscured from public view.  But the underlying offenses at issue in the case also include an alleged “secret lobbying … Continue Reading

Washington Becomes Latest State to Pass Law Prohibiting Foreign Involvement in Campaign Finance Activity

By Andrew Garrahan on Posted in Compliance Issues, International Strategy, Uncategorized
Effective today, June 11, 2020, a new law in Washington state prohibits involvement of “foreign nationals” in state campaign finance activity.  The law also requires corporations and other entities to certify their compliance with the new law whenever they make a contribution in the state.  This new law reinforces Washington’s reputation as one of the … Continue Reading

Compliance Considerations for Companies and Individuals Donating Funds, Goods, or Services to Domestic Government Entities

By Andrew Garrahan on Posted in Compliance Issues, COVID-19, Financial
As the coronavirus pandemic continues across the country, many corporations, organizations, and individuals are looking for ways they can help fight back. This often includes donating money, goods, or services to federal, state, or local government entities. These well-intentioned donations can generate compliance problems if not handled appropriately from the start. While the situation will … Continue Reading

New Jersey “Dark Money” Disclosure Law Permanently Enjoined

By Andrew Garrahan on Posted in Compliance Issues, Financial
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

New Online Political Advertising Rules Coming to California January 1

By Andrew Garrahan on Posted in Compliance Issues, Uncategorized
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

California Social Media DISCLOSE Act Becomes Law, Takes Effect 2020

By Andrew Garrahan on Posted in Compliance Issues, Uncategorized
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

Colorado Campaign Finance Enforcement System Found Unconstitutional

By Andrew Garrahan on Posted in Compliance Issues, Uncategorized
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

Fight Against Sexual Misconduct Bringing Regulations, Protections for Lobbyists

By Angelle Smith Baugh and Andrew Garrahan on Posted in Compliance Issues, Uncategorized
 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

U.S. House Considering Major Change to Trade Association PAC Fundraising Rules

By Andrew Garrahan and Matthew Shapanka on Posted in Congressional Action
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

Rep. Gowdy Plans Deeper Oversight

By Robert Kelner, Brian D. Smith, Gabe Neville and Andrew Garrahan on Posted in Congressional Investigations
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

Grassley Defends Congressional Oversight; House Democrats Turn to Statutory Oversight Authority

By Robert Kelner, Brian D. Smith and Andrew Garrahan on Posted in Congressional Investigations
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

The Gowdy Era of Congressional Investigations

By Brian D. Smith, Robert Kelner, Gabe Neville and Andrew Garrahan on Posted in Congressional Investigations
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

New Executive Branch Ethics Rules on Gifts and Procedures for New Hires, Appointees, and the Presidential Transition

By Andrew Garrahan on Posted in Compliance Issues, Congressional Action
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

Guidelines for Interacting with President-Elect Trump’s Transition Team

By Robert Kelner, Robert Lenhard, Zachary G. Parks, Derek Lawlor and Andrew Garrahan on Posted in Compliance Issues, Uncategorized
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

OGE Updates Rules Governing Recruiting of Federal Employees to Private Sector Jobs

By Robert Kelner and Andrew Garrahan on Posted in Uncategorized
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 Supreme Court Redraws the Lines for Corruption Prosecutions

By Robert Kelner, Robert Lenhard, Zachary G. Parks and Andrew Garrahan on Posted in Compliance Issues, Uncategorized
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

Annual GAO Report on Federal Lobbying Compliance Shows Mixed Enforcement Bag: Fewer Audits, More and Larger Enforcement Penalties

By Andrew Garrahan on Posted in Compliance Issues
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

Pay To Play With New Jersey

By Andrew Garrahan and Kevin Glandon on Posted in Compliance Issues
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 Regulation, Proposed Statute Add to State’s Reputation for Complex, Detailed Disclosure

By Andrew Garrahan on Posted in Compliance Issues
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

California Penalizes Campaign, Committee for Coordination Violation

By Robert Lenhard and Andrew Garrahan on Posted in Compliance Issues, Uncategorized
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
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