Zachary G. Parks

Zachary G. Parks

Zachary Park advises a wide range of corporate and political clients on federal and state campaign finance, lobbying disclosure, pay to play, and government ethics laws. Mr. Parks regularly 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 clients in investigations by the Federal Election Commission, the U.S. Department of Justice, and the House Oversight & Government Reform Committee.

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PLI Current Highlights New Wave of FARA Enforcement

By Zachary G. Parks on Posted in Compliance Issues, Uncategorized
As the Foreign Agents Registration Act continues to receive national attention, an article in this quarter’s PLI Current journal describes the Justice Department’s increased focus on the statute.  The article, authored by Covington’s Rob Kelner, Zack Parks, and Alex Langton, discusses the shifting FARA enforcement landscape, analyzes how the statute works, and addresses pending FARA … Continue Reading

IRS Announces Major Change To Nonprofit Donor Disclosure Requirements

By Zachary G. Parks, Derek Lawlor and Robert Kelner on Posted in Compliance Issues, Tax Reform, Uncategorized
In a significant and unexpected development, the U.S. Treasury Department announced yesterday that certain nonprofits — including trade associations and 501(c)(4) social welfare organizations — would no longer be required to disclose the names and addresses of their donors on the annual “Form 990” they file with the Internal Revenue Service. Although the IRS already … Continue Reading

A Review of Pending FARA Reform Bills

By Zachary G. Parks on Posted in Compliance Issues, Congressional Action
In recent months, Congress’s efforts to reform dramatically the Foreign Agents Registration Act (“FARA”) have picked up steam. As we explained in our recent FARA guide, FARA is a complex and broadly worded criminal statute that requires any “agent of a foreign principal” to register with the Department of Justice and file detailed public reports … Continue Reading

House Tax Bill Opens Door to Expanded Political Activity By Charities

By Robert Kelner, Robert Lenhard, Susan Leahy, Zachary G. Parks and Derek Lawlor on Posted in Congressional Action
There is one very important political law provision to watch as the tax bill moves to a final vote in the Senate, and potentially a conference committee reconciles the House and Senate versions.  This amendment will remove the ban on partisan political activities by charitable entities, churches, educational institutions and all other organizations exempt from … Continue Reading

Is Corporate Political Disclosure Leveling Off? Crunching the latest CPA-Zicklin Numbers

By Zachary G. Parks on Posted in Uncategorized
For years, the Center for Political Accountability’s annual CPA-Zicklin Index of corporate political practices has touted marked year-over-year increases in corporate political disclosure practices. Look at the subtitles for its recent reports: How Leading Companies are Strengthening Their Political Spending Practices (2013), How Leading Companies are Making Political Disclosure a Mainstream Practice (2014 and 2015), … Continue Reading

The Top Three Political Law Risks for Hedge Funds, Private Equity Funds, and Investment Firms

By Zachary G. Parks on Posted in Compliance Issues, Uncategorized
Perhaps no industry faces more scrutiny and regulation of its political activities than the financial services industry.   Even though these rules are often not intuitive, failure to comply with them can result in big penalties, loss of business, and debilitating reputational consequences.  In this advisory, we describe three sometimes overlooked political law related risks for hedge funds, … Continue Reading

SEC Pay-to-Play Rule Set to Expand to Capital Acquisition Brokers

By Zachary G. Parks on Posted in Uncategorized
The universe of those covered by the SEC’s pay-to-play restrictions is expanding. If a newly proposed SEC rule is adopted as expected, pay-to-play restrictions will now extend to cover the recently created class of broker-dealers called Capital Acquisition Brokers (“CABs”).  In this advisory, we discuss the background on the proposed rule and its implications for … 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

New Report Calls Out Corporate Political Disclosure “Basement Dwellers”

By Zachary G. Parks on Posted in Uncategorized
A report published today criticizes companies that refuse to disclose information about their political spending on their websites.  The non-profit Center for Political Accountability and the Zicklin School at Wharton annually rank all companies in the S&P 500 on their political disclosure practices, based on a 70-point metric.  The more information companies disclose on their … Continue Reading

Have We Reached A FARA “Tipping Point”?

By Zachary G. Parks on Posted in Compliance Issues
The New York Times, earlier this month, reported that “secret ledgers” in Ukraine show $12.7 million in cash payments designated for former Donald Trump campaign chairman Paul Manafort from Ukraine’s pro-Russian political party. Days later, the Associated Press reported that Manafort helped the pro-Russian party “secretly route at least $2.2 million in payments to two prominent Washington lobbying … 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

New Overtime Rules May Spell Trouble For Some Corporate PACs

By Zachary G. Parks on Posted in Compliance Issues
The Obama Administration’s publication yesterday of a regulation increasing the universe of employees entitled to overtime pay might reduce the number of employees from whom corporate PACs can seek contributions. The new regulations, which take effect on December 1, 2016, increase the salary level below which certain employees are entitled to overtime pay. Currently, salaried … Continue Reading

SEC Issues Fines for Pay-to-Play Violations That Predate Its Pay-to-Play Rule

By Zachary G. Parks on Posted in Government Contracts
A $12 million settlement announced last week by the Securities & Exchange Commission suggests that the SEC will aggressively pursue alleged schemes connecting political contributions to government contracts even if the political contributions do not violate its 2010 pay-to-play rule.  According to the settlement order, in 2010, the head of Public Funds at State Street … Continue Reading

Will President Obama’s New Overtime Regulations Shrink Corporate Restricted Classes?

By Zachary G. Parks on Posted in Compliance Issues, Uncategorized
Corporate PAC managers may soon find that the universe of employees who receive corporate PAC solicitations has unexpectedly shrunk.  In July 2015, the Department of Labor proposed new regulations that would dramatically increase the number of workers entitled to overtime wages.  The Department of Labor estimates that, under the new regulations, approximately 5 million new … Continue Reading

New Report Adds Pressure For Public Companies to Voluntarily Disclose Political Spending

By Zachary G. Parks on Posted in Uncategorized
A report published last week by the Center for Political Accountability will result in more pressure on public companies to voluntarily disclose information about their political spending. Each year, CPA in collaboration with the Zicklin Center at the University of Pennsylvania issues a detailed report “scoring” companies on their corporate political disclosure practices according to … Continue Reading

FEC Increases Contribution Limits, Permitting Individuals to Contribute over $800K to National Party Committees

By Zachary G. Parks on Posted in Congressional Action
The Federal Election Commission has increased the limits on the amount an individual can contribute to a candidate or national political party for the 2015-2016 election cycle.  An individual can now give up to $2,700 per election to a candidate for federal office, up from $2,600.  Because the primary and general count as separate elections, individuals may … Continue Reading

Lobbyists Can Now Sit on Some Federal Advisory Committees: Here’s How to Find Out Where

By Zachary G. Parks and Brian D. Smith on Posted in Compliance Issues
In a significant reversal by the Obama administration, lobbyists will now be permitted to serve on federal advisory committees, boards, and commissions after more than four years of sitting on the advisory committee sidelines. In guidance published in the Federal Register today, the Office of Management and Budget (“OMB”) quietly revised, in large part, the … Continue Reading

2013 GAO Lobbying Disclosure Report Shows Challenges in Compliance, Recordkeeping

By Brian D. Smith, Zachary G. Parks and Andrew Garrahan on Posted in Compliance Issues, Congressional Action
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
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