In 2018, Covington published the original version of its widely read primer on the Foreign Agents Registration Act, “FARA: A Guide for the Perplexed.” We have updated this primer periodically. This week, the firm released the latest edition of the primer, featuring new analysis of recent Department of Justice
Continue Reading Covington Releases Updated Version of “FARA: A Guide for the Perplexed”Political Law
A Potentially Overlooked Risk Area: Incorporating Congressional Investigations into Transactional Due Diligence
Congressional investigations are now a common reality across corporate America, and companies large and small are therefore more focused than ever on the potential effects of congressional inquiries into business activities, goals, and strategies. In this new reality, the most sophisticated companies, private equity firms, and other corporate players are…
Continue Reading A Potentially Overlooked Risk Area: Incorporating Congressional Investigations into Transactional Due DiligenceDemocratic Investigations Agenda is Coming Into Focus
If the upcoming midterm elections result in a Democratic majority in the House next year, companies, organizations, and individuals can expect a new wave of congressional investigations, hearings, and oversight, with a familiar focus on the Trump administration and an emphasis on a variety of private sector targets. The Democratic…
Continue Reading Democratic Investigations Agenda is Coming Into FocusFCC Issues Guidance Focused on Candidate Appearances on Talk Shows
By Matthew DelNero, Kiara Ortiz & Evan Chiacchiaro on
On January 21, 2026, the FCC’s Media Bureau released a Public Notice providing new guidance on how it will evaluate whether broadcast television stations have triggered an obligation to provide “equal opportunities” to political candidates under Section 315 of the Communications Act.
The FCC’s equal opportunities rule generally says that if a station gives one legally qualified candidate free airtime, it usually has to offer comparable airtime to the other candidates running for the same office unless an exemption applies. To avoid discouraging general news coverage, Congress created several exemptions to this rule—one of the most commonly used being the exemption for bona fide news interviews. In its new guidance, the FCC signals a more restrictive view of the bona fide news exemption, particularly in the context of late‑night shows, daytime talk shows, and other hybrid news‑entertainment formats.Continue Reading FCC Issues Guidance Focused on Candidate Appearances on Talk Shows
Covington’s Guide to Ballot Measures
By Robert Kelner, Derek Lawlor, Andrew Garrahan & Lauren Cox on
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…
Continue Reading Covington’s Guide to Ballot MeasuresSenate Advances Bills To Broaden Foreign Agent Disclosures in Lobbying Reports
Posted in Foreign Agents Registration Act, Political Law
Shortly before adjourning for 2025, the Senate passed two bills to broaden disclosure and registration requirements related to the regulation of foreign agents under the Foreign Agents Registration Act (“FARA”) and the Lobbying Disclosure Act (“LDA”): the Disclosing Foreign Influence in Lobbying Act (S. 856 / H.R. 1883)…
Continue Reading Senate Advances Bills To Broaden Foreign Agent Disclosures in Lobbying ReportsIs a Political Law Shareholder Proposal Under Your Tree? Strategies for Responding in the New Year
Posted in Political Law
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
By Derek Lawlor, Andrew Garrahan & Kimberly Railey on
Posted in Election, Political Law
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
By Derek Lawlor, Andrew Garrahan & Kimberly Railey on
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
By Robert Kelner, Peter Koski, Brian D. Smith, Susan Leahy, Kaitlyn Demers, Andrew Garrahan & William Sokolove on
Posted in Political Law
- On September 25, 2025, President Trump issued National Security Presidential Memorandum/NSPM-7, Countering Domestic Terrorism and Organized Political Violence. The memorandum