HomeEssential Ethics / September 2, 2022

Essential Ethics

September 2, 2022

Latest Developments:

  • The Attorney General of the United States released a memorandum concerning new restrictions on political activities of non-career department employees. The memo provides these employees with new admonishments, cautioning that they “may not participate in any partisan political event in any capacity…both public and non-public partisan political events.” The rules also rescind exceptions for participation in these events when an employee’s spouse pursues public office or on “the evening of election day.” More in Politico.
  • A Federal District Court in Puerto Rico proceeded this week with the prosecution of a Venezuelan national and financier who bribed Puerto Rico officials, promising major campaign donations in exchange for public personnel changes. The indictment claims that “from December 2019 through June 2020, then-Governor of Puerto Rico Wanda Vazquez…allegedly engaged in a bribery scheme with [the financier]…to finance [Vazquez’s] 2020 gubernatorial election campaign. Bloomberg provides further details.


The Practising Law Institute presents the annual Corporate Political Activities Conference on September 8-9, 2022 in Washington, D.C.  The conference is also hybrid online and on-demand, so it may also be viewed in segments. To sign up, use the following link:  PLI Two-Day Conference in Washington D.C.

In Case You Missed It:

  • Colorado Springs Forward:  The Colorado Springs Gazette reports that a local civic nonprofit will have to appear before state administrative courts for making outsized donations to two county candidates violating the state’s ban on corporate contributions to candidates. The Secretary of State office refused to dismiss the complaint even though a state inquiry “found the violation was cured” when the candidates returned the contributions. Oneissue is “the implication of quid-pro-quo corruption between the nonprofit corporation and the candidates…[as] the signatory of the contribution check operates a museum that received $500,000 in federal coronavirus pandemic relief funds through El Paso County four months before…[the] campaign donations from the nonprofit were issued.” The Secretary of State’s office found a defense that the mistake “by volunteers” was unintentional “not plausible,” noting other political activity by the nonprofit and affiliates.
  • California’s Campaign Debt Conundrum:  The Voice of San Diego reports that the city of Chula Vista has gained little traction in the year after its council voted unanimously to address a major campaign finance lacuna. The issue concerns “campaign debt…when candidates… spend more than they raise in donations, and the difference is listed on disclosure reports as an accrued expense — essentially a credit.” Then, once victorious candidates “secure a position of influence…[they] go back out and raise more money.” Chula Vista law “doesn’t offer a timeline for when those bills are due…these costs of campaign goods and services become donations, subject to a $360 per person cap, if they’re not paid upfront.” The issue has manifested half a dozen times over the last decade, with allegations certain victorious officials soliciting debt repayment contributions from entities who have business with the city.
  • A Dummy Contribution to a Ghost Candidate:  Local media in Orlando, Florida recounts the criminal court proceedings of former GOP county chair Ben Paris who made prohibited donations to a spoiler candidate allegedly fielded to siphon votes away from the opposing party candidate. The scheme was successful in narrowly electing Paris’s former boss, but the trial concerns Paris skirting individual campaign limits by making a contribution in the name of his cousin.