During the 2012 election cycle, we cautioned that campaign finance problems can haunt candidates long after the election is over.  Case in point:  As the New York Daily News reports, the New York City Campaign Finance Board recently voted to impose $72,402 in penalties for violations of 15 different campaign finance restrictions, including accepting contributions prohibited under a pay to play law, accepting corporate contributions, and accepting contributions in excess of contribution limits, in connection with a candidate’s 2009 campaign for Public Advocate.

The Campaign Finance Board found that the candidate committee engaged in 22 violations of a New York City pay to play law known as the “Doing Business” restrictions.  These restrictions impose a $400 limit on the contributions (including in-kind contributions) an individual who has “business dealings with the city” may give to the Public Advocate.  The law also limits contributions to candidates for Mayor or Comptroller ($400), Borough President ($320), or City Council ($250).

The scope of this pay to play rule is broad and the restrictions may apply to owners and senior officers and executives of companies seeking contracts with the city, including pension fund investment contracts, as well as city lobbyists.  City administration maintains a database listing registrants.

There are a few takeaways from this NYC campaign finance decision.  First, if you have or your organization has any dealings with New York City government, it is important to determine whether the Doing Business rules apply to you.  Second, although media reports often give the impression that campaign finance law is being undermined and under-enforced, some jurisdictions do have aggressive regulators.  Third, it is possible that others could avoid these problems by instituting a robust internal system of training and compliance.

There is a cost associated with being careful.  But increased resilience in the face of allegations of misconduct should be more than worth it.