Andrew Garrahan

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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St. Petersburg Passes Anti-Super PAC Ordinance, Hoping to Set Up Constitutional Showdown

By Andrew Garrahan on Posted in Campaign Finance, Corporate Political Spending Disclosure
The City of St. Petersburg, Florida yesterday passed an ordinance designed to take the question of “Super PACs” to the Supreme Court for the first time.  The ordinance, which we discussed in detail earlier this year, imposes a $5,000 limit on contributions to groups that raise money for or make independent expenditures or electioneering communications … Continue Reading

California Legislature Passes “California DISCLOSE Act,” a Complex but Clarifying Update to the State’s Political Advertising Disclosure Rules

By Andrew Garrahan on Posted in Campaign Finance, State Law
Over the weekend, the California legislature passed AB249, the California DISCLOSE Act, a controversial set of campaign finance disclosure rules that have been years in the making.  The law now awaits Gov. Jerry Brown’s approval.  The law’s proponents have argued that it is necessary in order to provide voters with complete information about the sponsors … Continue Reading

Avoiding State and Local Lobbying Compliance Violations

By Andrew Garrahan on Posted in Lobbying Compliance, State Law
Corporate legal and compliance departments are usually well aware of the laws regulating lobbying the federal government. Recent news reports, however, indicate that companies have more trouble with state and local lobbying laws. A few features of state and local lobbying make it a tricky blind spot. This increases the risk of failing to properly … Continue Reading

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

By Andrew Garrahan and Matthew Shapanka on Posted in Campaign Finance
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 Robert Kelner, Brian D. Smith, 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

California AG Becerra Hints at Crackdown on Nonprofit Political Activity

By Andrew Garrahan on Posted in Campaign Finance, State Law
Nonprofits that are active in California politics, already facing one of the most complex regulatory environments in the country, now have another thing to worry about: the state’s Attorney General.  In remarks Wednesday, Attorney General Xavier Becerra announced his intent to pursue nonprofit organizations that he believes “abuse” their nonprofit status for political purposes.  With the … Continue Reading

Virginia Makes Key Adjustments to Law Governing Gifts to Officials, Adds New Lobbyist Gift Notification

By Andrew Garrahan on Posted in Government Ethics, Lobbying Compliance, State Law
Organizations represented by lobbyists in Virginia should be aware of a new law enacted today.  The law eliminates a controversial exception to the state’s $100 limit on lobbyist gifts to legislators and officials, adds a key new exception to that law, and also includes an additional gift notification requirement for lobbyists.  The changes represent Virginia’s … Continue Reading

2016 GAO Annual Lobbying Disclosure Act Compliance Report Issued

By Andrew Garrahan on Posted in Lobbying Compliance
On Friday, the Government Accountability Office (“GAO”) released its tenth annual report on compliance with and enforcement of the federal Lobbying Disclosure Act (“LDA”).  The report summarizes the results of GAO’s random audits of lobbyists’ quarterly LD-2 activity reports and semi-annual LD-203 contribution reports, and provides a snapshot of the current enforcement environment. There are a … Continue Reading

New Executive Order on Ethics in Missouri Includes Lobbyist Gift Ban, Revolving-Door Provision; Legislature Considering Additional Restrictions

By Andrew Garrahan on Posted in Government Ethics, Lobbying Compliance, State Law
Earlier this month, newly-installed Missouri Gov. Eric Greitens issued Executive Order 2, applying strict ethics rules to executive branch employees in that state.  The order includes a ban on gifts from lobbyists, conflicts of interest rules, and a “revolving door” provision that prohibits employees who leave Greitens’ office from later lobbying his administration.  The state … 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 Government Ethics
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

The 2017 Presidential Inauguration: Ethics and Compliance Issues

By Robert Kelner, Robert Lenhard, Zachary G. Parks, Derek Lawlor and Andrew Garrahan on Posted in Campaign Finance, Government Ethics, Lobbying Compliance
With Election Day 2016 in the books, the political world turns to the transition of power and the January 20, 2017 Inauguration of President-elect Donald Trump and Vice President-elect Mike Pence. With the swearing in of the new President and Vice President will come the traditional balls, parties, and receptions. The inauguration and related events … 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 Campaign Finance, Government Ethics, Lobbying Compliance
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 Government Ethics
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 Campaign Finance, Enforcement, Government Ethics
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 Enforcement, Lobbying Compliance
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

Expanded March 30 Filing Enhances Pay-to-Play Disclosure, Highlights Penalties for New Jersey Government Contractors

By Andrew Garrahan and Kevin Glandon on Posted in Pay-to-Play, State Pay-to-Play
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 … Continue Reading

California Regulation, Proposed Statute Add to State’s Reputation for Complex, Detailed Disclosure

By Andrew Garrahan on Posted in Campaign Finance, Lobbying Compliance, State Law
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 Campaign Finance, Enforcement, State Law
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

Christie Vetoes Controversial New Jersey Pay-to-Play Provision

By Andrew Garrahan on Posted in Pay-to-Play, State Law, State Pay-to-Play
Earlier this week, New Jersey Governor Chris Christie vetoed key aspects of a bill that would have imposed new restrictions on the ability of national and federal political party committees to raise money from Wall Street and financial executives.  The bill, as we have previously discussed, sought to apply the state’s notoriously stringent pay-to-play rules … Continue Reading

New Campaign Finance, Lobbying, and Ethics Laws Take Effect

By Andrew Garrahan on Posted in Campaign Finance, Government Ethics, Lobbying Compliance, State Law
The New Year brings with it new laws governing campaign finance, lobbying, and ethics. Below we highlight some of the major state and federal laws that took effect on or around January 1. This is not intended to be an exhaustive list, but highlights some of the most significant changes that are new for 2015.  … Continue Reading
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