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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Interacting with the Government During the Pandemic: Compliance Blind Spots for Corporations and Executives

By Robert Kelner, Robert Lenhard, Michael Wagner, Peter B. Hutt II, Zachary G. Parks, Derek Lawlor, Andrew Garrahan and Jessica Jensen on Posted in Campaign Finance, Congressional Investigations, Corporate Political Spending Disclosure, Foreign Agents Registration Act, Government Ethics, Lobbying Compliance
The consequences of the COVID-19 pandemic are reverberating in every sector of the global economy, from life sciences to transportation, retail to manufacturing, financial services to sports and entertainment. As federal, state, and local governments attempt to blunt the pandemic’s public health and economic effects, many companies are frantically working with government to seek the … Continue Reading

New Jersey “Dark Money” Disclosure Law Permanently Enjoined

By Andrew Garrahan on Posted in Campaign Finance, Corporate Political Spending Disclosure, Lobbying Compliance, State Law
Last year, we blogged about a new and highly restrictive disclosure law in New Jersey that took aim at so-called “dark money” spending by nonprofit and political organizations.  In response to a series of lawsuits, a federal court has issued an order permanently prohibiting the state from enforcing the law against “independent expenditure committees” as … Continue Reading

New Online Political Advertising Rules Coming to California January 1

By Andrew Garrahan on Posted in Campaign Finance, Political Law, State Law
Amid ongoing focus on how social media and other companies approach online advertising, California’s latest effort to require disclosure of online advertising will take effect January 1.  We blogged on these revisions to the California DISCLOSE Act, sometimes called the Social Media DISCLOSE Act, when they passed back in 2018.  Absent federal action, we expect … Continue Reading

California Poised to Adopt Campaign Contribution Limits for City and County Elections

By Andrew Garrahan on Posted in Campaign Finance, State Law
The California legislature passed a new law this week that, if signed by the Governor, would impose campaign contribution limits on city and county elections in the state.  Under current law, cities and counties may adopt their own contribution limits, but most have not.  According to the legislature, this has led to a situation where … Continue Reading

New Jersey, Colorado Join Growing List of States Regulating “Dark Money”

By Andrew Garrahan on Posted in Campaign Finance, Corporate Political Spending Disclosure, Political Law, State Law
So-called “dark money” — political contributions and spending by groups that do not have to disclose their donors — continues to draw the attention of state legislators, with Colorado and New Jersey recently adopting laws that attempt to force some donor disclosure from the groups.  They join other states, including Washington and California, that have … Continue Reading

California Social Media DISCLOSE Act Becomes Law, Takes Effect 2020

By Andrew Garrahan on Posted in Campaign Finance, State Law
Earlier this week, California Gov. Jerry Brown approved the Social Media Disclose Act, to take effect in 2020.  We previously blogged about the Social Media DISCLOSE Act, which will place new disclosure obligations on social networks like Facebook and Twitter; advertising platforms like Google; and anyone who engages in online political advertising.  Covered platforms in … Continue Reading

California’s New “Social Media DISCLOSE Act” Regulates Social Media Companies, Search Engines, Other Online Advertising Outlets, and Political Advertisers

By Andrew Garrahan on Posted in Campaign Finance, State Law
California’s new “Social Media DISCLOSE Act” takes on the trending topic of online political advertising disclosure. Assuming Gov. Jerry Brown signs the bill, then come 2020, social media networks like Twitter and Facebook, as well as Google and similar tools, may face burdensome new obligations related to California political advertising.  Political advertisers themselves will also … Continue Reading

Colorado Enacts Replacement Campaign Finance Enforcement System

By Andrew Garrahan on Posted in Campaign Finance, Enforcement, Litigation, State Law
Just one week ago, a federal court in Colorado held that the state’s system for enforcing its campaign finance laws was unconstitutional.  Moving quickly, the Colorado Secretary of state has enacted temporary enforcement rules, effective immediately. Under the new rules, any person may file a complaint, just like under the old system.  However, the rules … Continue Reading

Colorado Campaign Finance Enforcement System Found Unconstitutional

By Andrew Garrahan on Posted in Campaign Finance, Enforcement, Political Law, State Law
In a case with interesting ramifications, a federal court this week struck down major parts of Colorado’s campaign finance enforcement system as unconstitutional. The system at issue, which was created through a ballot initiative, generally allowed any person who believed there had been a violation of the state’s campaign finance laws to file a written … Continue Reading

Fight Against Sexual Misconduct Bringing Regulations, Protections for Lobbyists

By Angelle Smith Baugh and Andrew Garrahan on Posted in Lobbying Compliance, State Law
As sexual abuse, assault, harassment, and other misconduct have dominated national headlines, state capitols and lobbyists have not escaped scrutiny.  Amidst a spate of allegations and member resignations, some state legislatures and ethics commissions are taking action.  While a variety of measures are being considered, including tightening gift rules, it is apparent that lobbyists and … Continue Reading

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
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