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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, as well as in congressional investigations.

Andrew’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.

Andrew’s counseling and advisory practice includes:

guiding clients on structuring of and compliance for their state and federal lobbying and grassroots advocacy campaigns;
representing campaigns, Super PACs, corporations, trade associations, and individuals on the applicability of the Federal Election Campaign Act (FECA) and state campaign finance law;
counseling on Foreign Agents Registration Act (FARA) registration and disclosure, and its interaction with the Lobbying Disclosure Act (LDA);
helping companies comply with state and federal ethics laws, particularly on gifts and conflicts of interests, and domestic anticorruption; and
auditing corporate political law compliance practices.

Andrew’s investigations and defense work includes:

representing clients in Congressional investigations, including responding to letter requests and subpoenas;
preparing company officers and other individuals for testimony in Congressional investigative hearings;
defending clients in Department of Justice matters related to campaign finance, lobbying, ethics, and public corruption; and
representing clients before the FEC and state campaign finance, lobbying, and ethics regulators.

Late Friday afternoon, the U.S. Supreme Court granted a stay of the Fourth Circuit’s decision setting aside the FCC Media Bureau’s guidance on entitlement to the lowest unit charge (“LUC”) for certain political ads placed on broadcast TV and radio.  See our prior post about this issue here.  Notably…

Continue Reading Supreme Court Action Revives FCC Media Bureau’s Political Ad Guidance

On August 25, 2026, a divided panel of the U.S. Court of Appeals for the Fourth Circuit set aside guidance by the FCC’s Media Bureau stating that two types of political advertising were entitled to the favorable “lowest unit charge” (“LUC”) rate: ads paid for as “party coordinated expenditures,” meaning…

Continue Reading Fourth Circuit Sets Aside FCC Media Bureau Guidance on Lowest Unit Charge; FCC Asks the Supreme Court to Step In

In an August 2026 Unified Agenda entry, the Department of Justice (“DOJ”) stated that it intends to complete its long-running effort to revise the regulations implementing the Foreign Agents Registration Act (“FARA”). The National Security Division (“NSD”) stated that it is considering a final rule that would adopt “many…

Continue Reading DOJ Signals it will Move Forward with Significant Revisions to FARA Regulations

State regulators are beginning to grapple with the implications of the Supreme Court’s recent decision in National Republican Senatorial Committee v. FEC (“NRSC”).  Minnesota may have provided the first clear example of how the ruling could reshape state campaign finance regimes. On June 30, the Supreme Court struck…

Continue Reading Early Post-NRSC Domino Falls: Minnesota Stops Enforcing Limits on Certain Party In-Kind Contributions

In a major decision today, the Supreme Court in NRSC v. FEC struck down longstanding limits on “coordinated party expenditures” that restricted the amounts political parties could spend in coordination with federal candidates. With this decision, national party committees and the federal accounts of state parties can now spend unlimited…

Continue Reading Supreme Court Decision in National Republican Senatorial Committee v. Federal Election Commission Empowers Political Parties, Calls Other Restrictions into Question

As the election season intensifies, companies face a rapidly evolving landscape of regulatory, compliance, and reputational considerations. With heightened scrutiny on political engagement, lobbying, campaign finance, and communications, organizations must be prepared to navigate complex and fast-moving legal requirements.

Drawing on our deep experience in election and political law, public…

Continue Reading Covington Launches Election Year Toolkit

An election year brings ample opportunities for corporations to participate in the political process, and the current political environment can create enormous pressures to do so. But with these opportunities and pressures come legal risks and compliance burdens. Given the differing and complex rules across jurisdictions, companies should be aware…

Continue Reading The 6 Top Compliance Mistakes by Corporations in an Election Year

With redistricting, the “billionaire tax” and other ballot measures, and heated gubernatorial and other races, contributors are giving huge amounts of money this year in California state and local elections.  California has a complex campaign finance system, and it can be easy to miss some of the requirements.  Key among…

Continue Reading Don’t Forget Your California Major Donor Reports!

Covington is pleased to announce that it has revised and updated its comprehensive 50-state survey of political laws for 2026.

Corporations, trade associations, non-profits, other organizations, and individuals face significant penalties and reputational harm if they violate federal or state laws governing corporate and personal political activities, the registration of…

Continue Reading Covington Announces Political Law Survey (2026 Edition)

Covington is pleased to announce that it has revised and updated its comprehensive 50-state survey of pay-to-play laws for 2026.

Companies doing business with the federal government or state and local governments and companies operating in regulated industries are subject to a dizzying array of “pay-to-play” rules. These rules effectively…

Continue Reading Covington Announces Pay-to-Play Survey (2026 Edition)