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

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.
California Poised to Adopt Campaign Contribution Limits for City and County Elections
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…
New Jersey, Colorado Join Growing List of States Regulating “Dark Money”
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…
California Social Media DISCLOSE Act Becomes Law, Takes Effect 2020
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…
California’s New “Social Media DISCLOSE Act” Regulates Social Media Companies, Search Engines, Other Online Advertising Outlets, and Political Advertisers
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…
Colorado Enacts Replacement Campaign Finance Enforcement System
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…
Colorado Campaign Finance Enforcement System Found Unconstitutional
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…
Fight Against Sexual Misconduct Bringing Regulations, Protections for Lobbyists
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…
California Gov. Brown Signs California DISCLOSE Act into Law
On Saturday, California Gov. Jerry Brown signed the California DISCLOSE Act, AB249, into law. We posted a detailed analysis of the law when it passed the legislature, but the key points bear repeating as it will be of interest to anyone who gives or spends money in California elections.
The law requires that some…
St. Petersburg Passes Anti-Super PAC Ordinance, Hoping to Set Up Constitutional Showdown
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…