Zachary G. Parks

Zachary G. Parks

Zachary Park advises a wide range of corporate and political clients on federal and state campaign finance, lobbying disclosure, pay to play, and government ethics laws. Mr. Parks regularly advises corporations and corporate executives on instituting political law compliance programs and conducts compliance training for senior corporate executives and lobbyists. He also has extensive experience conducting corporate internal investigations concerning campaign finance and lobbying law compliance and has defended clients in investigations by the Federal Election Commission, the U.S. Department of Justice, and the House Oversight & Government Reform Committee.

Subscribe to all posts by Zachary G. Parks

Covington Publishes Comprehensive Advisory Comparing Trump and Obama Executive Orders on Ethics

President Donald Trump this weekend signed his promised “drain the swamp” Executive Order, which imposes ethics restrictions on incoming and outgoing Trump Administration appointees. Incoming appointees would, of course, do well to carefully review the provisions of the Executive Order. But companies that deal with the Administration—whether by lobbying the executive branch, by seeing a … Continue Reading

New Year, New Gift Rules for the Federal Executive Branch

Corporations, trade associations, and others who interact with federal executive branch employees should be aware of the Office of Government Ethics’ (OGE) recent amendments to the executive branch gift rules, which go into effect on January 1, 2017. Seeking to encourage transparency and advance public confidence in the integrity of federal officials, OGE redefined some … Continue Reading

The 2017 Presidential Inauguration: Ethics and Compliance Issues

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

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

New Report Calls Out Corporate Political Disclosure “Basement Dwellers”

A report published today criticizes companies that refuse to disclose information about their political spending on their websites.  The non-profit Center for Political Accountability and the Zicklin School at Wharton annually rank all companies in the S&P 500 on their political disclosure practices, based on a 70-point metric.  The more information companies disclose on their … Continue Reading

Have We Reached A FARA “Tipping Point”?

The New York Times, earlier this month, reported that “secret ledgers” in Ukraine show $12.7 million in cash payments designated for former Donald Trump campaign chairman Paul Manafort from Ukraine’s pro-Russian political party. Days later, the Associated Press reported that Manafort helped the pro-Russian party “secretly route at least $2.2 million in payments to two prominent Washington lobbying … Continue Reading

The Supreme Court Redraws the Lines for Corruption Prosecutions

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

New Overtime Rules May Spell Trouble For Some Corporate PACs

The Obama Administration’s publication yesterday of a regulation increasing the universe of employees entitled to overtime pay might reduce the number of employees from whom corporate PACs can seek contributions. The new regulations, which take effect on December 1, 2016, increase the salary level below which certain employees are entitled to overtime pay.  Currently, salaried … Continue Reading

SEC Issues Fines for Pay-to-Play Violations That Predate Its Pay-to-Play Rule

A $12 million settlement announced last week by the Securities & Exchange Commission suggests that the SEC will aggressively pursue alleged schemes connecting political contributions to government contracts even if the political contributions do not violate its 2010 pay-to-play rule.  According to the settlement order, in 2010, the head of Public Funds at State Street … Continue Reading

Congressional Spending Bill Shuts Down Key Goals of Campaign Finance Reform Community

A major spending bill posted late last night by Congressional leaders contains provisions shooting down two key initiatives of the campaign finance reform community.  Stymied by a Federal Election Commission that has increasingly struggled to find consensus, campaign finance activists in recent years have turned their attention to other federal regulators, pressing those regulators to … Continue Reading

SEC Fines Should Prompt Firms Engaged in Political Intelligence To Revisit Insider Trading Policies

In a rare move, the Securities & Exchange Commission has assessed penalties against a political intelligence firm for failing to adopt adequate policies to prevent the flow of inside governmental information to the firm’s clients.  The enforcement action is particularly noteworthy because all the factual allegations took place in 2010, before Congress passed the STOCK … Continue Reading

Will President Obama’s New Overtime Regulations Shrink Corporate Restricted Classes?

Corporate PAC managers may soon find that the universe of employees who receive corporate PAC solicitations has unexpectedly shrunk.  In July 2015, the Department of Labor proposed new regulations that would dramatically increase the number of workers entitled to overtime wages.  The Department of Labor estimates that, under the new regulations, approximately 5 million new … Continue Reading

New Report Adds Pressure For Public Companies to Voluntarily Disclose Political Spending

A report published today by the Center for Political Accountability will result in more pressure on public companies to voluntarily disclose information about their political spending. Each year, CPA in collaboration with the Zicklin Center at the University of Pennsylvania issues a detailed report “scoring” companies on their corporate political disclosure practices according to a … Continue Reading

What’s Next for the SEC Pay-to-Play Rule Challenge?

Yesterday’s D.C. Circuit opinion upholding the SEC’s burdensome “pay-to-play” rule on procedural grounds is bad news for those questioning the rule’s constitutionality.  Nevertheless, the rule is still far from invincible. The SEC pay-to-play rule, among other things, effectively prohibits investment firm executives from making certain political contributions to state and local officeholders and candidates.  Last … Continue Reading

New Insights on FARA Enforcement Emerge from DOJ Letter to Sen. Grassley

In a recent letter to Sen. Chuck Grassley (R-Iowa), the Department of Justice offered a rare public glimpse into the enforcement activities of the small unit in the Department that enforces the Foreign Agents Registration Act.  Some of the details highlighted in the letter are consistent with observations that we have shared in this blog; … Continue Reading

Pay-to-Play Law on Gov. Christie’s Desk Poses Potential Threat to National Parties

A little-noticed sentence in a bill sitting on New Jersey Governor Chris Christie’s desk could, if it becomes law, threaten to curtail the ability of national party committees to raise money from Wall Street and financial industry executives.  The Republican and Democratic Governors Associations, the Republican National Committee, the Democratic National Committee, and the federal … Continue Reading

Covington Issues Client Advisory on Bank Loans and Transactions with Candidates and Political Groups

Covington recently issued an advisory to its bank and financial institution clients explaining the rules governing their business dealings with candidates and political groups. The advisory, which is available here, deals with loans and other transactions that sometimes cause banks to run afoul of Federal Election Commission regulations or government ethics rules. While banks are … Continue Reading

FEC Increases Contribution Limits, Permitting Individuals to Contribute over $800K to National Party Committees

The Federal Election Commission has increased the limits on the amount an individual can contribute to a candidate or national political party for the 2015-2016 election cycle.  An individual can now give up to $2,700 per election to a candidate for federal office, up from $2,600.  Because the primary and general count as separate elections, individuals may now give $5,400 per candidate … Continue Reading

CPA-Zicklin Index for 2015 Expected To Rank Entire S&P 500

Covington has recently learned that, for the first time ever, the CPA-Zicklin Index, which ranks companies’ political disclosure practices, plans to issue rankings for all 500 companies in the S&P 500 Index.  This is a significant expansion of the Index, which will impact many public companies that have not previously been subject to intense scrutiny … Continue Reading

Covington Releases How-To Guide For Responding To Corporate Political Disclosure Initiatives

Covington today released a client advisory providing best practices to assist in-house counsel of publicly-traded companies in responding to corporate political disclosure initiatives.  These initiatives aim to force companies to post to their websites more information regarding corporate political activities, such as details regarding corporate contributions to trade associations and 501(c)(4) social welfare organizations.  Despite … Continue Reading

The SEC Pay-to-Play Rule Year in Review

When the history of the Securities & Exchange Commission’s pay-to-play rule is written, 2014 could be the inflection point.  Developments this year suggest two dramatically different paths for the rule in the years to come: either the rule will unravel from court challenges or it will become an increasingly prominent enforcement weapon in the SEC’s … Continue Reading

MSRB Advances Expanded Pay-to-Play Rule Covering Municipal Advisors

For two decades, municipal securities dealers have been subject to Municipal Securities Rulemaking Board (“MSRB”) rule G-37 which bars them from receiving state and local business for two years after certain political contributions are made by the dealers and individuals affiliated with them.  Earlier this week, the MSRB advanced amendments to rule G-37 that would … Continue Reading

Lobbyists Can Now Sit on Some Federal Advisory Committees: Here’s How to Find Out Where

In a significant reversal by the Obama administration, lobbyists will now be permitted to serve on federal advisory committees, boards, and commissions after more than four years of sitting on the advisory committee sidelines.  In guidance published in the Federal Register today, the Office of Management and Budget (“OMB”) quietly revised, in large part, the … Continue Reading

SEC Announces Major Fines In First Pay-to-Play Enforcement Case

The Securities & Exchange Commission hit a Philadelphia-area private equity firm today with a major penalty, in the SEC’s first case involving alleged violations of its 2010 “pay-to-play” rules.  More enforcement actions may be coming. The SEC pay-to-play rules were adopted to prevent, among other things, executives of investment firms from making political contributions in … Continue Reading
LexBlog