Tag Archives: sua sponte

FEC Issues Zero Tolerance Decision on Foreign National Contributions

In a little noticed decision earlier this month, the FEC announced the settlement of an enforcement case that sets a compliance standard that few companies may currently meet.  FEC ADR Case 708 (Marsh & McLennan Companies, Inc. PAC).  The outcome is even more surprising because the case involved a single errant donor the company brought … Continue Reading

A Vote on FEC Enforcement

The Federal Election Commission made public two versions of its Enforcement Manual today, one based on current practices for handling the agency’s enforcement docket, and one proposing a dramatic shift in how cases could be handled in the future.  The choice between the two versions may be up for discussion at the agency’s next open … Continue Reading

The Dangers of Sua Sponte

Yesterday’s guilty pleas in the Danielczyk criminal trial leaves open an important question that campaign finance practitioners must consider closely going forward: when does the government consider a sua sponte submission itself to constitute a criminal violation, and seek to compel counsel to become a witness against their client?  As BNA first reported, the Justice … Continue Reading
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