It’s a common scenario: An employee receives a text from a friend asking them to contribute to the campaign of a candidate the friend supports. Without thinking much about it, the employee makes a $500 contribution. Though the employee has been trained on their company’s political contributions policy, it doesn’t occur to the employee to check with compliance before contributing. But the employee’s seemingly routine political contribution could jeopardize the company’s contracts with public entities, trigger investigations, or even result in enforcement actions and substantial penalties.
As the 2026 election season accelerates, now is a good time for companies that do business with government entities to emphasize pay-to-play compliance and remind employees of the consequences that can result from their personal political contributions. In this alert, we outline pay-to-play risks, compliance measures, and common pitfalls, as well as how to prepare for the possibility of an exemption application.
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