Joan P. Sullivan, leader of the Government Compliance and Investigations Practice Group and a Certified Compliance and Ethics Professional(CCEP), was featured in the January 2020 issue of ethikos, a publication from the Society of Corporate Compliance and Ethics (SCCE). In the interview for the article, Joan discusses lobbying compliance topics such as: What constitutes lobbying, what triggers the various government requirements, and what organizations should be doing from an auditing and monitoring perspective to ensure that they are tracking their interactions with government officials.
Joan explains that lobbying can occur anywhere by ordinary employees. Whether an activity is “reportable lobbying” and what is required will depend upon the jurisdiction in which the organization is operating (i.e. federal, state, local) and it can be quite technical, along with many exceptions to consider. When certain thresholds are met, registering as an in-house lobbyist may be required, and there are additional reporting requirements. Disclosure and transparency are critical elements in the mix. Making an unsolicited telephone call to a public official could be construed as lobbying and taking officials to lunch may run afoul of gift laws for lobbyists. These are just a few of the numerous types of questions and individual circumstances that can be answered in periodic live training sessions to make sure employees and organizations are compliant. If an organization is unsure if it should register as a lobbyist, it is recommended that the employees who interact with government officials be identified and have them record their activities for monitoring purposes.
Additionally, Joan covers the risks associated with hiring former government officials and advises the organization and the individual of what the potential hire can and cannot do on behalf of the organization, and if any ethical walls or recusal protocols may be needed.
Read Joan’s full interview on lobbying compliance http://bit.ly/2vdKPg0
Copyright 2020 ethikos, a publication of the Society of Corporate Compliance and Ethics (SCCE).