Compliance Notes - Vol. 7, Issue 19
RECENT LOBBYING, ETHICS & CAMPAIGN FINANCE UPDATES
Campaign Finance & Lobbying Compliance
Tennessee: State Senator Charlane Oliver plans to introduce legislation in January 2027 that would prohibit corporations, labor unions and other organizations from making political expenditures in Tennessee as a condition of obtaining a state business license. The proposal mirrors a law enacted in Hawaii and a similar measure set to appear on Montana’s November 3, 2026 ballot and reflects a broader effort to limit corporate and "dark money" spending in elections following the Supreme Court’s 2010 Citizens United decision, which permitted corporations, labor unions and other organizations to make unlimited independent expenditures in support of or opposition to political candidates. (Adam Friedman, Tennessee Lookout)
Government Ethics & Transparency
On September 15, 2026, the Senate voted 49-50 against advancing the Digital Asset Market Clarity Act, legislation that would have created a federal regulatory framework for the $2.3 trillion cryptocurrency industry. The vote followed negotiations over ethics restrictions related to President Donald Trump’s and his family’s cryptocurrency holdings and business interests. Although Trump agreed to additional restrictions, including limits on federal elected officials issuing digital assets and expanded enforcement authority for state attorneys general, Democrats maintained that the proposal lacked sufficient ethics safeguards and unsuccessfully sought a requirement that presidents divest certain cryptocurrency holdings once they exceed a specified value. (Mary Clare Jalonick, Associated Press)
California: Governor Gavin Newsom signed Assembly Bill 1130 on September 19, 2026, allowing authorities to impose administrative, civil and criminal penalties against social media influencers who fail to disclose when they are paid by political campaigns to post political content. Although California law already requires disclosure of paid political advertising, the measure adds enforcement mechanisms under the Political Reform Act. The legislation follows controversy surrounding Tom Steyer’s gubernatorial campaign, after reports that paid influencers posted political advertisements without disclosing that they were compensated by Steyer’s campaign, prompting a complaint to the Fair Political Practices Commission. (Doha Madani, NBC News)
Montana: On September 16, 2026, a federal judge blocked Montana officials from enforcing the state’s artificial intelligence campaign advertising law against former state legislator Dan Bartel and the Accountability in State Government Political Action Committee, finding that the restrictions raise First Amendment concerns. The law prohibits the use of artificial intelligence-generated campaign content that misrepresents a candidate or political party within 60 days of an election unless the communication includes a disclosure that the content has been materially altered by artificial intelligence. United States District Judge Susan Watters found that Bartel and the committee faced a credible threat of enforcement under the law. The ruling allows the committee to use its planned general election advertising while the case proceeds ahead of the November election. (Tom Lutey, Montana Free Press)
We read the news, cut through the noise and provide you the notes.
Compliance Notes from Nossaman’s Government Relations & Regulation Group is a periodic digest of the headlines, statutory and regulatory changes and court cases involving campaign finance, lobbying compliance, election law and government ethics issues at the federal, state and local level. Our attorneys, policy advisors and compliance consultants are available to discuss any questions or how specific issues may impact your business. If there is a particular subject or jurisdiction you’d like to see covered, please let us know.