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Federal Lobby Reporting Changes: You Need to Know JACK

Lobbyists registered under the Lobbying Disclosure Act (LDA) are now required to disclose federal and state convictions of certain crimes. Under the "Justice Against Corruption on K Street Act of 2018," or "JACK Act," lobbyist registrants filing Form LD-1, and quarterly filers of Form LD-2 lobbying activity reports are required to disclose whether any of the listed lobbyists have been convicted of offenses involving bribery, extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering.

This past weekend, the House Clerk and Secretary of the Senate updated the lobbying disclosure forms to implement the law, effective with the first quarter lobby reports of 2019. The first quarter reports are due on April 22. For each lobbyist that has been convicted of one of the "predicate offenses" listed above, the reports require:

  • the date of the conviction;
  • the jurisdiction of the offense (federal judicial district, or specific county/municipal jurisdiction); and
  • either a reference to the predicate offense(s) or the code section(s) under which the lobbyist was convicted, including the number of counts for each.

This information must appear on every subsequent report on which that lobbyist is listed.

Although the vast majority of lobbyists will never have anything to report, it is still important to take this new requirement seriously. Lobbyist registrants should specifically ask each of the lobbyists they are listing, and their outside consultants, whether they have any reportable convictions. Making false statements on LDA filings or omitting information required to be reported may be a violation of the law by the lobbyist registrant.

Copyright © by Ballard Spahr LLP


About this Author

Kate A. Belinski Political and election lawyer Ballard Spahr

Kate Belinski practices political and election law with a focus on lobbying and public policy, campaign finance, government ethics, and matters involving administrative law. Kate's clients include corporations, trade associations, other nonprofit organizations, advocacy groups, as well as PACs, Super PACs, other political committees, candidates, and officeholders. She counsels numerous members of Congress and their staffs on legal and financial disclosure obligations under the Ethics in Government Act and represents them before the House and Senate Ethics Committees.

Timothy Jenkins Finance Attorney Ballard Spahr

Timothy Jenkins is nationally recognized for his work advising clients on all aspects of political law. He represents leading U.S. companies nationwide on federal, state, and local gift rules, lobbying registration and election law, pay-to-play provisions, the Foreign Corrupt Practices Act, and the Foreign Agents Registration Act.

Tim has more than 30 years' experience representing clients before Congress, presidential administration officials, and federal regulatory agencies. He serves as a lobbyist for prominent trade associations and major corporations, with an emphasis on the financial services, health care, and pharmaceutical industries.

Prior to attending law school, Tim worked as a congressional staffer, serving as an investigator for the Senate Labor and Human Resources Committee as well as the Senate Government Affairs Committee. Tim leverages this congressional background along with three decades of legal experience and an extensive network of contacts within Congress, the administration, and the federal government to provide effective, efficient strategic advice to his clients.