The Board of Ethics is responsible for enforcing the City’s Public Integrity Laws and is required to include information concerning its enforcement activities in its Annual Report.

Board investigations stem from three main sources: complaints received from the public; referrals from a government agency; or from the initiative of the Board’s Executive Director. To accept a complaint for investigation, the complaint must:

• Provide the full name and address of the complainant;

• Identify the person or persons who allegedly violated the Public Integrity Laws; and

• Contain facts that describe a violation of the Public Integrity Laws, including relevant times, places, and names of witnesses, if known.

If the complaint does not meet these requirements, the Executive Director must reject it and notify the complainant of the reasons for the rejection. The complainant is free to refile their complaint at any time with additional information or to resolve the issues raised by the Executive Director’s response.

If the complaint satisfies these requirements, Board Enforcement Staff begin an investigation into the allegations. If the investigation leads to probable cause that a violation occurred, the Executive Director can initiate an administrative or judicial enforcement proceeding.

While an investigation or enforcement proceeding is ongoing, a person (i.e., anyone involved in the proceeding such as a witness, complainant, subject, etc.) may not disclose any information or documents related to the investigation – whether learned through the investigation or proceeding or obtained solely from the Board or Board Staff (unless subject to certain exceptions articulated in Board Regulation 2, Subpart D). Once either the investigation or enforcement proceeding has ended, a person may disclose any information about that investigation.

At any point, the Executive Director can seek to resolve a matter through a settlement agreement. In a settlement agreement, subjects of enforcement admit to violations and, in most cases, agree to pay a civil monetary penalty. All settlement agreements must be approved by the Board.

The following tables summarize the Board’s FY2022 Investigation and Enforcement Activity.

The following tables summarize the Board’s investigation and enforcement activity stemming from complaints in FY2022.

The following tables summarize the Board’s investigation and enforcement activity stemming from referrals from other governmental agencies in FY2022.

The following tables summarize the Board’s investigation and enforcement activity in FY2022 stemming from the Executive Director’s initiative.

In FY2022, the Board approved two settlement agreements:

• Lawrence Krasner for District Attorney, Lawrence Krasner, and Vernon Anastasio (Dec. 8, 2021): Resolving violations of Philadelphia’s Campaign Finance Law for misstatements and omissions in campaign finance reports filed with the Board as well as for spending $1,000 in excess pre-candidacy contributions. Lawrence Krasner for District Attorney has agreed to pay $10,000 in civil monetary penalties and has already disgorged to the City the $1,000 excess contribution to the City.

• Real Justice PAC and Rebecca Bond (Dec. 8, 2021): Resolving violations of Philadelphia’s Campaign Finance Law for misstatements and omissions in campaign finance reports filed with the Board. Real Justice PAC has agreed to pay $30,000 in civil monetary penalties.

In total, parties in FY2022 agreed to pay a total of $40,000 in civil monetary penalties. In addition, in FY2022, parties to settlement agreements concerning excess contributions accepted by candidates for City elective office agreed to disgorge to the City $1,000.

The Board’s settlement agreements are available on the Board’s website here.

The Board is authorized by the Philadelphia Home Rule Charter and the Philadelphia Ethics Code to conduct hearings to adjudicate alleged violations of the City’s Public Integrity Laws. The administrative enforcement process is confidential until there is a final determination issued by the Board, at which point the final determination is made public. In FY2022, the Board issued its fourth Final Determination in an administrative adjudication.

On April 25, 2022, the Board of Ethics issued its Final Determination in the matter of Creamer v. Morrison, an administrative enforcement proceeding initiated by the Board’s Executive Director in June of 2021.

The Executive Director charged that Celena Morrison, the Executive Director of the Mayor’s Office of LGBT Affairs, violated the Ethics Code by soliciting, accepting, and receiving a gift in the form of a loan. Ms. Morrison requested a hearing, which was held on December 15, 2021. The Board found that the evidence presented at the hearing did not demonstrate that a violation of the Ethics Code occurred. A copy of the Final Determination is available on the Board’s website here.