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 is required to 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 the 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 is ongoing, a person (e.g., a witness, complainant, subject, etc.) may not disclose any information or documents related to the investigation learned or obtained solely from the Board or Board Staff (unless subject to certain exceptions articulated in Board Regulation 2, Subpart D). Once the investigation 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 FY2023 Investigation and Enforcement Activity.

The following tables summarize the Board’s investigation and enforcement activity stemming from complaints in FY2023.

The following tables summarize the Board’s investigation and enforcement activity stemming from referrals from other governmental agencies in FY2023.

The following tables summarize the Board’s investigation and enforcement activity in FY2023 stemming from the Executive Director’s initiative.

In FY2023, the Board approved four settlement agreements:

• Councilmember Kenyatta Johnson (December 21, 2022): Resolving violations of Philadelphia’s Financial Disclosure Law for omissions in Statements of Financial Interests filed with the Board.  Councilmember Johnson agreed to pay $2,000 in civil monetary penalties.

• Allan Domb (December 21, 2022): Resolving violations of Philadelphia’s Public Disclosure Law for not disclosing the nature and extent of a financial interest in legislation. Allan Domb agreed to pay $2,000 in civil monetary penalties.

• Tariq El-Shabazz (February 22, 2023): Resolving violations of Philadelphia Code § 20-602 (Representation by City Officers, Employees, and Members of Council) for representing criminal defendants in cases prosecuted by the Philadelphia District Attorney. Tariq El-Shabazz agreed to pay $16,000 in civil monetary penalties.

• CBL Real Estate, LLC (June 5, 2023): Resolving lobbying violations of Philadelphia Code § 20-1203 (Reporting) for failing to disclose the subject matter of direct communications with City officials. CBL Real Estate, LLC agreed to pay $4,000 in civil monetary penalties.

Parties in FY2023 agreed to pay a total of $24,000 in civil monetary penalties. 

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 pursue enforcement of alleged violations of the City’s Public Integrity Laws through either an administrative adjudication or judicially in the Philadelphia Court of Common Pleas.

On April 10, 2023, the Board filed an Emergency Petition in the Court of Common Pleas against Defendants For a Better Philadelphia PAC and For a Better Philadelphia 501(c)(4) to enforce the City’s annual campaign contribution limits and to enjoin continuing violations thereof. The Petition alleged that the Defendants’ expenditures to influence the outcome of the 2023 Philadelphia Mayoral election in support of a candidate who had solicited funds for and directed funds to the Defendants constituted in-kind contributions to that candidate’s campaign under Board Regulation 1.33(d). Accordingly, the Petition further alleged that these contributions exceeded the annual limits in 2022 and 2023. The Court issued an order that same day enjoining the Defendants from making new expenditures to influence the outcome of the May 2023 Philadelphia Mayoral Primary Election. The Court also ordered the Board to file a Complaint in this matter, whereupon its Emergency Petition would be converted into a Motion for Permanent Injunction.

The Board then filed the Complaint on April 14, 2023. On April 24, 2023, the parties entered into a joint Stipulation and Order by Agreement, in which the Defendants, in part, agreed to cease making further expenditures to influence the outcome of the 2023 Mayoral Primary and General Elections that advocate for the election or defeat of any particular candidate, that reference a particular office, or that contain campaign slogans of any particular campaign. The Defendants also agreed to refrain from delivering any further materials to the electorate resulting from expenditures made to influence the outcome of the 2023 Philadelphia Mayoral Primary and General Elections. The Board agreed to withdraw its Motion for Permanent Injunction.