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 No. 2 (Investigation and Enforcement Proceedings), 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 FY2024 investigation and enforcement activity. The data below does not reflect the total number of active investigations as of the end of FY2024.

The following tables summarize the Board’s investigation and enforcement activity stemming from complaints in FY2024.

The following tables summarize the Board’s investigation and enforcement activity stemming from referrals from other governmental agencies in FY2024.

The following tables summarize the Board’s investigation and enforcement activity in FY2024 stemming from the Executive Director’s initiative.

The following tables summarize the disposition of matters that were pending as of the end of FY2023.

In FY2024, the Board approved three settlement agreements:

• Brahin Behlin (January 22, 2024): Resolving violations of Philadelphia’s Conflict of Interest Law for engaging in a matter within his official responsibilities in which he also held a financial interest. Brahin Behlin has paid $250 in civil monetary penalties.

• Saterria Kersey (February 21, 2024): Resolving violations of Philadelphia Home Rule Charter Section 10-107(4) for engaging in certain political activities while a City employee; specifically, circulating and soliciting signatures for nominating petitions for a Pennsylvania House candidate and serving as the chairperson of the candidate’s designated political committee. Saterria Kersey has paid $600 in civil monetary penalties. 

• Jannie Blackwell (April 18, 2024): Resolving political activity violations of Philadelphia Home Rule Charter Section 10-107(4)(d) and Board of Ethics Regulation 8.3 for providing a platform to candidates for elective office and promoting their candidacies while on duty and in City Hall. Ms. Blackwell has paid $2,000 in civil monetary penalties.

Parties in FY2024 paid a total of $2,850 in civil monetary penalties. 

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

In FY2023, the Board initiated judicial enforcement in the Philadelphia Court of Common Pleas against For a Better Philadelphia 501(c)(4) and For a Better Philadelphia PAC for alleged campaign finance violations. The Court ruled in favor of both Defendants on September 11, 2023. The Board filed a notice of appeal of the Court’s decision to the Pennsylvania Commonwealth Court on October 10, 2023. The Board withdrew its appeal on December 19, 2023. Defendants and two individuals filed a lawsuit against the Board and the Executive Director on January 29, 2024, related in part to the Board's underlying enforcement action. That litigation is ongoing at the time of this report.