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 FY2021 Investigation and Enforcement Activity.

The following table summarizes the Board’s investigation and enforcement activity stemming from complaints received from the public in FY2021.

The following table summarizes the Board’s investigation and enforcement activity stemming from referrals from other governmental agencies in FY2021.

The following table summarizes the Board’s investigation and enforcement activity in FY2021 stemming from the Executive Director’s initiative.

In FY2021, the Board approved four settlement agreements:

• Taubenberger for Philadelphia (Jan. 20, 2021): Resolving violations of Philadelphia’s Campaign Finance Law for failing to disclose $32,000 in unpaid accruing debt on six of its 2019 campaign finance reports. Taubenberger for Philadelphia agreed to pay $2,000 in civil monetary penalties within 30 days of the execution of the settlement and amended all reports to correctly reflect the accruing debt.

• William Stewart Graham (Jan. 20, 2021): Resolving violations of the Home Rule Charter for participating in prohibited political activity – specifically organizing and coordinating campaign fundraisers – while serving as Councilmember Oh’s Chief of Staff. Mr. Graham agreed to pay $2,400 in civil monetary penalties due within 30 days of the execution of the settlement.

• The Honorable Anthony Hardy Williams, Williams for Mayor, and Paula Wright (Feb. 17, 2021): Resolving violations of Philadelphia’s Campaign Finance Law for failing to exclude $12,983.50 in excess pre-candidacy contributions; accepting $27,000 in excess contributions; and failing to disclose three in-kind contributions during the 24-Hour reporting period. Senator Williams agreed to pay a civil monetary penalty of $2,000. Williams for Mayor agreed to pay $12,000 in civil monetary penalties and to disgorge $39,983.50 in excess pre-candidacy and excess contributions.

• Protect Our Police PAC and Nicholas Gerace (Jun. 16, 2021): Resolving violations of seven late-filed Campaign Finance Reports during the 2021 Primary season in violation of Philadelphia’s Campaign Finance Law. Protect Our Police PAC and Nicholas Gerace agreed to pay a cumulative civil monetary penalty of $12,000 due within 30 days of the effective date of the agreement.

In total, parties in FY2021 agreed to pay a total of $30,400 in civil monetary penalties. In addition, in FY2021, parties to settlement agreements concerning excess contributions accepted by candidates for City elective office agreed to disgorge to the City $39,983.50.

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

In FY2017, the Board implemented procedures to efficiently resolve violations arising from the late filing of campaign finance reports with the Board. The procedures expedite and simplify the assessment of penalties for the late filing of campaign finance reports, except in certain delineated cases. Descriptions of the procedures can be found on the Board’s website.

In FY2021, Board Enforcement Staff used these procedures to collect $1,500 for the City from four filers that did not timely file campaign finance reports with the Board in 2021 Cycles 1 and 3 or the 24-Hour reporting period. Board Staff routinely updates the penalties information on the Board’s website, which includes late filers from FY2017-FY2021.