Ki P. Hong
Ki P. Hong advises major corporations on the unique political law issues they face when engaging in government affairs or government procurement activity. These include federal and state campaign finance, lobbying, gift, ethics and conflict-of-interest laws. He also advises clients on pay-to-play laws that impose special restrictions on the political activity of companies that have or seek government contracts, as well as their covered employees. He advises clients on establishing and maintaining comprehensive systems to ensure compliance with those laws. In addition, he represents clients at the enforcement stage.
Mr. Hong’s clients include companies from a wide range of different industries. He represents the “Big Four” accounting firms and leaders in other industries, such as technology, energy, media, insurance and communications. He also represents nine of the top 10 U.S. banks and nearly all of Wall Street.
Mr. Hong is well-regarded for his experience with state and federal pay-to-play laws. Such laws include MSRB Rules G-37/G-38 as well as proposed Rule G-42 for municipal advisers. He also advises clients on implementing Dodd-Frank’s definition and regulation of municipal advisers. He has extensive experience in SEC Rule 206(4)-5 for investment advisers and drafted model policies and procedures to address this Rule that have become the industry standard. Mr. Hong also advises clients on the pay-to-play provisions within CFTC Rule 23.451 covering swap dealers and major swap participants.
He also has extensive experience advising clients on election, lobbying and government ethics laws. Mr. Hong routinely represents clients before federal enforcement agencies such as the Federal Election Commission, and he works with the House and Senate Ethics Committees, the Office of Congressional Ethics and the Office of Government Ethics. He also works frequently with various state ethics commissions around the country. He advises clients on state laws that require government contractors and investment advisers to register as lobbyists.
Mr. Hong regularly counsels major corporations on inquiries and proxy proposals issued by shareholder groups regarding transparency in corporate political spending and lobbying activities.
Mr. Hong served on the steering committee of the Council on Government Ethics Laws (COGEL), an association of the federal and state government agencies that implement and enforce campaign finance and ethics laws throughout the United States and Canada. Mr. Hong is the first attorney in private practice to be elected to the steering committee in COGEL’s history.
Mr. Hong co-authored the Ethics Handbook for Entertaining and Lobbying Public Officials, which was first published in 1994 and continues to be updated for subscribers. He co-authored several chapters of the Practicing Law Institute’s publication “Corporate Political Activities” for every edition of the publication since 1993. He also co-authors the Institute’s “Corporate Political Activities Deskbook.”
Mr. Hong is a regular speaker at conferences, such as those organized by the Practising Law Institute, the Investment Adviser Association and the Securities Industry and Financial Markets Association. He also is a main speaker at an all-day seminar that he organizes every year, having completed the 18th annual seminar with more than 270 attendees in May 2012. He consistently has been selected for inclusion in Chambers USA: America’s Leading Lawyers for Business, and Washingtonian Magazine repeatedly has recognized him as a top lawyer in the field of ethics and election law.
J.D., Harvard Law School, 1992 (cum laude)
B.A., Cornell University, 1989 (cum laude)
“Corporate Political Activities Deskbook,” Practising Law Institute, 2012
"The SEC's New Pay-to-Play Rule for Investment Advisers," (co-author), The Review of Securities & Commodities Regulation, Volume 43, 2010
"Corporate Political Activities: Complying with Campaign Finance, Lobbying & Ethics Laws" (select chapters), Practising Law Institute, 1993-2009
"Political Organizations Get a Break as Congress Eases Tax Filing Requirements," Impact, January 2003
Stanford Law & Policy Review, "The Criminal and Civil Enforcement of Campaign Finance Laws," (co-author), Volume 10 / 1, Fall 1998