Compliance Notes - Vol. 7, Issue 16

RECENT LOBBYING, ETHICS & CAMPAIGN FINANCE UPDATES

Campaign Finance & Lobbying Compliance

Congressional candidate and entrepreneur Michael Carbonara has invested roughly $2.2 million in campaign funds into cryptocurrency, an unconventional strategy that has generated substantial gains while raising questions about self-dealing. The campaign paid at least $21,000 in transaction fees to Ibanera, a financial technology company Carbonara previously led as CEO, prompting scrutiny over whether cryptocurrency investing constitutes a necessary campaign expense and whether the fees reflected fair-market value. Carbonara has defended the approach as consistent with his support for digital assets and noted that campaigns can earn investment income on idle funds. The crypto activity also has inflated the campaign's reported receipts, with approximately $2 million effectively counted twice when funds were converted back from cryptocurrency holdings. (Claire Heddles, Miami Herald)