In the last days of August, Goldman Sachs surprised its employees with a new rule: the firm's top employees will be barred from donating to certain political campaigns, including that of Trump-Pence.
In a memo sent out on August 29, the firm's global compliance office said that starting on September 1, "all partners across the firm are considered “Restricted Persons” as defined by the firm’s Policy on Personal Political Activities in the US." This means that as of this moment, Goldman's partners are "prohibited from engaging in political activities and/or making campaign contributions to candidates running for state and local offices, as well as sitting state and local officials running for federal office", and specifically donating to the Donald Trump campaign, in order to "minimize potential reputational damage."
The memo conveniently provides the following example of the type of political activity that is barred, among others:
Any federal candidate who is a sitting state or local official (e.g., governor running for president or vice president, such as the Trump/Pence ticket, or mayor running for Congress), including their Political Action Committees (PACs).
As Fortune, which first obtained the memo reported, said that Goldman's new rule was meant to remove any implication of so-called “pay to play.” Four years ago Goldman bank paid $12 million to settle charges that a former Boston-based banker had picked up bond underwriting business in the state while working for and contributing funds to the campaign of a then Massachusetts state treasurer and governor-hopeful, Tim Cahill.
Pay-to-play rules were first introduced by the Securities and Exchange Commission in 2010, after several investment advisors were accused of trying to win business, such as managing public pensions, with improper tactics including political contributions. If a financial advisor were to make a campaign contribution to a public official or candidate, they would be banned from providing advisory services for compensation to the government client for two years under the rules.
Goldman explains that "the policy change is also meant to minimize potential reputational damage caused by any false perception that the firm is attempting to circumvent pay-to-play rules, particularly given partners’ seniority and visibility," adding that “all failures to pre-clear political activities as outlined below are taken seriously and violations may result in disciplinary action."
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