California’s political watchdog organization is slapping former Assemblyman Evan Low with a $106,000 fine for 23 counts of violating state campaign finance laws — allegations that include using his tech nonprofit to pay actor Alec Baldwin more than $227,000 to appear at an event for the group and a fundraiser for Low, which investigators said he tried to conceal.

The decision, which must be approved by the California Fair Political Practices Commission at its April 10 meeting, wraps up a five-year investigation prompted by a CalMatters article that alleged Low failed to file payment reports for donations he solicited for his nonprofit, the Foundation for California’s Technology and Innovation Economy, in a timely manner. The state’s Political Reform Act, which regulates campaign finance and seeks to provide more transparency around elections, requires elected officials to disclose payments of $5,000 or more made at their request within 30 days.

In the course of its investigation, the FPPC found that Low failed to report 16 of these payments, totaling $227,500 — made to the Foundation for California’s Technology and Innovation Economy, the California Legislative LGBT Foundation and Equality California — within that time frame. The disclosures were filed between five and 528 days late.

“Payments made at the behest of elected officials, including charitable donations, are a means by which donors may seek to gain favor with elected officials,” Angela Brereton, the FPPC’s assistant chief of enforcement, and Jenna Rinehart, the agency’s senior commission counsel, wrote in the decision. “Timely reporting of such activity serves to increase public awareness regarding potential attempts to influence in this manner. There is inherent public harm in non-disclosure, because the public is deprived of important information that the Act mandates must be timely disclosed.”

Low served in the state assembly from 2012 to 2024 where he represented parts of Silicon Valley — he failed to disclose payments between Feb. 9, 2018 and March 17, 2020. The former assemblyman, who made an unsuccessful bid for Congress last year, most recently took a job as the president and CEO of the LGBTQ+ Victory Institute and the LGBTQ+ Victory Fund.

Low and his attorney, Amber Maltbie of Nossaman LLP, did not respond to a request for comment.

At the center of the investigation is a $220,000 speaking fee paid to Baldwin, along with other accommodations including a $4,499 first-class airfare bill, a $724 one-night stay at the former Fairmont hotel in downtown San Jose and a nearly $1,500 limousine rental to transport the actor around Silicon Valley.

In October 2019, Danielle Sires, a consultant for the tech foundation and an assembly committee that Low chaired, reached out to the Creative Artists Agency to book Baldwin to speak at the foundation’s February 2020 tech summit, as well as a Lunar New Year’s celebration that doubled as a fundraiser for Low’s reelection bid.

In a Jan. 4, 2020, social media post on X, formerly known as Twitter, Low said the celebration would include a “surprise celebrity guest.”

“For the Year of the Rat, expect big surprises and a big name,” he wrote. “You won’t want to miss out on this special ‘presidential-esque’ event!”

The post was accompanied by a photo of Low with former presidential candidate Al Gore. Baldwin was playing President Donald Trump on “Saturday Night Live” at the time of the fundraiser.

A few weeks after Sires’ initial email, the CAA sent back a contract for Baldwin to appear at both events. The consultant responded asking if there was a way to have the Lunar New Year event “in a separate contract stating that option is voluntary,” the FPPC found.

“So two separate contracts but all the money under one? But its(sic) not voluntary. If he doesn’t do it, he would still be paid his full fee,” an unnamed representative for CAA wrote in an email to Sires. “That doesn’t work in your favor to include the voluntary part.”

The two parties eventually agreed on two contracts, with the first stating that Baldwin was required to appear at both events and the second contract marking the $220,000 fee as a “voluntary appearance,” according to the FPPC.

“The Enforcement Division contends the communications and multiple contracts evidence an intent to conceal the portions of the agreement pertaining to the Lunar Event,” Brereton and Rinehart wrote.

The Foundation for California’s Technology and Innovation Economy ultimately paid $227,049 for Baldwin to appear at both the tech summit and Low’s Lunar New Year fundraiser. The FPPC determined that the actor’s time was split evenly between the events, which means that Low and his 2020 state assembly committee were required to discloses half of those expenses, roughly $113,524.

Low initially told investigators that Baldwin appeared at the Lunar New Year fundraiser on his “own accord.” But earlier this year, the FPPC said he recanted, and admitted that he failed to disclose the payments on his campaign committee reports on time. Low and the committee were also unable to provide any records, bills or receipts for those expenses, according to the FPPC.

As a part of the settlement, Low has paid back the expenses to the foundation, which was noted in a March 28 filing. The money came from a Low for State Controller 2030 committee that was set up on March 11.

Sean McMorris, the transparency, ethics and accountability program manager for good government group California Common Cause, called “behested” payments — those made at the request of an elected official — a “loophole for special interests to curry favor with politicians they need votes from.” He said they’re essentially unregulated so disclosure is the only mechanism of transparency that the law offers.

“When you try to skirt that transparency aspect, it deprives the public of knowledge,” he said in an interview with Bay Area News Group.

McMorris said he thought the fine was “appropriate” and “sends a strong message of deterrence for people who think about doing it in the future.” One thing that concerns him though, is that individuals who are fined by the FPPC can pay the fine using money they’ve raised over the course of their campaign.

“You’re essentially allowing a bad actor who used the money of others to do this thing to essentially go to these same donors and utilize the money to pay off any fines that they incurred because of their bad behavior,” he said. “I don’t think that’s right, but that’s just the way the law is.”

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