Committee considers raising threshold on foreign‑national certification in campaign finance

State Government, Tribal Affairs, and Elections Committee · February 20, 2026

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Summary

HB 2123 would set a $6,000 threshold (adjustable) before campaigns must collect certifications that contributions are not financed or directed by foreign nationals; PDC staff described the certification's gatekeeping role, while campaign treasurers called the rule administratively burdensome and ineffective.

The committee took testimony on House Bill 2123, which would require candidates and political committees to collect a certification that contributions are not financed or directed by foreign nationals only when an entity contributes more than $6,000 in the aggregate (threshold adjustable by the Public Disclosure Commission).

Sean Flynn, general counsel for the Public Disclosure Commission, explained the current certification serves two functions: to notify potential donors about prohibitions and to provide a gatekeeping mechanism so campaigns do not unintentionally accept foreign‑sourced money. Flynn said removing the certification risks weakening that gatekeeping and complicates enforcement.

Campaign treasurers and compliance professionals disagreed. Jace Michaud and Connor Edwards said the certification is largely an honor system that imposes significant administrative burdens without evidence of foreign influence in Washington elections; they urged repeal or a higher threshold. Several practitioners said the PDC could offer an alternative registration method but that PDC staff historically resisted that approach. Other testifiers warned a $6,000 threshold could be exploited by foreign actors using straw entities to route contributions below reporting thresholds.

Staff and members discussed tradeoffs between administrative burden and gatekeeping. No committee vote occurred at the hearing.