March 6, 2025
To: Members of the Ethics Commission
From: Olabisi Matthews, Director of Enforcement
Subject: Agenda Item 7: Quarterly Enforcement Report
Summary and Action Requested
This report provides general programmatic updates and data about the cases handled by the Commission’s Enforcement Division.
No action is required by the Commission, as this item is for informational purposes only.
Cases Resolved
Fiscal Year 2026
So far in Fiscal Year 2026 (July 1, 2025 – March 4, 2026), the Enforcement Division has concluded a total of 26 enforcement matters. Two additional matters are presented as proposed stipulations in agenda items 5 and 6 on this month’s Commission meeting agenda.
Cases In Progress
So far in FY26, 95 enforcement matters have been initiated. 59 of these 95 cases began from complaints that the Commission received from the public. 24 matters were initiated by the Division based on media reports, observations in public disclosures, independent research, findings from audit reports, and interactions with regulated persons. 11 matters were initiated based on referrals from the Controller’s Whistleblower Program. Some of these matters initiated in FY26 remain in progress while others have already been resolved.
In total, 29 matters are currently in progress, including matters that were initiated during FY25 and one matter initiated in FY24. Of these matters, 11 are in preliminary review, and 18 are open investigations. The matter initiated in FY24 is In the Matter of Charlie Chiem which is presented before the Commission for ratification of the proposed Stipulation in a separate agenda item.
The current cases in progress are broken down by program area in the charts 1 and 2 below.
Matters in Preliminary Review:
Chart 1 – Matters in Preliminary Review by Program Area: 11
Chart 2: Open Investigations by Program Area: 18
Streamlined Administrative Resolution Program Review Project Update
As part of a separate agenda item, the Enforcement Division will provide an overview of the proposed amendments to the Commission’s Streamlined Administrative Resolution Program (“SARP”) requesting the Commission’s approval of the recommended proposals. The Enforcement Division is also recommending that SARP matters be returned to the Consent Calendar as fully described in the memo.
Enforcement Regulation Review Project Update
As previously reported, the Enforcement Division is conducting a comprehensive review of its Enforcement Regulations to identify gaps, clarify ambiguities, and strengthen provisions that guide the enforcement process. The objective of this effort is to ensure that the regulations more clearly inform the Commission, respondents, staff, and the public regarding the rules governing enforcement, and to support a process that is transparent, efficient, and fair.
Enforcement Staff have previously presented recommended amendments to the Commission and incorporated the Commission’s feedback into the ongoing revisions. There are no substantive updates at this time. Enforcement Staff remain engaged in the required meet-and-confer process with the Municipal Executives Association (MEA), and that process is ongoing.
Once the meet-and-confer process concludes, Enforcement Staff will return to the Commission to seek approval of the finalized proposed amendments.
We continue to welcome feedback and questions from the Commission as revisions progress.