The Missouri Ethics Commission recently issued an advisory opinion clarifying campaign finance rules for corporations seeking to contribute to PACs.

Currently, a corporation may not contribute its own funds to its connected PAC, but it may contribute direct corporate funds to an unconnected PAC. The new opinion provides additional guidance on whether a corporation and a PAC are considered connected for the purpose of campaign finance law.

If contributions to a PAC are from a corporation’s general treasury, and not from the corporation’s officers, employees, or spouses thereof, it is possible the PAC is not connected to the organization. In such a scenario, if the corporation does not expend funds or provide services or facilities to administer or maintain the PAC, and it does not expend funds or provide services to solicit contributions to the PAC from its members, officers, directors, employees, or security holders, it is not a connected organization. This is true even when the PAC is funded 100 percent by a corporation’s general treasury funds.

Moreover, assuming the corporation did not establish the PAC and does not serve as a connected organization, it may make unlimited monetary contributions from the corporate treasury.