Who can work on US political campaigns?
US federal law bars foreign nationals from spending money on any US election and from taking part in a campaign's decisions, under 52 U.S.C. § 30121 and 11 CFR § 110.20. US citizens and green card holders are not foreign nationals.
General information, not legal advice. Laws and app policies as we read them on 24 Oct 2026.
The federal ban
- A foreign national may not give money or anything of value, or pay for ads or other spending, in connection with any federal, state or local election in the US. 52 U.S.C. § 30121, 11 CFR § 110.20
- Nobody may ask for or accept such a gift from a foreign national. 52 U.S.C. § 30121
- A foreign national may not direct, control or take part in the decisions of a campaign, party, PAC or anyone else about election spending, or about how a political committee is run. 11 CFR § 110.20
- Knowingly helping someone make a banned contribution or expenditure breaks the rule too. 11 CFR § 110.20
Who counts
- A foreign national is anyone who is not a US citizen or national and is not a lawful permanent resident. 52 U.S.C. § 30121, 11 CFR § 110.20
- Green card holders are not foreign nationals. The FEC says a green card holder may give to campaigns. 52 U.S.C. § 30121, FEC: foreign nationals
- Status decides it, not where a person lives: a US citizen living abroad is not a foreign national, and a visa holder living in the US is. 52 U.S.C. § 30121
- A company organized under foreign law, or with its main place of business abroad, counts as a foreign national. 52 U.S.C. § 30121, 22 U.S.C. § 611
- A US subsidiary of a foreign company may run a PAC only if it is incorporated and based in the US, the parent does not fund it, and US citizens or green card holders make every decision about it. FEC: foreign nationals
Vendors and decisions
- Any person or company, foreign or domestic, may sell goods or services to a political committee as a commercial vendor without making a contribution, as long as no foreign national takes part in the committee's decisions. MUR 7563, MUR 7350 analysis
- In the Cambridge Analytica matters, the FEC's analysis treated foreign staff who shaped messages, picked targets and chose which messages went to which audiences as possibly taking part in the campaigns' decisions. Who had the final say was not the test. MUR 7350 analysis, MUR 7351, MUR 7382
- Those were early findings, not a ruling. The FEC closed the files in 2021 with no penalty, as the record was thin and time limits had passed. MUR 7350 closing report
- A foreign national may volunteer without pay and even sit in strategy meetings, but may not manage the committee or take part in its decisions. FEC: volunteer activity, FEC AO 2004-26
- In AO 2007-22 the FEC let a campaign pay Canadian citizens as staff in roles outside fundraising and finance. Paid work is not banned in itself, a part in decisions is. FEC AO 2007-22
Fair market pricing
- Goods, or a business's services, given to a campaign free or below the usual and normal charge are a contribution in kind. An individual's own unpaid volunteer time is not. 11 CFR § 100.52, FEC: volunteer activity
- The usual and normal charge for services is a commercially reasonable rate at the time the work is done. 11 CFR § 100.52
- In AO 2018-11 the FEC allowed a free service only because it was offered on commercial terms, in the normal course of business, to every similar customer, not for political reasons. FEC AO 2018-11
- So a foreign company, or a foreign national selling their work, that gives a campaign free or cut-price clips makes a banned contribution, and so does a foreign national who hands over ready-made material for free. Charging what other clients pay keeps it a sale. 11 CFR § 100.52, FEC AO 2007-22
- A foreign national who volunteers their own time, unpaid, makes no contribution, as long as they stay out of the campaign's decisions. FEC: volunteer activity, FEC AO 2004-26
California's own rule
- California bars foreign governments, foreign principals and foreign nationals from making contributions, expenditures or independent expenditures for any state or local candidate or ballot measure, directly or through someone else. Cal. Gov. Code § 85320
- Lawful permanent residents are left out of the ban by name, and so are people with unexpired DACA deferred action. Cal. Gov. Code § 85320
- A person outside the US counts as a foreign principal unless they are a US citizen or a US organized entity based in the US. Cal. Gov. Code § 85320
Still unsettled
- No FEC opinion says where cutting or posting clips for a campaign turns into taking part in its decisions. Choosing messages, targets or audiences is where the FEC's analysis looked hardest. MUR 7350 analysis
- California's rule has no general decision making ban like the federal one, and does not say whether being paid by a committee to post counts as an expenditure by the poster. Cal. Gov. Code § 85320
Common questions
Can a green card holder clip for a US political campaign?
Yes. 52 U.S.C. § 30121 leaves lawful permanent residents out of the definition of foreign national, so the ban does not reach them.
Does the ban cover state and local elections?
Yes. 52 U.S.C. § 30121 covers federal, state and local elections in the US, and California adds its own ban in Gov. Code § 85320.
Can a foreign company sell services to a US campaign?
Yes, as a commercial vendor at the usual charge, the FEC said in MUR 7563, as long as no foreign national takes part in the campaign's decisions under 11 CFR § 110.20.