August 14, 2019

FEC Approves Distribution of Tokens to Campaign Volunteers

Stephen T. Middlebrook

The Federal Election Commission issued an advisory opinion approving a political campaign’s distribution of digital blockchain tokens with no monetary value to campaign volunteers as an incentive to engage in volunteer activities.

Volunteers received the tokens for registering to vote, hosting events and doing other things to support the campaign. The tokens cannot be bought or sold or used to obtain goods or services. At the end of the campaign, the three volunteers with the most tokens will receive prizes and participants may keep their tokens as souvenirs. The FEC concluded the tokens did not constitute compensation to volunteers which would be prohibited under applicable law but rather were indistinguishable from traditional forms of campaign souvenirs which are allowed.

Stephen T.. Middlebrook

Womble Bond Dickinson