FEDERAL ELECTION COMMISSION 

Washington, DC 20463 

 April 25, 2023 

Via Electronic Mail 

Matthew A. Levin 

Markowitz Herbold PC 

1455 SW Broadway 

Suite 1900 

Portland, Oregon 97201 

mattlevin@markowitzherbold.com

 RE: MUR 8092 

 Bashar Wali 

Dear Mr. Levin: 

 On April 18, 2023, the Federal Election Commission accepted the signed conciliation 

agreement submitted on your client's behalf in settlement of a violation of 52 U.S.C. § 30122 and 

11 C.F.R. § 110.4(b)(1)(ii), a provision of the Federal Election Campaign Act of 1971, as 

amended and Commission regulations. 

 The Commission reminds you that the confidentiality provisions of 52 U.S.C. 

§ 30109(a)(12)(A) still apply, and that this matter remains open. The Commission will notify 

you when the entire file has been closed. 

 Enclosed you will find a copy of the fully executed conciliation agreement for your files. 

Please note that the civil penalty amount of $13,750 is due within 30 days of the effective date of 

the conciliation agreement and the remaining civil penalty amount of $13,750 is due within 60 

days of the effective date of the conciliation agreement. If you have any questions, please 

contact me at (202) 694-1650. 

 Sincerely, 

 Kimberly D. Hart 

 Attorney 

Enclosure 

 Conciliation Agreement 

MUR809200090
BEFORE THE FEDERAL ELECTION COMMISSION 

In the Matter of ) 

 ) 

 Bashar Wali ) MUR 8092

 

CONCILIATION AGREEMENT 

This matter was initiated by a sua sponte submission (“the Submission”) made to the 

Federal Election Commission (the “Commission”) by Bashar Wali (“Wali”). See 52 U.S.C. 

§ 30109(a)(1). The Commission found reason to believe that Bashar Wali violated 52 U.S.C. 

§ 30122 and 11 C.F.R. § 110.4(b)(1)(ii), provisions of the Federal Election Campaign Act (the 

“Act”) and Commission regulations, by knowingly permitting his name to be used for the 

making of contributions in the name of another. 

 NOW, THEREFORE, the Commission and Respondent, having participated in informal 

methods of conciliation, prior to a finding of probable cause to believe, do hereby agree as 

follows: 

 I. The Commission has jurisdiction over the Respondent and the subject matter of 

this proceeding, and this agreement has the effect of an agreement entered pursuant to 52 U.S.C. 

§ 30109(a)(4)(A)(i). 

 II. Respondent has had a reasonable opportunity to demonstrate that no action should 

be taken in this matter. 

 III. Respondent enters voluntarily into this agreement with the Commission. 

 IV. The pertinent facts and law in this matter are as follows: 

1. Provenance is a limited liability company based in Portland, Oregon and 

elects to be treated as a partnership for tax purposes. 

MUR809200091
MUR 8092 (Bashar Wali)

Conciliation Agreement 

Page 2 of 4 

2. Bashar Wali (“Wali”) was Provenance’s President from June 2010 

through May 30, 2020. 

3. From April 2018 to September 2018, Wali; his spouse, Eileen Wali; and 

Leslie Lew, Vice President of Revenue, made the following political contributions: 

Date Conduit Recipient Amount 

4/24/18 Bashar Wali NRSC $33,900 

4/30/18 Bashar Wali Tillis Majority Committee (primary) $10,400 

9/18/18 Bashar Wali American Hotel & Lodging Assoc. PAC (AHLA PAC) $5,000 

3/28/19 Bashar Wali Thom Tillis Committee (primary) $100 

3/29/19 Bashar Wali Thom Tillis Committee (primary) $5,400 

3/28/19 Bashar Wali Thom Tillis Committee (general) $100 

4/17/19 Bashar Wali Wyden for Senate (primary) $2,800 

4/17/19 Bashar Wali Wyden for Senate (general) $2,800 

4/17/19 Bashar Wali Hoops PAC $5,000 

6/11/19 Bashar Wali AHLA PAC $5,000 

10/21/19 Bashar Wali AHLA PAC $10,000 

Total Bashar Wali Reimbursed Contributions for 2018-2019 $80,500 

9/18/18 Eileen Wali AHLA PAC $5,000 

3/29/19 Eileen Wali Thom Tillis Committee (P) $2,800 

3/29/19 Eileen Wali Thom Tillis Committee (G) $2,800 

4/17/19 Eileen Wali Hoops PAC $5,000 

6/11/19 Eileen Wali AHLA PAC $5,000 

Total Eileen Wali Reimbursed Contributions for 2018-2019 $20,600 

9/18/18 Leslie Lew AHLA PAC $5,000 

Total Leslie Lew Reimbursed Contributions for 2018-2019 $5,000 

TOTAL REIMBURSED CONTRIBUTIONS $106,038 

4. On April 25, 2019, July 12, 2019, and October 14, 2019, Wali sent three 

separate emails to Holly Landry, Provenance’s Corporate Controller, instructing her to process 

and issue contribution reimbursements totaling $106,038 in the form of three $50,000 bonus 

payments as described above. 

5. On May 8, 2019, July 19, 2019, and October 18, 2019, Provenance 

reimbursed Wali for his political contributions totaling $106,038 in the form of three $50,000 

bonus payments. These bonus payments were in addition to Wali’s annual performance bonus 

approved by the Board of Directors. 

MUR809200092
MUR 8092 (Bashar Wali)

Conciliation Agreement 

Page 3 of 4 

6. Under Section 30122, “[n]o person shall make a contribution in the name 

of another person or knowingly permit his name to be used to effect such a contribution.” 

52 U.S.C. § 30122; see also 11 C.F.R. § 110.4(b)(1)(ii). 

 V. Respondent Bashar Wali violated 52 U.S.C. § 30122 and 11 C.F.R. 

§ 110.4(b)(1)(ii) by knowingly permitting his name to be used to make contributions in the name 

of another. 

VI. Respondent will take the following actions: 

1. Respondent Bashar Wali will cease and desist from violations of 

52 U.S.C. § 30122 and 11 C.F.R. § 110.4(b)(1)(ii). 

2. Respondent will pay a civil penalty of Twenty-Seven Thousand Five 

Hundred Dollars ($27,500), pursuant to 52 U.S.C. § 30109(a)(5)(A). The civil penalty will be 

paid as follows: 

i. A payment of Thirteen Thousand Seven Hundred and Fifty Dollars 

($13,750) is due no more than thirty (30) days from the date this Agreement becomes effective; 

and 

ii. A payment of Thirteen Thousand Seven Hundred and Fifty Dollars 

($13,750) is due no more than sixty (60) days from the date this Agreement becomes effective. 

VII. The Commission, on request of anyone filing a complaint under 52 U.S.C. 

§ 30109(a)(1) concerning the matters at issue herein or on its own motion, may review 

compliance with this agreement. If the Commission believes that this agreement or any 

requirement thereof has been violated, it may institute a civil action for relief in the United States 

District Court for the District of Columbia. 

MUR809200093
MUR 8092 (Bashar Wali)

Conciliation Agreement 

Page 4 of 4 

VIII. This agreement shall become effective as of the date that all parties hereto have 

executed same and the Commission has approved the entire agreement.

 IX. Except as otherwise provided, Respondents shall have no more than 30 days from 

the date this agreement becomes effective to comply with and implement the requirements 

contained in this agreement and to so notify the Commission. 

X. This conciliation agreement constitutes the entire agreement between the parties 

on the matters raised herein, and no other statement, promise, or agreement, either written or 

oral, made by either party or by agents of either party, that is not contained within this written 

agreement shall be enforceable.

FOR THE COMMISSION:

Lisa J. Stevenson 

 Acting General Counsel 

BY: __________________________ ____________________ 

Charles Kitcher Date

Associate General Counsel 

 for Enforcement 

FOR THE RESPONDENT:

__________________________ ____________________ 

Matthew Levin Date

Counsel for Respondent 

February 13, 2023

4/25/23

Charles 

Kitcher

Digitally signed 

by Charles Kitcher 

Date: 2023.04.25 

10:40:08 -04'00'

MUR809200094