Rule 206(4)-5 (Rule) under the Investment Advisers Act of 1940, commonly known as the “pay to play” rule, prohibits an investment adviser from providing paid investment advisory services to a government entity for two years after the adviser or certain of its employees or executives make a contribution to an official of the government entity.  See “Key Elements of a Pay-to-Play Compliance Program for Hedge Fund Managers,” Hedge Fund Law Report, Vol. 3, No. 37 (Sep. 24, 2010).  In a recent administrative order, the SEC sanctioned a private fund adviser for violating the Rule.  For an example of SEC leniency for an inadvertent violation of the Rule, see “SEC Excuses a Hedge Fund Manager’s Inadvertent Violation of the Pay to Play Rule,” Hedge Fund Law Report, Vol. 7, No. 3 (Jan. 23, 2014).