The financial agent for ABC Vancouver and Ken Sim’s mayoral campaign in 2022 has been fined $11,888 by Elections BC for accepting prohibited contributions and not returning $2,400 to a donor within the timeframe set out in campaign finance rules.
Elections BC issued a report Wednesday that said Corey Sue, a chartered professional accountant, accepted contributions totalling $27, 329.84 that resulted in multiple contraventions under the Local Elections Campaign Financing Act, or LECFA.
The report included an accompanying "enforcement notice" that was sent to Sue from Adam Barnes, Elections BC’s director of investigations. The notice provided a list of the prohibited donations and names of donors.
Of the total prohibited amount of $27,329.84, Sue collected $13,125.74 via the ABC campaign and $14,204.10 for Sim’s mayoral run.
The notice indicates a total of $2,400 was not returned to Ramya Ledchumanan within 30 days of Sue becoming aware of the prohibited contribution.
Barnes said he based the $11,888 penalty to Sue on the following factors:
• Failing to return prohibited contributions gives an elector organization an advantage in that they had access to money during the campaign period that they were not entitled to.
• While Sue failed to return the contributions in the required time, he did ultimately remit them to [Elections BC] as required by LECFA.
• Sue’s campaign has been responsive to the investigation.
• Sue told the investigator that accepting the prohibited contributions were “honest mistakes and not intentional.”
• Sue had not previously been the subject of a monetary penalty under LECFA.
Sue said in an email Wednesday that as a volunteer-led organization that processed nearly 3,100 transactions and $2.4 million in contributions during the 2022 campaign, “we acknowledge that a small number of inadvertent errors occurred.”
He said the findings in the report show that ABC Vancouver fully co-operated throughout the process, “did not intentionally attempt to circumvent campaign finance rules” and took prompt action to return any inadvertent donation errors to the contributors once they were identified.
“Administrative monetary penalties can be issued even when there is no intent to breach the rules, which is the situation here,” Sue said.
“While we are disappointed in the ruling, as we believe we made every effort to correct the inadvertent errors within the appropriate time frame, we respect the decision. ABC has used this as an opportunity to further strengthen our internal procedures.”
Donor names
ABC Vancouver accepted prohibited donations totalling $1,160.82 each from Christina Anthony, David Bustos, Duncan Bustos, Elizabeth Zaozirny, Jeff Mooney, Kailash Gupta and Marie-Jeanne Becker-Godard.
The party also accepted prohibited donations totalling $1,250 each from Robert Murphy, Russell Ladd, Teresa Anne Edgar and Volta Auto.
Prohibited donations to Sim’s campaign came from Kim Kawaguchi ($3,560.82), Mitchell Ladd ($1,200), Robert Disbrow ($3,560.82), Susan Patterson ($1,160.82), William Disbrow ($2,321.64) and the $2,400 from Ledchumanan.
There is no indication in the enforcement notice that donors knowingly contributed dollar amounts that they knew were prohibited under LECFA, which governs political parties’ financial agents.
Barnes noted in the notice that after an investigator sent Sue a copy of the investigation report, he indicated that one of the prohibited contributions may have been reported in error.
“You noted that the contribution attributed to the name Haywood Capital Markets was actually from personal funds,” Barnes wrote.
“Haywood Capital Markets is a brokerage firm. In this case, two individuals directed Haywood to make contributions using their personal funds that are managed by Haywood. The contributions were attributed to Haywood in error by ABC Vancouver.”
Barnes said that because it was likely the two Haywood contributions were not prohibited in nature, he excluded them from the decision.
“Under other circumstances, [Elections BC] would ask you to file a supplementary report correcting this error, however these contributions have already been returned to the contributors, negating the need to do that,” he said.
Investigations team
The enforcement notice includes a timeline of correspondence with Sue, which indicates Elections BC’s audit and assessment team notified its investigations team March 8, 2024 of prohibited contributions accepted by Sue.
Elections BC contacted Sue the next day and requested confirmation that all prohibited contributions had been returned to contributors. Sue emailed a response May 27, 2024 stating that all contributors had been refunded.
Sue also provided “contextual information about the contribution and provided evidence of the returns,” according to the notice, which also stated that in one of Sue’s responses that “ABC Vancouver did not deliberately attempt to circumvent the provisions in LECFA.”
In the months following, Sue provided bank statements and supplementary reports to Elections BC. Then on March 10, 2025, Sue provided an Excel document to Elections BC that contained a finalized list of contributions accepted contrary to LECFA.
The document indicated two prohibited contributions that were returned to Ledchumanan more than 30 days after Sue became aware of them, which is contrary to LECFA, according to Elections BC.
The maximum contribution limit an individual could make in 2022 was $1,250. That increased to $1,324 in 2023, then $1,370.68 in 2024 and is $1,402.40 this year.
Sue can request a review of the fine by an Elections BC adjudicator.
A request must be made in writing and received by the investigator within 14 days after the date on which he received the enforcement notice. The request must state the grounds on which the request for review is made.
Sue may also seek relief from the monetary penalties from the BC Supreme Court within 30 days of receiving his notice.
Progress Vancouver
Elections BC’s release Wednesday also announced fines against three other Vancouver civic parties, including former mayor Kennedy Stewart’s Forward Together party, which failed to elect candidates in the 2022 election.
In that case, Forward Together’s financial agent Louise Onarheim was fined $7,392 for failing to repay campaign debt within six months of it becoming due.
Progress Vancouver, which was headed by mayoral candidate Mark Marissen and failed to elect any candidates, was fined a total of $13,740.
One of the party’s financial agents, AnnMarie Aase, was fined $4,315 for accepting prohibited donations and failing to return donations.
A separate $4,500 penalty issued to Progress Vancouver was for accepting a prohibited loan. Another $4,425 was levied against the party for accepting a contribution other than through a financial agent.
Holly Chen, also one of the party’s financial agents, was fined $500 for accepting prohibited donations.
Namrata Takkar, financial agent for Vision Vancouver, was fined $750 for accepting a prohibited donation and failing to return the contribution.
X/@Howellings
