Nana Wu
The glittering opulence of the Kennedy Center’s annual Honors Gala in December, a cornerstone event celebrating the nation’s performing arts elite, has become overshadowed by mounting concerns over ethical conduct within the Federal Communications Commission (FCC). Attendees at this exclusive, black-tie affair, which typically draws Washington’s most influential figures and requires significant donations for premium seating, included two high-ranking FCC commissioners whose recent regulatory decisions were pivotal to the fate of media giant Paramount and its parent company, Paramount Global. The optics of these officials accepting lavish gifts of attendance from a company currently navigating critical FCC approvals have ignited a firestorm among ethics watchdogs and legal experts, who argue that the very appearance of impropriety undermines public trust and compromises the integrity of the regulatory process.
The gala, hosted by President Donald Trump, is renowned for its stringent ticketing policies, with priority given to donors contributing over $75,000. This year’s honorees included Hollywood titan Sylvester Stallone, the iconic glam rock band Kiss, and disco pioneer Gloria Gaynor. However, behind the scenes of this star-studded celebration, regulatory decisions with multi-billion dollar implications were being shaped.
A Pattern of Generosity and Scrutiny
Federal Communications Commissioner Olivia Trusty, who cast a decisive vote five months prior to the gala, approving Paramount’s monumental $8 billion merger with Skydance Media, was a guest at the event. Ethics disclosure records, obtained by ProPublica, reveal that Paramount gifted Trusty and her guest tickets valued at over $12,000.
FCC Chair Brendan Carr, another key figure in the merger’s approval, occupied a coveted private skybox alongside Paramount CEO David Ellison and other executives from Paramount and CBS. These premium seats, according to Kennedy Center guidelines, command prices as high as $125,000 per ticket. While Carr’s financial disclosure for the past year has not yet been publicly released, his prior disclosures indicate a consistent pattern of accepting such gifts. Since his appointment in 2017, Carr has accepted Kennedy Center gala tickets from CBS or its parent company at least seven times, accumulating a value exceeding $63,000.
This pattern extends beyond Carr and Trusty. ProPublica’s analysis of ethics disclosures reveals that seven FCC commissioners have accepted Kennedy Center gala tickets from CBS or its parent company over the last decade. This practice has drawn sharp criticism from ethics experts, who deem it a blatant conflict of interest, given the FCC’s regulatory oversight of these media entities.
The Paramount-Skydance Merger: A High-Stakes Regulatory Battle
The timing of these gifts is particularly sensitive. The December gala occurred as Paramount was actively pursuing a hostile takeover bid for Warner Bros. Discovery, a deal that would create an entertainment behemoth and necessitate further FCC approval. The proposed consolidation, valued at an astonishing $110 billion, aims to merge two of Hollywood’s largest studios, bringing under one corporate umbrella streaming services like Paramount+ and HBO Max, major networks such as CBS and CNN, and a vast array of broadcast channels, cable networks, and digital platforms.
This potential megacorporation, poised to fundamentally alter how millions access news, movies, sports, and video games, has ignited fierce opposition. Over 5,000 actors, producers, and entertainment industry workers, including prominent figures like Robert De Niro, Javier Bardem, Joaquin Phoenix, and Glenn Close, have signed an open letter condemning the merger’s potential to eliminate jobs and compromise the industry’s integrity, independence, and diversity.
The regulatory hurdles facing the Paramount-Skydance deal are significant. Beyond the FCC’s ongoing review, a coalition of states, including California and New York, has filed a lawsuit seeking to block the merger on antitrust grounds. International regulators are also scrutinizing the deal for its potential national security implications and its impact on global consumers. The British government, for instance, has indicated plans to investigate whether the new entity would stifle competition. The FCC’s review specifically includes an examination of the Middle Eastern sovereign wealth funds backing the transaction, namely those from Saudi Arabia, Qatar, and Abu Dhabi.
Ethics Experts Sound the Alarm
Federal ethics rules strictly prohibit government employees from accepting gifts from entities that do business with, are regulated by, or seek official action from their agency. Four prominent ethics experts have unequivocally stated that by accepting the premium tickets, Commissioners Trusty and Carr have compromised the FCC’s impartiality and should recuse themselves from any decisions pertaining to the Paramount merger.
“There’s no way that any top federal regulator should ever, ever accept a gift from a regulated company with interests their work will foreseeably affect,” stated Walter Shaub, former director of the federal Office of Government Ethics. “The appearance of taking gifts like that is terrible. What’s at stake is nothing less than the public’s trust in government.”
Virginia Canter, an ethics lawyer with extensive experience in various federal administrations, echoed these concerns, asserting that commissioners who accepted the tickets cannot participate in this matter without damaging the integrity of the government’s decision-making process. “This is shocking. Pretty disturbing, that’s what I would say. I just don’t understand what they were thinking,” Canter commented, now serving as chief counsel for ethics and corruption at the nonpartisan watchdog group Democracy Defenders Fund.
The FCC’s Defense and the Persistence of Practice
The FCC, in its defense, has stated that agency ethics officers have consistently cleared commissioner appearances at the Kennedy Center gala, deeming them consistent with ethics law. “FCC Chairs and officials have attended the same event, in the same ways, consistently from the Trump Administration to the Biden Administration to the Obama Administration,” an FCC spokesperson said in a statement. “There has been no change in recent years.”
This justification has been met with strong disapproval. Shaub dismissed the FCC’s defense as “outrageous,” arguing that the rationale of precedent or widespread practice does not absolve officials of their ethical obligations. “It’s no excuse to say that you took the gift because everyone else was doing it or that your agency has had a bad habit of indulging in gift taking for a long time,” Shaub retorted. “That kind of explanation doesn’t work for school children, and it sure as hell doesn’t work for government officials who are supposed to have better judgment than a fifth grader.”
The historical context reveals a long-standing practice of FCC commissioners accepting complimentary tickets to the Kennedy Center Honors gala from CBS or its parent company. An analysis by ProPublica indicates that seven out of the ten commissioners who served since 2016 accepted such tickets, collectively valued at over $260,000. Jessica Rosenworcel, President Joe Biden’s appointee and former FCC chair, who stepped down in January 2025, was a regular attendee. Nathan Simington, the sole commissioner among those serving since 2016 who did not accept any gifts, stated he declined invitations because it “wasn’t my cup of tea.”
Beyond the Kennedy Center gala, FCC commissioners have accepted paid trips from various entities regulated by the agency to attend banquets and conferences. These gifts, totaling over $308,000 across a decade, have come from companies like NBCUniversal, ABC-Disney, and Fox News. However, the overwhelming majority of these substantial gifts have originated from CBS and its parent company.
Melissa Zukerman, Paramount’s chief communications officer, acknowledged the practice as a “decades-long CBS practice to invite government officials from both parties” but did not elaborate on the purpose of the gifts or address the potential conflict of interest, especially following the recent change in ownership.
A Tangled Timeline of Regulatory Maneuvers
The December 2025 gala occurred at a particularly charged moment for Paramount and the FCC, but this was not the first instance of intertwined events. In September 2024, Paramount filed for FCC approval for its Skydance merger. Just a month later, the FCC initiated an investigation into CBS following a complaint by a conservative group regarding a “60 Minutes” interview with Democratic presidential candidate Kamala Harris. President Trump subsequently filed a lawsuit, alleging deceptive editing of the interview, a claim CBS denied.
In November 2025, less than two weeks after his election victory, Trump declared his intention to appoint Carr as FCC chair. Shortly thereafter, Carr accused CBS of biased election coverage, suggesting it would impede the Paramount-Skydance merger approval. In December 2025, Carr, along with Commissioners Rosenworcel, Gomez, and Geoffrey Starks, accepted Kennedy Center gala tickets from Paramount, with a combined value of $48,156.
On January 16, 2025, days before her departure, Rosenworcel announced the FCC’s dismissal of the election complaint against CBS, framing it as a victory for the First Amendment. However, Carr, as the incoming FCC chair, swiftly reopened the investigation.
The lawsuit brought by Trump against CBS was eventually settled for $16 million, a decision criticized by legal experts who deemed Trump’s claims unsubstantiated. Two days after Trump announced receiving the settlement funds, the FCC approved the Paramount-Skydance merger. As a condition of approval, Paramount agreed to appoint an independent ombudsperson to evaluate bias claims and to eliminate its diversity, equity, and inclusion initiatives.
By this time, Commissioners Starks and Simington had resigned. Trusty, a Trump appointee, had been confirmed by the Senate the preceding month. Trusty and Carr voted in favor of the merger, while Commissioner Anna Gomez cast a dissenting vote, criticizing the approval for imposing “never-before-seen forms of government control over newsroom decisions and editorial judgment.”
Ethics experts noted that while Trusty may not have faced a conflict at that specific juncture, Carr and Gomez, despite her dissenting vote, did. Shaub emphasized that under federal rules, simply repaying the ticket cost does not absolve officials of the need for recusal, particularly when a refusal to repay exacerbates the ethical dilemma.
The Road Ahead: Scrutiny and Potential Challenges
With the Paramount-Skydance merger greenlit by the FCC, Ellison has turned his attention to acquiring Warner Bros. Discovery. Warner initially resisted Paramount’s overtures, accepting a bid from Netflix on December 5, 2025, just two days before the Kennedy Center gala. Ellison, in response, engaged in extensive communication with administration officials, including a lengthy conversation with President Trump, as reported by The Wall Street Journal.
On the night of the gala, Trump publicly voiced concerns about the Netflix deal, signaling his intent to become directly involved in the regulatory approval process. Meanwhile, inside the Kennedy Center, Carr and his wife were seated with Ellison in an exclusive skybox. Commissioner Gomez, in a statement to ProPublica, revealed she declined Paramount’s invitation due to “serious concerns about press independence connected to conditions Paramount agreed to as part of its merger transaction before the FCC.” Hours after the gala, Paramount launched its hostile takeover bid for Warner Bros. Discovery. Approximately three months later, Carr publicly endorsed Paramount over Netflix on CNBC, promising swift approval.
The potential for commissioners to abstain from future merger votes due to ethical concerns remains a complex issue. Federal conflict of interest rules allow for agency designees to permit voting after considering factors such as the difficulty of reassigning the matter and the financial interests of the parties involved. However, Carr has previously bypassed full commission votes, delegating authority to FCC staff for approvals, as he did with the Nexstar Media Group’s acquisition of Tegna.
Any decision on the Paramount deal, whether by the full commission or through delegated authority, is likely to face legal challenges. Richard Painter, former White House ethics attorney, cautioned that courts, while often deferential to government judgment, can become skeptical of regulatory decisions if the process is demonstrably compromised. “A judge may very well say that the merger decision of the FCC isn’t worth jack because the process was corrupted,” Painter stated.
The Office of Government Ethics memo from 2009 and subsequent tightening of gift rules in 2016 explicitly advised against accepting gifts from entities seeking official action or that could create an appearance of impropriety. While an exemption exists for “widely attended gatherings” that further agency programs, experts argue that the Kennedy Center Honors gala, with its focus on entertainment and celebrity, does not fit the criteria for a structured exchange of ideas beneficial to the agency’s mission. The FCC’s failure to provide written authorization for the tickets, or to identify who authorized them, further fuels concerns about transparency and adherence to federal regulations.
The persistent acceptance of high-value gifts by FCC commissioners from companies with significant regulatory matters before the agency raises fundamental questions about the fairness and impartiality of the regulatory process. As the media landscape continues its rapid transformation, the public’s trust in regulatory bodies hinges on their demonstrable commitment to ethical conduct and the avoidance of even the appearance of impropriety. The ongoing scrutiny of the FCC’s actions in the Paramount merger will undoubtedly serve as a critical test of these principles.
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