A consultant for a Boston City Council candidate was hit with a campaign finance violation and $5,000 fine, for activity that led to a presumption of illegal coordination between the campaign and a supportive labor union he also worked for.

Christopher Keohan, a consultant with CK Strategies, LLC who did work for the 2023 committee to reelect City Councilor Erin Murphy, was notified of the violation on Nov. 20 but the letter from the state Office of Campaign and Political Finance was not posted publicly until Wednesday.

“This office has completed its review of a complaint alleging what appeared to be a coordinated expenditure by the International Association of Fire Fighters made to support the 2023 reelection campaign of Erin Murphy for Boston City Council,” OCPF Director William Campbell wrote.

“Based on our review, OCPF has determined that both you and CK Strategies, LLC did not comply with the requirements of the campaign finance law,” he added. “While OCPF did not find evidence of an intentional violation in this instance, we believe that the failure to comply with the requirements of the campaign finance law was due in large part to a lack of understanding of those requirements.”

The campaign finance violation was first reported by the Boston Globe.

The crux of the violation centers around work Keohan’s consulting firm was retained to do for campaign work, including campaign mailers and advertising for the committee to elect Murphy, while at the same time doing similar work for the International Association of Fire Fighters, which included designing, producing and distributing a mailer that endorsed Murphy and another candidate.

The IAFF’s mailer was intended to be an independent expenditure, paid for by the union’s general treasury fund. The IAFF filed an independent expenditure report disclosing that the value of the endorsement mailer for Murphy was $13,229, the OCPF letter states.

“OCPF received a complaint raising concerns that the mailers showed evidence of coordinated expenditures as they utilized similar fonts and layouts, as well as the same mail permit,” Campbell wrote.

Campbell’s letter explains that the work done by Keohan on behalf of both the Murphy campaign committee and the union endorsing her led to a presumption that the IAFF mailer did not meet the criteria for an independent expenditure, as there appeared to be coordination between the candidate’s campaign and IAFF.

Thus, the expenditure should have been filed as a campaign contribution to Murphy, and, at more than $13,000, exceeded the annual $1,000 limit for individual contributions in 2023, per the OCPF letter.

“The presumption may be rebutted by evidence demonstrating that the services were provided consistent with a previously established written firewall policy that prohibits the flow of strategic non-public information to the person or entity making the expenditure, or other evidence indicating that the common consultant actually prohibited the flow of strategic, non-public information between the entity making an independent expenditure and the candidate, candidate’s committee or agent,” Campbell’s letter states.

Campbell said a firewall policy must designate specific staff to work solely for the candidate and other staff that will work only for the individuals or entities making independent expenditures — in this case, Murphy and IAFF.

That was not the case in this instance, the OCPF found. Keohan acknowledged doing work for both Murphy and the IAFF and acknowledged that CK Strategies does not have a written firewall policy, though it has a verbal one in place.

“Both Murphy and the IAFF filed affidavits with the OCPF, under the pains and penalties of perjury, stating that they were unaware of your status as a common consultant, and that the committee, Murphy and the IAFF did not directly receive any strategic, non-public information from the other,” Campbell wrote.

“However, OCPF has concluded that your simultaneous work for both entities absent proper firewalling triggered the presumption of coordination between the IAFF and the committee, and no evidence has been provided to rebut that presumption,” he added.

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To resolve the matter, Keohan made a $5,000 contribution to the commonwealth.

Keohan told the Herald Thursday that he paid the fine to resolve the matter, but believes that “we did everything by the book.”

“It was a presumptive finding,” Keohan said. “We decided not to fight it in order to get past the issue. We still believe we did everything by the book, but in the interest of time and ensuring that something like this never happens again, we worked with OCPF to create our own written firewall policy and have moved past it.”

City Councilor Erin Murphy (Matt Stone/Boston Herald)