On February 14, 2010, Senator Charles Schumer and Representative Chris van Hollen proposed legislation to ban foreign companies, or those controlled by foreign companies or governments, from making campaign contributions in US elections. The proposal followed the US Supreme Court decision in Citizen's United v. Federal Election Commission that corporate entities could be considered individuals when making contributions to US election campaigns, thus allowing for functionally unlimited donations. In the holding, the court overturned Section 203 of the Bipartisan Campaign Reform Act, which had prohibited corporations from directly donating campaign funds from their general treasury on the grounds that the provision infringed upon their First Amendment free speech rights.

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