Graham violated the law 17 times, according to a panel of the city's Ethics Commission. The full commission will consider it next week.
Until she resigned in 2008, Graham headed the Centre City Development Corp., a nonprofit agency that oversaw such projects as a convention center. She was accused of trying to influence the agency's decision on a proposed hotel by Lennar Corp. during a period when she received $3.5 million from a Florida deal involving a Lennar subsidiary.
Graham, who resigned July 24, didn't report her business ties with the projects' developers in required financial disclosure forms.
Her attorney says she's gratified that the panel found she didn't intentionally violate the law and never made money off the hotel project.