FEDERAL ELECTION COMMISSION

WASHINGTON, D.C. 20463

STATEMENT OF REASONS OF 

COMMISSIONERS SHANA M. BROUSSARD AND ELLEN L. WEINTRAUB 

One’s endorsement of a candidate should never be for sale. It should also go without saying 

that there are situations where the Commission should not abandon an enforcement matter. In this 

matter we had overwhelming evidence that a presidential campaign committee purchased an 

endorsement using corporate resources, and that it concealed that purchase through a chain of 

transactions that channeled the funds in a manner intended to obscure their true source and purpose. 

It is illegal for a corporation to make contributions to a federal candidate’s committee and 

for such a committee to knowingly accept prohibited contributions.1

 Additionally, federal 

committees are obligated to disclose the true source of their expenditures through truthful and 

accurate reporting.2

 Using an intermediary to obscure information that should be available to the 

public is decidedly unacceptable. 

But that appears to be what happened here. In the lead-up to the 2012 Republican Party Iowa 

presidential caucus, Dmitri Kesari, a deputy campaign manager for Ron Paul’s campaign, using 

corporate resources belonging to Designer Goldsmiths, Inc.,3 presented a check to then-Iowa State 

Senator Kent Sorenson to switch his support from Michele Bachmann to Ron Paul. Then, other 

principals from Paul’s campaign worked to funnel payoffs, disguised as audio-visual expenditures, 

from Ron Paul’s campaign committee, Ron Paul 2012 Presidential Campaign Committee, Inc. (the 

“Ron Paul Committee”), through two other corporations, and ultimately, to Sorenson. Sorenson, 

Kesari, Paul’s campaign chairman Jesse Benton, and Paul’s campaign manager John Tate were all 

criminally prosecuted for their efforts to effect and conceal these payments.4

 

1

 52 U.S.C. § 30118(a). 2

 Id. § 30104(b)(5). 3

 Designer Goldsmiths, Inc., is a Virginia corporation owned by Kesari and his wife. See Factual and Legal 

Analysis at 1-2, MUR 6800 (Ron Paul 2012 Presidential Campaign Committee, Inc., et al.). 4

 Despite their convictions, and the prosecution’s recommendation that they serve more than two years for their 

roles in making these hidden payments, Paul’s campaign chairman and campaign manager were not sentenced to any 

prison time. Grant Rodgers, Ron Paul Aides Avoid Jail Time in Endorsement Scheme, DES MOINES REGISTER (Sept. 20, 

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of

Ron Paul 2012 Presidential Campaign 

Committee, Inc., et al.

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 MUR 6800 

 

 

MUR680000211
MURs 6800 (Ron Paul 2012 Presidential Campaign Committee, et al.) 

Statement of Commissioners Shana M. Broussard and Ellen L. Weintraub

Page 2 of 3 

These payoffs were well documented. By the time the Office of General Counsel (“OGC”) 

made its initial recommendations in this matter, Sorenson had already pleaded guilty to a two-count 

information in United States v. Kent Leroy Sorenson,

5 and there was an extensive state ethics report 

outlining the payments at issue.6 These materials established a chain of circuitous maneuverings to 

move funds and effect secret payoffs from the Ron Paul Committee into a company controlled by 

Sorenson, by way of a third-party audio-visual company.7 Sorenson confirmed the scheme, stating 

that he had switched his support to the Ron Paul Committee, “in exchange for concealed payments 

that amounted to $73,000” which came from the Ron Paul Committee and “were concealed by 

transmitting them to a film production company, then through a second company [controlled by 

Sorenson], and finally to Sorenson and his spouse.”8 By this time, it was also established that a 

$25,000 check from Kesari’s corporation was being held by Sorenson and his wife as a “concealed 

security” to ensure that the obscured payments continued to flow from Paul’s campaign to 

Sorenson.9

It was no accident that the funds traveled in such a complicated way. The payments 

appeared on campaign disclosure reports as an audio-visual expense, rather than a covertly 

purchased endorsement. Sorenson admitted to this in the Stipulated Statement of Facts that 

accompanied his plea, which stated that he “knew that agents of [the Ron Paul Committee] would 

and did falsely omit his name and other identifying information from required reports to the FEC.”10 

2016), https://www.desmoinesregister.com/story/news/crime-and-courts/2016/09/20/jesse-benton-john-tate-sentencingron-paul-kent-sorenson-michele-bachmann/90742638/. They were later pardoned by then-President Trump. Statement 

from the Press Secretary Regarding Executive Grants of Clemency, THE WHITE HOUSE (Dec. 23, 2020)

https://trumpwhitehouse.archives.gov/briefings-statements/statement-press-secretary-regarding-executive-grantsclemency-122320/; Morgan Watkins, Donald Trump Pardons ex-campaign manager for Sens. Rand Paul, Mitch 

McConnell, LOUISVILLE COURIER JOURNAL (Dec. 24, 2020), https://www.courierjournal.com/story/news/politics/2020/12/24/trump-pardons-jesse-benton-ex-campaign-manager-rand-paul-mitchmcconnell/4042657001/. Kesari was sentenced to three months’ incarceration with supervised release and fined 

$10,400. Judgment, United States v. Dimitrios N. Kesari, 4:2015-cr-00103 (S.D. Iowa Sept. 21, 2016). The pardon did 

not affect the liability of the institutional actors at issue here.

5 See United States v. Kent Leroy Sorenson, Case No. 4:2014-cr-00103 (S.D. Iowa Sept. 16, 2014). The district 

court sentenced Sorenson to 15 months in prison for each count, to be served concurrently, and assessed a fine of $200. 

See Judgment, Sorenson, 4:2014-cr-00103 (S.D. Iowa Jan. 17, 2017). The Eighth Circuit Court of Appeals affirmed the 

district court’s sentence on December 12, 2017. See United States v. Kent Leroy Sorenson, 705 Fed. Appx. 481 (8th Cir. 

Dec. 12, 2017). 

6 Report to the Iowa Senate Ethics Committee on the Investigation of State Senator Kent Sorenson (Oct. 2, 

2013) (the “Independent Investigator’s Report”). At the time that the Commission made its initial findings, the 

Independent Investigator’s report was available on the Des Moines Register’s webpage. The report is now archived at: 

https://wayback.archive-it.org/all/20131029082608/http://www.desmoinesregister.com/assets/pdf/

Sorenson_investigation_part1.pdf (Volume 1) and https://wayback.archive-it.org/all/20131029082719/

http://www.desmoinesregister.com/assets/pdf/Sorenson_investigation_part2.pdf (Volume 2). 7

 See Factual and Legal Analysis at 1–4, MUR 6800 (Ron Paul 2012 Presidential Campaign Committee, Inc., et 

al.) (citing Stipulated Statement of Facts, Sorenson, 4:14-cr-103 (S.D. Iowa Aug. 27, 2014); and Independent 

Investigator’s Report, supra). 8 Department of Justice Press Release, Former Iowa State Senator Pleads Guilty to Concealing Federal 

Campaign Expenditures (Aug. 27, 2014) https://www.justice.gov/opa/pr/former-iowa-state-senator-pleads-guiltyconcealing-federal-campaign-expenditures; see also Stipulated Statement of Facts ¶¶ 12–15. 9 Stipulated Statement of Facts ¶¶ 11–12. 10 Id. ¶ 17.

MUR680000212
MURs 6800 (Ron Paul 2012 Presidential Campaign Committee, et al.) 

Statement of Commissioners Shana M. Broussard and Ellen L. Weintraub

Page 3 of 3 

In 2016, the Commission correctly found reason to believe that the Ron Paul Committee had 

knowingly accepted a prohibited corporate in-kind contribution and had failed to properly report its 

disbursements to the Commission.11 It further found that Designer Goldsmiths, Inc. had made a 

prohibited corporate in-kind contribution.12 Finally, the Commission determined that these 

violations were knowing and willful.13 At that point, the Commission was already in possession of 

extensive admissions and information establishing the violations, which could have supported 

probable cause filings. But OGC obtained even more information establishing the Ron Paul 

Committee’s involvement in making and concealing payments to Sorenson. When OGC filed its 

Second General Counsel’s Report in 2018, the criminal convictions of Kesari, Benton, and Tate — 

all Ron Paul Committee campaign officials who had been acting to benefit Paul’s campaign — for 

causing false campaign contribution reports had been affirmed by the United States Court of 

Appeals for the Eighth Circuit.14 We had all the information we needed to confirm the payments to 

Sorenson and further bolster the Commission’s findings.15 A complete record to support a finding 

of probable cause was in place.

Although the Ron Paul Committee and Designer Goldsmiths, Inc. requested that the 

Commission enter into pre-probable cause conciliation negotiations and the Commission agreed,16

those efforts floundered. Following unsuccessful negotiations, OGC, despite having already built 

an impressive factual record, recommended that the Commission abandon the matter and close the 

file.17 

Given the extensive factual record already in possession of the Commission, and the fact 

that the Commission still had time to pursue this matter and seek civil penalties, we voted to direct 

OGC to draft probable cause briefs and move to the next stage in the enforcement process. Two of 

our Republican colleagues did not think that this activity was worth pursuing.18 As a result, the Ron 

Paul Committee and Designer Goldsmiths, Inc. will never be held accountable for their roles in the 

scheme. 

_______________________ __________________________ 

Date Shana M. Broussard

Commissioner

_______________________ __________________________ 

Date Ellen L. Weintraub 

Commissioner

11 See Certification MUR 6800 (June 16, 2016). 12 Id. 13 Id. 14 See United States v. Jesse Benton, John Tate, and Dimitrios Kesari, 890 F.3d 697 (8th Cir. May 11, 2018). 15 Second Gen. Counsel’s Rpt. at 3, MUR 6800. 16 See Certification, MUR 6800 (Mar. 19, 2019). 17 See Memorandum to the Commission Regarding Recommendation to Close the File, MUR 6800 (June 14, 

2021). 

18 Certification, MUR 6800 (Aug. 31, 2021). One colleague was recused from this matter.

February 11, 2022

February 11, 2022

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