FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) 

 ) 

Unknown Respondents, et al. ) MUR 8082 

 ) 

 

STATEMENT OF REASONS OF VICE CHAIR ELLEN L. WEINTRAUB AND 

COMMISSIONER SHANA M. BROUSSARD 

This matter concerned allegations that three political consultants illegally funnelled at least $1.27 

million in potentially illegal corporate contributions to federal and state political committees through a 

series of conduit corporations. These serious allegations implicate 52 U.S.C. § 30122, one of the most 

critical anti-corruption aspects of the Federal Election Campaign Act of 1971, as amended (the “Act”). 

The complaint’s allegations are primarily based on in-depth investigative reporting by the Orlando 

Sentinel — a newspaper founded in 1876 and the recipient of multiple Pulitzer Prizes, including one for 

investigative reporting. The Sentinel’s reporting on this scheme was detailed and well-sourced, with the 

paper having internal emails and memoranda from the political consultants discussing the scheme in its 

possession. The Sentinel’s reporting provided a credible allegation of a significant violation that the 

conduit corporations made contributions in the name of another, warranting further investigation into the 

true source of the funds1

 Unfortunately, the Commission could not muster the requisite four votes to 

pursue that investigation.2

 

This Commission exists because of the intrepid investigative reporting that revealed the 

Watergate scandal. Watergate inspired a raft of bipartisan legislation aimed at restoring American’s faith 

in government, and one of those laws created this agency. For 50 years, this Commission has benefitted 

from the efforts of independent journalists in fulfilling its mission of providing transparency and 

accountability as mandated by law. Some of the most significant allegations that the Commission has 

considered were initially brought to light by investigative reporting.3

The Commission should consider all sources of credible information when making reason to 

1

 Federal Election Commission, Statement of Policy Regarding Commission Action in Matters at the Initial Stage in 

the Enforcement Process, (Mar. 7, 2024) (“A ‘reason to believe’ finding followed by an investigation would be appropriate 

when a complaint credibly alleges that a significant violation may have occurred, but further investigation is required to 

determine whether a violation in fact occurred and, if so, its exact scope.”), https://www.fec.gov/resources/cmscontent/documents/mtgdoc-24-10-A.pdf. 

2

 Cert. ¶ 2 (Feb. 8, 2024).

3

 See, e.g., MUR 7122 (American Pacific International Capital, Inc., et al.) ($1.3 million foreign national 

contribution). 

MUR808200515
MUR 8082 (Unknown Respondents, et al.) 

Statement of Vice Chair Ellen L. Weintraub and Commissioner Shana M. Broussard 

Page 2 of 2 

believe findings, including factual allegations uncovered by investigative journalism. A “reason to 

believe” finding is simply an indication that the Commission has found sufficient legal justification to 

open an investigation to determine whether there is probable cause to believe that a violation of the Act 

occurred.4

 Each detail in this complex scheme does not need to be known at the “reason to believe” 

stage; determining the facts is the purpose of the Commission’s investigative authority. 

As we have said before and we will say again, given the Commission’s history, it would be 

ironic, ahistorical, and a serious departure from precedent and practice to refuse to consider information 

derived from journalistic investigation and reporting.5

Date Ellen L. Weintraub 

Vice Chair 

Date Shana M. Broussard 

 Commissioner 

4 See Stmt. of Reasons of Vice Chair Ellen L. Weintraub & Comm’rs Cynthia L. Bauerly and Steven T. Walther at 1 

n.2, MUR 6441 (Unknown Respondents) (Aug. 15, 2012) (citing 12 F.R. 12545, Statement of Policy Regarding Commission

Action in Matters at the Initial Stage in the Enforcement Process (March 16, 2007)).

5 See, e.g., Stmt. of Reasons of Stmt. of Reasons of Comm’rs Shana M. Broussard & Ellen L. Weintraub at 4-5, MUR 

7784 (Make America Great Again PAC, et al.) (June 15, 2022). 

April 9, 2024

April 9, 2024

MUR808200516