Everyone has a price

With Roger Sollenberger, Political Reporter

Pay Dirt is a weekly foray into the pigpen of political funding. Subscribe here to get it in your inbox every Thursday.

The Big Dig this week is… Donald Trump’s Dark-Money Maze

An inquiry from the feds has thrown new light on the murky relationships between a dozen Trump-aligned groups. And the problem traces back, as do so many other problems in Trumpworld, to a familiar name: former top aide Corey Lewandowski.

When Lewandowski got himself fired from a pro-Trump super PAC last fall—after allegedly sexually assaulting a big donor—the group brought in a clean-up crew. When Lewandowski refused to step down, they opened up a new super PAC without him.

That super PAC—the preposterously titled “Make America Great Again, Again!”—was the 12th in a labyrinth of political groups and nonprofits that comprise the Trump fundraising network. And it may have been the one that finally tipped the scales: Federal election officials now want to know why some of the super PAC’s payments aren’t being properly reported.

Unprecedented for an Un-President

Brendan Fischer, deputy executive director of good government group Documented, said the extent of Trump’s network is unparalleled.

“It is worth emphasizing: All of this is totally unprecedented for a former president,” Fischer told The Daily Beast. “Even if Trump kept it simple, and just had one hard money PAC, a single super PAC, and a pair of 501(c)(3)/501(c)(4) nonprofits, there would be no parallel with any former president in American history.”

Anyone who’s taken even the quickest of peeks at Trump’s personal financial disclosures would recognize the pattern.

His first such disclosure revealed positions with more than 500 entities, nearly 400 of which used his name or initials. And Trump has “organized” the mess in a stultifying Russian-nesting-doll structure—companies within companies within companies.

This isn’t an accident. The layout gives the Trump Organization financial flexibility, while making it difficult to follow the billions of dollars that Trump, his family, and his accountants move across the organization.

When Trump hauled his private life into politics, he brought this practice with him, too.

The full apparatus counts a dozen separate political committees and dark money organizations. Almost all of them share one of three names.

Here they are:

Make America Great Again PAC (converted from the old Trump campaign)
Make America Great Again Action (super PAC)
Make America Great Again, Again! (super PAC)
Trump Make America Great Again (small-dollar joint fundraising committee)
Make America Great Again Policies Inc (a 501(c)(4) nonprofit)
America First Policy Institute (a 501(c)(3) nonprofit)
America First Works (formerly America First Policies; a 501(c)(4) nonprofit)
America First Legal Foundation (a 501(c)(3) nonprofit)
America First Action (super PAC)
Save America (leadership PAC)
Save America (joint fundraising committee)
Trump Victory (high-dollar joint fundraising committee)

The Trump-endorsed America First Action super PAC pulled in nearly $200 million between 2017 and 2020. Its sister nonprofit, America First Works—formerly America First Policies—posted $51.3 million in revenue for 2020, doling out nearly $40 million in grants.

The TMAGA PAC raised $884 million for 2020, with Trump Victory tossing in another $336.3 million. Those guns mostly fell quiet last year, while Trump’s three new PACs built up a $124.4 million stash, with another $12.5 million in the MAGAA! super PAC.

We won’t know how much those other dark money nonprofits raised in 2021, or what they did with it, until after the midterms.

As Trump gears up for 2024, these groups are in various stages of repair. However, that also appears to have created some internal problems. In fact, according to a filing on Wednesday, even the Trump campaign admits it isn’t always able to follow its own money.

Professor Chaos

Fischer chalked up the mess to a few factors, including Trump’s will-he-or-won’t-he candidate status, his relationship with the Republican National Committee, and disarray among his associates.

But Brett Kappel, a specialist in campaign finance and nonprofit law at Harmon Curran, perceived something more designed.

“The central lesson of Watergate is ‘Follow the money,’” Kappel told The Daily Beast. “And this byzantine structure of different types of legal entities—which are subject to different fundraising restrictions and file different reports with different agencies according to different filing schedules—appears to be designed to make that task as difficult as possible.”

FEC let me be

After Trump left the White House, the industriously sycophantic Lewandowski wormed his way back into his graces, winning the right to run the Make America Great Again Action super PAC. At the same time, he quietly created a Florida nonprofit, Make America Great Again Policies Inc.

But MAGA Policies didn’t appear to do anything—at all. There has been no reporting on any actual activity since it was created. Zero. It is a black box.

Then Lewandowski reportedly sexually assaulted a Trump donor and got himself booted from orbit. More experienced hands took over the new MAGAA! super PAC, led by former Florida attorney general Pam Bondi, and that also got complicated.

According to a new corporate filing in Florida, Bondi—who also happens to lead the massive America First Policy Institute nonprofit—also took over Lewandowski’s mysterious MAGA Policies nonprofit, adding former Trump administration officials Ric Grenell and Matt Whitaker, as well as Donald Trump Jr. paramour Kimberly Guilfoyle. All of those people are also on the new super PAC’s payroll.

But here’s the rub: The super PAC hasn’t been paying them directly. The nonprofit has, as part of a “cost share agreement.”

On Tuesday, the FEC sent the super PAC a letter saying that’s not cutting it. The group needs to explain exactly what they mean by “cost share agreement,” the letter said, because what they provided is not adequate.

For a full analysis, check out the story at The Daily Beast dot com.

From Roger's Notebook

Touch and go. A disgraced former federal judge has been quietly slipping cash to conservative politicians. The judge, 9th Circuit Appellate justice Alex Kozinski, was forced to resign in 2017 after 15 women came forward to accuse him of sexual harrassment. But over the last couple of years, Kozinski, who now runs a small private practice in California, has stepped up his political donations, contributing around $40,000 to GOP candidates in 2020, and another $15,000 since then.

It also appears Kozinski may have been trying to keep a low donor profile, at least for a while, giving in amounts that kept his totals under the $200 per candidate disclosure limit. With rare exceptions, such as major recent donations to first-time Senate candidates Blake Masters and Herschel Walker, the latter of which appeared on a filing this week, Kozinsky split his contributions into small increments—$25, $50, $100, but also much lower amounts, like $5, or $4.16. In some cases, like with his donations to Rep. Matt Gaetz (R-FL) while under investigation for sex crimes, Kozinski appears to have slammed the brakes just before he hit the $200 limit.

Scratch my back. Sen. Mike Crapo (R-ID) saw a windfall in campaign cash this week from a company who has pressing business directly before him in the Senate.

The company, Grail, has spent upwards of half a million dollars this year lobbying to pass a House bill that would expand Medicare to cover early detection cancer screening—Grail’s specialty. Turns out, Crapo has been the Senate sponsor of that very same bill.

At the same time, Grail is also the subject of intense legal and regulatory battles in the U.S. and Europe. The Federal Trade Commission sued Grail last year to block a multibillion-dollar acquisition process from its former parent company.

Crapo, who has framed early cancer detection as a pillar of his re-election bid, also happens to be the top Republican on the Finance Committee, and would likely become chair if he wins re-election and the GOP takes the Senate.

On Monday and Tuesday, Crapo received a combined $26,700 between Grail executives and the company’s PAC, with Grail-hired lobbyists chipping in a few thousand on top of that.

More like Lauren D’oh!-bert. Rep. Lauren Boebert (R-CO) has never had the cleanest finances in Congress. Last year, she reported spending donor funds on personal rent and utilities, then had to pay it back. She also misreported her husband’s million-dollar consulting income in apparent violation of House ethics rules, and at one point her campaign claimed in an FEC filing that she represented the state of Utah.

But despite overhauling her campaign’s compliance team at the beginning of this year, the problems have persisted. Last week, the FEC flagged tens of thousands of dollars in excessive contributions to the Boebert campaign. And that might take another bite out of what was already a thin first-quarter fundraising haul.

Good news. Justice Department prosecutors secured a guilty plea last week from a man who lied to the FEC in order to fraudulently funnel hundreds of thousands of dollars to a super PAC through bogus nonprofits, thereby concealing the true sources of the money.

Bad news. On the other end of concealed political transfers, the FEC’s Republican commissioners blocked action against Democratic congressional candidate Christy Smith, who did not disclose the names of her paid campaign staff, only the payroll company. All three Democratic commissioners voted to take enforcement action, as the FEC’s internal legal team had recommended. The split decision could set the table for a far bigger case still in the works, this one involving a shell company that the Trump campaign used to hide the recipients of more than $770 million in payments.

More from the Beast’s Politics desk

Sam Brodey and I pulled back the curtain on the relentless GOP oppo onslaught to take down Rep. Madison Cawthorn (R-NC).

Investigations reporter Jose Pagliery writes that a New York judge has ordered Trump to immediately cough up the $110,000 he owes for refusing to hand over evidence.

And it turns out that Trump’s top lawyer, Jesse Binnall, has one more thing in common with his boss—both hate paying taxes. Binnall still has a $140,000 federal lien on him for unpaid taxes dating back to 2010.

We'll be back next week with more Pay Dirt. Have a tip? Send us a note and subscribe here.

If you are on a mobile device or cannot view the images in this message, click here to view this email in your browser. To ensure delivery of these emails, please add emails@thedailybeast.com to your address book. If you no longer wish to receive these emails, or think you have received this message in error, you can safely unsubscribe.