MYSTERY
MONEY
How a loophole could allow foreign money to flow
into super PACs through secretive shell companies

 ACKNOWLEDGMENTS
This report was written by Research Director Michael Beckel and Research Associate Amisa
Ratliff. Design by Communications Associate Sydney Richards.
Cover image credit: bioraven/Shutterstock.com

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[ 2 — Mystery Money ]

Issue One

 MYSTERY
MONEY
BY MICHAEL BECKEL & AMISA RATLIFF

INTRODUCTION

M

oney laundering schemes to illegally funnel foreign money into super PACs
through shell companies threaten the integrity of our political system.

Since the Supreme Court’s Citizens United decision in 2010 paved the way for the
super PAC era, there has been a proliferation of corporate super PAC donors —
including scores of opaque and obscure companies that allow the people behind them
to remain hidden. Such secretive entities provide especially ideal cover for foreigners
wishing to evade the existing prohibition on their involvement in U.S. elections.
A new Issue One analysis shows why this loophole needs to be closed. Issue One’s
extensive examination of campaign finance records identified a number of super PAC
contributions from limited liability companies (LLCs) and other opaque business entities
that raise eyebrows and reveal blind spots in existing transparency rules.
While some of the corporate super PAC contributions investigated by Issue One
could be linked to the people behind them, these connections could only be found
by unearthing little-known public records — cumbersome steps that few members
of the public or press have the time to do. And concerningly, in some cases, it was
impossible to learn from public records alone the true sources of the funds involved
or the identities of the people controlling these obscure companies. Indeed, many of
the cryptic companies identified by Issue One are registered in Delaware, which has
been described by the Institute on Taxation and Economic Policy as “one of the easiest
jurisdictions in the world to set up an untraceable shell company.”

Issue One

[ Mystery Money — 3 ]

 SHELL COMPANY SHENANIGANS
While super PACs are required by law to publicly
reveal their donors, sometimes the donors they
list are little more than opaque shell companies.
Among the notable super PAC contributions
from obscure and opaque groups this election
cycle were the following:
─  River Birch LLC and Willow LLC — two
companies tied to Jim Ward and Fred Heebe,
a pair of Louisiana businessmen who have
been accused of bribing a politician in New
Orleans — have contributed $300,000 since
2015 to a super PAC called New Horizons
USA that has mostly aided Democrats in
Louisiana, including $50,000 last October.
Strangely, $200,000 in contributions from
these two LLCs that were reported to state
regulators appear to be missing from the
super PAC’s federal campaign finance filings,
which should have been identical to its
state-level reports.
─  East Coast Plumbing LLC, a little-known
New Jersey-based company that appears to
be associated with New York City billionaire
Steven Roth — who has served as an
economic adviser to President Donald Trump
— contributed $250,000 in November to the
Senate Leadership Fund, a super PAC that
supports Republican Senate candidates.
─  A mysterious New York-based company
called Tomfoolery LLC, which, in campaign
finance filings, simply listed a 60-story

If foreign actors seize
on this loophole,
they are likely to
go unnoticed and
unthwarted.

skyscraper in New York City as its address
and could not be conclusively linked to any
particular person, contributed $75,000
earlier this year to Lone Star Forward, a
liberal super PAC active in Texas.
─  A Democratic super PAC called Mind the
Gap collected $50,000 last year from an
obscure 501(c)(4) “social welfare” nonprofit
called MTG Research, which formed in
Delaware just a month prior to giving away
these funds and will never be required to
publicly disclose its donors.
─  A little-known Delaware-based company
called Victory Marketing LLC — that said
it performed $40,500 worth of services for
a super PAC called Action Coalition PAC
between October 2017 and March 2019
— was actually part of a scheme that bilked
conservative donors to the tune of tens
of millions of dollars, according to federal
prosecutors.

Why is super PAC donor transparency important?
Transparency allows the public to assess who is behind the political ads they see from super
PACs. It also helps empower the public and the press to hold politicians and special interests
accountable. When super PACs simply list opaque shell companies or secretive dark money
groups as contributors, the public is left in the dark about the true identity of the sources of the
money being spent to influence elections.

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Issue One

 Are all contributions from LLCs suspicious?
No, not all LLCs are suspicious. In most states, it’s easy to determine the actual people behind
an LLC. But in some states — most notably Delaware and Wyoming — public records need not
identify any living, breathing people associated with LLCs, essentially making them black boxes.

─  Jersey Bay Holdings LLC, a low-profile
company that appears to be tied to Uriel
Cohen, an investor operating in the U.S.
Virgin Islands with a scant history of
previous political giving, contributed
$25,000 in November to America First
Action, the main super PAC supporting
Trump’s reelection.
Additionally, at least two LLCs highlighted in
this report appear to have been formed solely to
make political expenditures:
─  The Florida-based Race Fans for Trump
2020 LLC gave $27,000 earlier this year to
Patriots PAC of America, a super PAC that
sponsored multiple Trump-themed NASCAR
vehicles.
─  The Hawaii-based Society of Young
Women Scientists and Engineers LLC
gave $150,000 last year to 1820 PAC, a
super PAC supporting the reelection of Sen.
Susan Collins (R-ME). The Campaign Legal
Center has already filed a complaint with the
Federal Election Commission (FEC) alleging
that this LLC violated campaign finance laws.
While Democratic and Republican FEC
commissioners alike have said that intentionally
using business entities such as LLCs to mask
one’s identity is illegal, enforcement actions
against those who break this rule have been
rare.

A BROKEN SYSTEM
The dozen case studies in this report together
illustrate a broken campaign finance system
Issue One

that allows deep-pocketed donors to remain
anonymous and avoid scrutiny. Clearly, these
cases are just the tip of the iceberg. And it’s
especially important to call attention to this
issue now as the country enters the final months
of the 2020 election, when even larger sums of
money are expected to pour into super PACs
and campaigns across the country.
Worryingly, if foreign actors seize on this
loophole, they are likely to go unnoticed and
unthwarted, which could be calamitous for the
country. Congress and the FEC need to act now
to prevent major scandals.
The Justice Department has already said that
foreign actors have used shell companies to
pump money into U.S. elections at least twice
in recent years. In one case, scandal-plagued
Malaysian financier Low Taek Jho allegedly
provided money to rapper Pras Michel of the
Fugees through shell companies to help bankroll
a pro-Barack Obama super PAC in 2012. And in
another, an unidentified Russian businessman
allegedly was the true source of money
donated to a pro-Trump super PAC in 2018 by
a shell company associated with businessmen
Lev Parnas and Igor Fruman, who became
household names for their involvement in the
Ukraine scandal.

WHAT CAN BE DONE?
Violations of the law are likely to continue until
new laws and regulations are implemented,
including more transparency for LLC super PAC
donors and stiffer penalties for Americans who
help foreign nationals use business entities like
LLCs to evade anti-corruption laws. It is bad
public policy to simply rely on a super PAC’s
[ Mystery Money — 5 ]

 word that the funds they receive — especially
money from mysterious donors — are not from
foreign nationals.
There are two main ways to stop foreigners
from abusing LLCs and other business entities
to influence our elections: Congress needs
to strengthen the law, and the FEC needs to
enhance existing transparency rules to help give
the public more confidence that the law is being
followed.
To strengthen the law, Congress should pass
the Shell Company Abuse Act to stop foreigners
from using tax loopholes to engage in illegal
political activity. This commonsense, bipartisan
proposal would make it a felony for Americans
to establish — or help establish — business
entities that conceal illegal political activities
by foreign nationals. This includes the owners,
officers, incorporation agents, and attorneys for
companies, including LLCs.
The Shell Company Abuse Act has been
sponsored by Sens. Richard Blumenthal (DCT), Dick Durbin (D-IL), Chuck Grassley (RIA), Lindsey Graham (R-SC), and Sheldon
Whitehouse (D-RI).
Additionally, the FEC should bolster the public’s
confidence that foreigners aren’t using business
entities to illegally influence our elections by
strengthening current regulations to shine more
light on the people behind corporate super PAC
donations.

The dozen case studies
in this report together
illustrate a broken
campaign finance
system that allows
deep-pocketed donors
to remain anonymous
and avoid scrutiny.

Individuals have long been allowed to use
certain LLCs to make donations to federal
candidates. But these contributions are required
by law to show both the name of the LLC and
the name of the person, or people, responsible
for the money. This same principle should be
extended to corporate super PAC donors: The
same amount of information should be publicly
revealed regardless of whether an LLC gives
money to a candidate or a super PAC. •

Here’s how super PACs could be even more transparent when
reporting LLC donors:
When Unite the Country — the main super PAC supporting Democrat Joe Biden’s presidential
campaign in the primary — received $100,000 in December from a Delaware-based LLC called
BPG Real Estate Services LLC, it voluntarily included a note specifying that the money was
actually from three men behind the company: Christopher Buccini, Robert Buccini, and David
Pollin. All super PACs should embrace this practice.

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Issue One

 CASE
STUDIES
12 notable super PAC donations that illustrate blind
spots with existing transparency rules

 TABLE OF
CONTENTS
Large political contributions from completely unknown sources

9

─  Tomfoolery LLC: $75,000 to Lone Star Forward, a super PAC that supported Democratic Senate
candidate Cristina Tzintzún Ramirez in Texas
─  MTG Research: $50,000 to the Democratic-aligned super PAC Mind the Gap

Business entities that appear to have been formed to make political expenditures

11

─  Society of Young Women Scientists and Engineers LLC: $150,000 to 1820 PAC, a super PAC
supporting Republican Sen. Susan Collins in Maine
─  Race Fans for Trump 2020 LLC: $27,000 to Patriots PAC of America, a pro-Trump super PAC

Mysterious LLCs linked to specific individuals thanks to obscure records

13

─  East Coast Plumbing LLC: $250,000 to the Repubican-aligned super PAC Senate Leadership Fund
─  Jersey Bay Holdings LLC: $25,000 to the pro-Trump super PAC America First Action
─  Wasatch Partners LLC: $25,000 to New Day for America, a super PAC associated with Republican
John Kasich, the former governor of Ohio
─  Big Hen Group I LLC: $12,000 to Swing Left, a pro-Democratic super PAC

LLCs associated with controversial donors

16

─  River Birch LLC and Willow LLC: $300,000 to New Horizons USA, a super PAC that has supported
politicians in Louisiana, including Democratic Gov. John Bel Edwards
─  RS LLC: Roughly $160,000 to political candidates and groups on both sides of the aisle, including
$10,000 to the LGBTQ Victory Fund super PAC

An obscure LLC that is part of a shadowy political operation

18

─  Demeter Analytics Services LLC: Approximately $220,000 to VFA PAC, a super PAC that is part of
the political network built by conservative billionaires Charles and David Koch

An opaque LLC used in a conspiracy to defraud donors

19

─  Victory Marketing LLC: Reported about $40,500 worth of phone banking, direct mail, and
compliance consulting services for a super PAC called Action Coalition PAC that never occurred, as
part of a scheme that bilked conservative donors

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Issue One

 LARGE POLITICAL CONTRIBUTIONS FROM
COMPLETELY UNKNOWN SOURCES
Tomfoolery LLC
In February 2020, an obscure New York-based
company called Tomfoolery LLC contributed
$75,000 to Lone Star Forward, a super PAC
active in Texas that supported Democrat Cristina
Tzintzún Ramirez, a labor organizer and writer,
during her unsuccessful Senate campaign.
Public records alone provide scant information
— and no resolution — about who directed this
super PAC contribution, which accounted for
more than a quarter of the roughly $276,000
raised by Lone Star Forward. During the
Democratic Senate primary, in which Tzintzún
Ramirez finished third, she pledged not to
accept support from “corporations or corporate
PACs.”
The only clue in campaign finance records about
who is behind Tomfoolery LLC is an address at
28 Liberty Street, a 60-story skyscraper in New
York City whose many clients include multiple
firms that specialize in incorporation services,
meaning countless companies that do not have
a physical office at that address could use it as
their own. The FEC records do not list a suite
number.
An Issue One review of business records
uncovered two separate companies with the
name Tomfoolery LLC that have links to 28
Liberty Street — one formed in New York in
2004 and one formed in Delaware in 2017.
New York business records list a Tomfoolery LLC
based at an address in Monroe County, about a
five-hour drive from New York City. According
to property tax records, this address is a singlefamily home owned by Thomas Kanzler and Jeri
Teller-Kanzler, the director of cybersecurity at
Avangrid Inc., an energy company previously
known as Iberdrola USA that is owned by
Spanish energy giant Iberdrola. Some of
Avangrid’s business filings list as its registered

Issue One

A review of public
records alone cannot
determine who made the
donation to the Lone Star
Forward super PAC using
Tomfoolery LLC.

agent the firm National Registered Agents Inc,
at 28 Liberty Street in New York City — the
same address that Tomfoolery LLC used in its
FEC filing.
Meanwhile, Delaware business records show that
a separate company also named Tomfoolery
LLC was formed there in 2017. These records
list this company’s registered agent as The
Corporation Trust Company, a business
that specializes in forming corporations and
LLCs. Delaware business records obtained by
Issue One show that this Tomfoolery LLC’s
“authorized person” is currently listed as Justyn
Volesko, co-founder and managing partner at
AJ Wealth, a financial planning firm in New York
City based at 28 Liberty Street — the address
of the skyscraper listed on the FEC records for
Tomfoolery LLC.
Because many LLCs aren’t required to divulge
much information publicly, a review of public
records alone cannot determine which of these
LLCs made the donation to the Lone Star
Forward super PAC, or at whose direction the
donation came.

[ Mystery Money — 9 ]

 MTG Research
In May 2019, an obscure Delaware-based
organization called MTG Research donated
$50,000 to a Democratic-aligned super PAC
called Mind the Gap — a little-known group
operated by a trio of academics at Stanford
University and primarily funded by a network of
Silicon Valley donors.
In its articles of incorporation, which were
filed in April 2019, MTG Research describes
itself as a 501(c)(4) “social welfare” nonprofit
focused on “fostering the civic involvement and
engagement of underrepresented or historically
disadvantaged populations.”

Even when MTG Research
files its first tax return with
the IRS — which won’t
happen until long after the
2020 election is over — that
document will not detail who
funded its operations.

[ 10 — Mystery Money ]

It’s not clear if any of the Stanford academics
behind Mind the Gap — Barbara Fried, Paul
Brest, and Graham Gottlieb — are also
associated with MTG Research. The only person
listed on the group’s incorporation records is
Pat Moore, a former Obama White House lawyer
who now works at Hemenway & Barnes, a
Boston-based law firm that has also been paid
for legal services by the Mind the Gap super
PAC.
Where did MTG Research get $50,000 in less
than two months to give to the Mind the Gap
super PAC? Nothing in the public record can
answer that question. And even when MTG
Research files its first tax return with the IRS —
which won’t happen until long after the 2020
election is over — that document will not detail
who funded its operations.

Issue One

 BUSINESS ENTITIES THAT APPEAR TO HAVE BEEN
FORMED TO MAKE POLITICAL EXPENDITURES
Society of Young Women Scientists and Engineers LLC
On December 31, 2019, a mysterious LLC
called Society of Young Women Scientists and
Engineers donated $150,000 to 1820 PAC, a
super PAC that is supporting the reelection of
Sen. Susan Collins (R-ME).
The Hawaii-based LLC had formed just five
weeks earlier, on November 26. The company
does not appear to have a website or business
revenue, which led the Campaign Legal Center
to conclude that there was reason to believe
that the group, and any of its contributors,
broke the law by using a shell company to hide
the true identity of the donor or donors.
Just one name is listed on the incorporation
records of the LLC: Jennifer Lam, who is
identified as the manager of the LLC as well
as its agent. According to an investigation by
the Honolulu Civil Beat, this is likely Tiffany
Jennifer Lam, the wife of Martin Kao, who is the
CEO of Navatek, a Honolulu-based engineering
company that recently received an $8 million

defense contract in Maine. The couple has also
each contributed the legal maximum of $5,600
to Collins’ reelection campaign.
In a complaint filed with the FEC in February,
the Campaign Legal Center cited Society of
Young Women Scientists and Engineers’ lack of
a website, social media accounts, or business
record, as well as the short period of time
between the LLC’s formation and its contribution
to argue there is little evidence the group had
sufficient income to cover the contribution to
1820 PAC “without an infusion of funds provided
to them for that purpose.”
The Campaign Legal Center further argued
that the group should register as a political
committee and disclose its donors because
there is no record of Society of Young Women
Scientists and Engineers “conducting any
significant activities other than making
contributions since its formation.”

Race Fans for Trump 2020 LLC
A short-lived super PAC called Patriots PAC
of America spent tens of thousands of dollars
promoting President Donald Trump’s reelection
around the Daytona 500 in February. The super
PAC sponsored multiple NASCAR vehicles
emblazoned with Trump’s name and campaign
logo, although one of them did not compete in
Daytona due to a traffic accident en route.
Henry John “Hank” Foley of Daytona Beach,
Florida, a Delta Airlines pilot, registered the
Patriots PAC of America super PAC with the
FEC on January 10. NASCAR driver Tim Viens, a
Issue One

vocal Trump supporter who was slated to drive
the vehicle that had to be scratched, was also
listed on the form as the PAC’s “designated
agent.”
Over the course of three days in early February,
Patriots PAC of America received $27,000 from
a Florida-based company called Race Fans for
Trump 2020 LLC — which had been formed
by Foley just a few days earlier — and paid
$25,000 to Mike Harmon Racing for NASCAR
sponsorships.

[ Mystery Money — 11 ]

 Within two weeks, Race Fans for Trump 2020
LLC dissolved. And shortly afterwards, on March
2, Patriots PAC of America also shut down, with
Race Fans for Trump 2020 LLC accounting for
99% of the money the group raised.
In May, Brendan Fischer of the Campaign Legal
Center told The Daily Beast that “there are
some apparent legal violations here” because
“it seems apparent that the $27,000 came
from a source other than the LLC, which does
not appear to have any legitimate business or
investment revenue.”
FEC commissioners have warned that if a
corporate entity is “created and operated for the
sole purpose of making political contributions,”
that could raise flags for possible enforcement
actions.
Where did Race Fans for Trump 2020 LLC get
$27,000 to donate to this super PAC in just a
few days? It’s not clear.
Florida business records indicate that Race Fans
for Trump 2020 LLC had just three members:
─  Alpha 1 Management LLC (a company Foley
created in November 2019),
─  Specter Enterprise LLC (a company formed
in November 2019 by Wendell Dallarosa,
a former Daytona Beach police officer who
now lives in Port Orange, Florida), and
─  Safe Marketing Group (a company without
much of a paper trail that is also listed as a
member of a separate LLC Foley created in
February 2020).

Where did Race Fans
for Trump 2020 LLC get
$27,000 to donate to this
super PAC in just a few
days?

storage container company that earned national
attention after its founders — Adam and Desiree
Haller — made a $100,000 deal on ABC’s
“Shark Tank” last year. Notably, Viens previously
partnered with Desiree Haller on a company
called Boat Gadget, which sold a device
marketed as “the ultimate 10-in-1 boat tool.”
Neither Viens, Foley, nor the Hallers have
histories of making large federal-level political
contributions, although Viens was going to put
down $25,000 for the deposit for the NASCAR
vehicle that Patriots PAC of America had to pull
from the race in Daytona. Meanwhile, Dallarosa
has contributed about $22,000 to Republican
candidates and groups in recent years.
While Patriots PAC of America is no more, Foley
launched a second super PAC earlier this year
called Patriots of America PAC, which continues
to tout Viens and Trump-themed NASCAR
vehicles, including spending another $350,000
on racing sponsorships in June.

The only detail known about Safe Marketing
Group — which is not registered with the Florida
Secretary of State’s office — is its address,
which is in an industrial warehouse office park in
Port Orange, Florida. The same address is also
listed on Facebook by Viens, the NASCAR driver,
as a way for fans to contact him.
Viens and Safe Marketing Group appear to
share this address with SubSafe, a plastic food

[ 12 — Mystery Money ]

Issue One

 MYSTERIOUS LLCs LINKED TO SPECIFIC INDIVIDUALS
THANKS TO OBSCURE RECORDS
East Coast Plumbing LLC
In November 2019, the Senate Leadership Fund
— the main super PAC supporting Republican
Senate candidates — reported receiving
$250,000 from an obscure Lodi, New Jerseybased company called East Coast Plumbing LLC.
From the campaign finance filing alone, it’s
not immediately clear who is behind this
contribution. But extensive research by Issue
One suggests the company is associated with
New York City billionaire Steven Roth, who has
served as an economic adviser to President
Donald Trump.
The address listed for East Coast Plumbing
LLC in the super PAC’s campaign finance filing
— Route 17 & 17 Robinson Road — is a onestory industrial building owned by Interstate
Properties, a company based in nearby Paramus,
New Jersey.

largest property owners in New York City.
Vornado’s CEO and board chairman is billionaire
Steven Roth, who emerged last year as a major
Republican donor.
Vornado also co-owns two skyscrapers with the
Trump Organization, and in 2017, it was even
reportedly one of the finalists for the nowstalled project to redesign the FBI’s Washington,
D.C., headquarters.
Another piece of evidence that suggests Roth
is connected to this super PAC contribution:
Jay Beckoff, Vornado Realty Trust’s senior
compliance manager, is listed as the “authorized
signatory” on East Coast Plumbing LLC’s
2010 certificate of formation, which Issue One
obtained from the Delaware Secretary of State’s
office. Unfortunately, this document is not
required to identify the company’s owner.

Interstate Properties’ Paramus address is
shared with Vornado Realty Trust, one of the

Jersey Bay Holdings LLC

In November 2019, America First Action —
the super PAC that President Donald Trump’s
campaign has endorsed as the sole “approved
outside non-campaign group” supporting his
2020 reelection — received $25,000 from an
obscure company called Jersey Bay Holdings
LLC, which appears to be tied to an investor
operating in the U.S. Virgin Islands with a scant
history of political giving.

Issue One

“Jersey Bay” likey refers to a body of water
off the island of St. Thomas in the U.S. Virgin
Islands in the Caribbean, which were once
described by Newsweek as “a slice of paradise
that some experts consider the nation’s one and
only, officially sanctioned, full-blown offshore
tax shelter.”
Corporate records obtained by Issue One from
the Delaware Secretary of State’s office show

[ Mystery Money — 13 ]

 that Jersey Bay Holdings LLC — which has no
website and little presence online — was formed
in Delaware in March 2017. The company’s
certificate of formation was signed by Uriel
Cohen, an investor and securities trader with
more than 15 years of experience in the financial
industry.
Jersey Bay Holdings LLC’s New York City
address in campaign finance records matches
that of Alpine Global Management, an
investment firm Cohen co-founded that is
associated with a cluster of similarly named
companies in the U.S. Virgin Islands. Cohen also
founded White Bay Group, an investment firm in
the U.S. Virgin Islands.

America First Action
received $25,000 from an
obscure company called
Jersey Bay Holdings LLC,
which appears to be tied
to an investor operating
in the U.S. Virgin Islands
with a scant history of
political giving.

Cohen’s sole known prior federal-level political
contribution was $1,800 in 2016 to Virgin
Islands Del. Stacey Plaskett, a Democrat.

Wasatch Partners LLC
In October 2019, a low-profile company called
Wasatch Partners LLC made a $25,000 donation
to New Day for America, the super PAC that
supported the unsuccessful 2016 presidential
run of former Gov. John Kasich (R-OH) and
continues to help Kasich advance his political
ambitions.

Without the property records
tying Wasatch Partners
to Bob Walter and George
Bennett, there wouldn’t be
any indication of the true
source behind the LLC’s
donation.

[ 14 — Mystery Money ]

Obscure real estate records uncovered by Issue
One revealed who controls Wasatch Partners
LLC: Bob Walter, founder of the multi-billiondollar healthcare services company Cardinal
Health, and George Bennett, a former Cardinal
Health executive who still works with Walter
at Talisman Capital Partners, the private
investment company for the Walter family.
Without the property records tying Wasatch
Partners to Walter and Bennett, there wouldn’t
be any indication of the true source behind
the LLC’s donation. Ohio business records
simply list lawyers from the Cleveland-based
firm BakerHostetler as the representatives of
Wasatch Partners LLC. Those documents don’t
provide any information about the members
or owners of the LLC, which was originally
incorporated in January 2000 under the name
Deer Run South LLC.
For his part, Bennett does not have a history

Issue One

 of large contributions to Kasich’s political
committees. But Walter has long been a financial
supporter of Kasich. Data from the National
Institute on Money in Politics, which tracks state
and federal campaign contributions, shows that

Walter contributed roughly $32,000 to Kasich’s
gubernatorial campaigns between 2009 and
2013. And during Kasich’s unsuccessful 2016
presidential bid, he donated $500,000 to New
Day for America.

Big Hen Group l LLC

Swing Left was launched in the wake of the 2016
election with the goal of mobilizing progressives
to “swing” enough congressional districts
for Democrats to win control of the House of
Representatives in 2018. Today, its website says
it helps people find “the most impactful things
[they] can do to help Democrats win the most
important elections.”
Because it is registered with the FEC as a hybrid
super PAC, Swing Left is allowed to collect
contributions of unlimited size from just about
any source — including individuals, labor
unions, and companies. Since its formation,
Swing Left has raised millions of dollars,
including $12,000 earlier this year from a
little-known Delaware-based LLC called Big Hen
Group I.
Big Hen Group I LLC does not have a website.
Business records show it was registered in
Delaware on October 5, 2004, the same day an
LLC called Big Hen Group II was also registered.
Neither business filing identifies the companies’
owners; both simply list Incorporating Services
Ltd., a company that specializes in incorporation
services, as their registered agents.
Yet since its creation, Big Hen Group I LLC
has emerged as a prolific political donor. In
2012, the company donated $100,000 to an
unsuccessful ballot measure in California that
would have required genetically modified foods
to be labeled. And over the past five years, it
has contributed $500,000 to Senate Majority
PAC (SMP), the main super PAC supporting
Democratic Senate candidates.

Issue One

Who’s behind the LLC? Media articles have noted
that former Google CEO Eric Schmidt controls
Big Hen Group, and that he has used the LLC
to support political candidates and groups.
But that’s not something megadonors behind
obscure LLCs often confirm on the record.
While LLCs that contribute to super PACs are
not asked to provide additional information
about the people behind them, if the same
company donates to a federal candidate, party
committee, or traditional PAC, it is required
to provide the name of the person, or people,
behind the contribution. To wit: Big Hen Group I
LLC identified Schmidt as the true source behind
its $319,500 contribution to the Democratic
National Committee last year.
If the same rule that currently applies to other
political groups is extended to super PACs, the
public won’t be left in the dark about the true
sources of money from opaque LLCs.

If the same rule that
currently applies to other
political groups is extended
to super PACs, the public
won’t be left in the dark
about the true sources of
money from opaque LLCs.

[ Mystery Money — 15 ]

 LLCs ASSOCIATED WITH CONTROVERSIAL DONORS
River Birch LLC and Willow LLC
River Birch LLC and Willow LLC — two
companies tied to a pair of Louisiana landfill
owners who have been accused of bribing a
politician in New Orleans — have contributed
$300,000 since 2015 to a super PAC called New
Horizons USA, including $50,000 last October.
These contributions account for roughly 98% of
the $306,000 that New Horizons USA has raised
since its formation, according to an Issue One
analysis of Louisiana campaign finance filings.
The owners of River Birch LLC and Willow LLC
are Jim Ward and his stepson Fred Heebe, who
have been accused of bribing then-New Orleans
Mayor Ray Nagin in the wake of Hurricane
Katrina with $20,000 in campaign cash funneled
through shell companies they controlled in order
to receive preferential treatment, according to a
civil racketeering lawsuit that is slated to go to
trial in November.
Ward and Heebe were also the subjects of a
years-long criminal bribery investigation by the
U.S. Department of Justice, which was ultimately
abandoned after some of the prosecutors
involved engaged in misconduct. River Birch LLC
also faces a lawsuit filed in 2012 by the state
ethics board, which has been on hold because of
the other litigation.

Ward and Heebe have denied all wrongdoing in
the civil racketeering case, as has Nagin, who
is currently serving a 10-year federal prison
sentence for a separate bribery case.
Using shell companies to evade campaign
contribution limits is illegal, but Ward
acknowledged in a deposition that he and Heebe
used multiple companies to give Nagin more
than the legal limit because “we didn’t want to
go being as obvious as it — as it was.”
Ahead of Louisiana’s November 2015 election,
New Horizons USA spent $17,000 on TV ads
critical of one of the Republican candidates
running for lieutenant governor, and in October
2018, New Horizons USA PAC transferred
$200,000 to Gumbo PAC, a super PAC that
spent heavily to help incumbent Democratic Gov.
John Bel Edwards win reelection in 2019.
Curiously, several large contributions and
expenditures seem to be missing from New
Horizons USA’s federal campaign finance filings.
For one, its $200,000 contribution to Gumbo
PAC was only reported in state campaign
finance documents — filings that should have
been identical to its federal ones. And a pair of
$100,000 contributions to New Horizons USA
in October 2018 — one from River Birch LLC
and another from Willow LLC — were also only
reported in state campaign finance filings, not
federal ones. It is illegal to file false campaign
finance reports with the FEC.

It is illegal to file false
campaign finance
reports with the FEC.

[ 16 — Mystery Money ]

Issue One

 RS LLC
In less than three years, a little-known
company called RS LLC — which has an almostnonexistent online presence — has become
a prolific political donor, including donating
$10,000 last year to the LGBTQ Victory Fund,
a hybrid super PAC that works to elect “LGBTQ
leaders at every level of government.”
RS LLC was created in August 2017 by the
Oklahoma-based Otoe-Missouria Tribe.
According to business records filed in Kansas,
its director is Ted Grant, the tribe’s vice
chairman.
Since then, RS LLC has contributed roughly
$160,000 to a mix of Democratic and
Republican candidates and groups, according
to data from the National Institute on Money in
Politics, which tracks state and federal campaign
contributions. Nearly half of this sum went to
state attorney general candidates across the
country, including Georgia, New Mexico, and
Nevada.

actions by the Consumer Financial Protection
Bureau, which the tribe unsuccessfully appealed
to the U.S. Supreme Court in 2017.
Federal court records indicate that RS LLC
is “a wholly owned subsidiary” of Red Stone
Inc., another tribal entity created by the OtoeMissouria Tribe. Both Red Stone Inc. and RS
LLC are identified in court records as part of
a network of tribal lending operations that a
federal judge last year ruled were being used
by an online-lending businessman for their
immunity from U.S. usury laws in exchange for
monetary payments.
The controversial nature of RS LLC has led at
least one political candidate to part with money
from the company. In 2018, Letitia James,
the Democrat who is now New York’s attorney
general, refunded a $10,000 contribution to
RS LLC after the media raised questions about
her accepting money from a lender whose
operations were banned in the state.

What type of business is RS LLC exactly?
Answering that question requires a tremendous
amount of research.
Corporate records filed in Kansas describe RS
LLC as an “arm” of the Otoe-Missouria Tribe,
which has been an active player in the shortterm, high-interest lending industry for roughly
10 years — sometimes offering short-term
loans and installment loans with interest rates in
the range of 400% to 700%.
Because of these exorbitant interest rates,
lending companies associated with the OtoeMissouria Tribe have earned the ire of state and
federal regulators in recent years. New York
banned some of their lending operations in
2014. Regulators in Connecticut fined the tribe
and two of its companies $1.5 million in 2015.
And they’ve been the target of enforcement

Issue One

The controversial
nature of RS LLC has
led at least one political
candidate to part
with money from the
company.

[ Mystery Money — 17 ]

 AN OBSCURE LLC THAT IS PART OF A SHADOWY
POLITICAL OPERATION
Demeter Analytics Services LLC
Since it was formed in 2013, an obscure super
PAC called VFA PAC has raised about $220,000
— all of it from a little-known company called
Demeter Analytics Services LLC, including
$60,000 since April 2019. VFA PAC has never
run any political ads. Instead, it has mostly used
its money to purchase voter lists, which are then
combined with consumer information to create
profiles of voters for targeting by the political
network built by conservative businessmen
Charles and David Koch.
In November 2015, Politico described Demeter
Analytics Services as “the holding company”
for the data analytics firm i360, which has been
called the Koch brothers’ “data mine.” In filings
with the IRS over the years, Demeter Analytics
Services has been described as a wholly
owned subsidiary of multiple Koch-connected
nonprofits, including the Kochs’ flagship
Freedom Partners Chamber of Commerce and,
prior to that, a group called Themis Trust.

While the money flowing
through Demeter Analytics
Services can be tied to the
Koch brothers’ political
network, it is virtually
impossible to link the funds
the LLC has donated to VFA
PAC to a specific individual
or group of people.

[ 18 — Mystery Money ]

Through Themis Trust and the Freedom Partners
Chamber of Commerce, the Koch network has
paid roughly $48 million to Demeter Analytics
Services since its formation. FEC filings show
that Demeter Analytics Services LLC also
earned $200,000 in list rental income from the
unsuccessful 2016 presidential campaign of
Republican Ben Carson, who now serves as the
secretary of Housing and Urban Development.
While the money flowing through Demeter
Analytics Services can be tied to the Koch
brothers’ political network, it is virtually
impossible to link the funds the LLC has donated
to VFA PAC to a specific individual or group of
people. The Koch network has long been known
for its innovative tactics to avoid disclosing
donors, even inspiring a book called Dark Money
by New Yorker reporter Jane Mayer.
The Freedom Partners Chamber of Commerce,
which is now known as the Seminar Network
Chamber of Commerce, is structured as a
501(c)(6) trade association, meaning it does
not have to publicly disclose its members.
According to CNN, it had more than 600
individual members who paid at least $100,000
each in annual dues last year.
Delaware business records show that Demeter
Analytics Services formed as a corporation in
2011 and was converted into an LLC in 2017.
Its early directors and members included a
number of current and former Koch Industries
executives as well as Marc Short, who spent
five years working as the president of Freedom
Partners Chamber of Commerce and now serves
as Vice President Mike Pence’s chief of staff.
After it became an LLC, Demeter Analytics
Services has had less stringent reporting
requirements about the people involved in its
operations.

Issue One

 AN OPAQUE LLC USED IN A CONSPIRACY TO
DEFRAUD DONORS
Victory Marketing LLC
FEC records show that an obscure Delawarebased company called Victory Marketing LLC
performed roughly $40,500 worth of phone
banking, direct mail, and compliance consulting
between October 2017 and March 2019 for a
little-known super PAC called Action Coalition
PAC.
Federal prosecutors, however, discovered that
both Victory Marketing LLC and Action Coalition
PAC were actually part of a scam PAC network
that bilked conservative donors to the tune of
tens of millions of dollars. Victory Marketing
LLC did not, in fact, perform any actual services.
Instead, it existed solely to transfer funds from
deceived donors to bank accounts controlled by
the fraudsters.
In March 2019, William Tierney, the Arizona man
behind this scam PAC network, was sentenced
to two years in prison for “conspiring to defraud
tens of thousands of victims of more than
$1 million in connection with political action
committees falsely purporting to support causes
including autism awareness, law enforcement
support, and the pro-life movement.”

LLC, which specializes in incorporation services,
as its registered agent. But that firm simply
lists another incorporation services firm,
Corporations USA LLC, as its registered agent.
And Corporations USA LLC lists itself as its own
registered agent — providing no clues as to who
is behind Victory Marketing LLC, just layer after
layer of opaque businesses.

Victory Marketing LLC did
not, in fact, perform any
actual services. Instead, it
existed solely to transfer
funds from deceived donors
to bank accounts controlled
by the fraudsters.

Campaign finance filings and Delaware business
records made scrutiny of Victory Marketing LLC
nearly impossible.
The address Victory Marketing LLC provided in
FEC records was simply a box at a UPS store in
Seaford, Delaware, a city of about 7,000 people
in the southern part of the state. And the only
two individuals listed on Victory Marketing LLC’s
certificate of formation were employees of a law
firm hired by the LLC to perform incorporation
services.
Victory Marketing LLC’s certificate of formation
also lists a company called A-1 Incorporators

Issue One

[ Mystery Money — 19 ]

 UNCOVERING MYSTERY MONEY

1

Examine the
company’s
online
presence

2

Examine
the LLC’s
business
records

Issue One’s tips for the best questions to ask when LLCs make
super PAC contributions
─  Does an online search of the LLC’s name yield any meaningful information or news stories?
─  Does the LLC have a website?
─  Does the LLC have a social media presence?
─  What results does a Twitter search of the company’s name yield?
─  What results does a Google x-ray search of .gov websites plus the company’s name yield?
How about a Google x-ray search of .xls files and .pdf files?

─  Is the LLC registered in the state of its address listed in FEC filings?
─  If not, does the company’s name yield any positive hits on OpenCorporates?
─  Is the company registered in Delaware?
─  What, if anything, do the business records say about the primary purpose of the LLC?
─  Whose names are listed on the articles of incorporation or any other business records?
─  Is the only name listed a lawyer or employee at a firm that specializes in incorporation
services?

─  Do the filings list the LLC’s actual members or owners?
─  Investigate the people whose names are listed
─  What results do Google searches yield about these people?
─  How about Google x-ray searches of .gov websites?
─  Use FEC.gov, OpenSecrets.org, and FollowTheMoney.org to determine if they have made
political contributions in their own name in the past.

─  When was the LLC donor incorporated? How much time elapsed between the date of its
incorporation and the date of its donation?

3

Examine
the LLC’s
address

─  Is the LLC’s address a P.O. Box? A space in an industrial office park? Someone’s home?
─  What results do online searches of the LLC’s address — including Google x-ray searches
of .gov websites — yield?

─  Are other companies associated with this address?
─  What do property records show about who owns the land associated with the address of
the LLC?

─  Use FEC.gov, OpenSecrets.org, and FollowTheMoney.org to learn if its address has ever

appeared in federal or state campaign finance data or if the name of the LLC has appeared
as an individual donor’s employer.

Questions? Contact Issue One Research Director Michael Beckel at mbeckel@issueone.org

[ Last Updated — July 2020 ]