CLC Complaint Alleges John Bolton Super PAC’s Connection to Cambridge Analytica Resulted in Campaign Finance Violations


WASHINGTON – Campaign Legal Center (CLC) filed a complaint with the Federal Election Commission (FEC) alleging that the John Bolton Super PAC’s work with Cambridge Analytica resulted in unlawful coordinated communications during the 2014 election cycle. 

In the 2014 elections, Cambridge Analytica provided services to the John Bolton Super PAC, the North Carolina Republican Party, and Thom Tillis’ campaign. Although Cambridge Analytica is supposed to separate its work for campaigns from its work for super PACs, evidence indicates that this didn’t happen—and that Cambridge Analytica acted as a conduit to funnel strategic information to the John Bolton Super PAC – which then spent $1.4 million on ads supporting Tillis’ U.S. Senate candidacy.

As a result, the John Bolton Super PAC made excessive and unreported contributions, in violation of the reporting requirements and contribution limits required by law, and in violation of its status as an independent expenditure-only super PAC.

“It is important that the FEC investigate this violation and enforce the law so that the voices of everyday voters are not drowned out by billionaires,” said Brendan Fischer, director, federal and FEC reform program at CLC. “This apparent violation fits into a pattern where the use of Cambridge Analytica as a vendor seems to be a condition of billionaire megadonor Robert Mercer’s support of a candidate. Cambridge Analytica has been used in both the U.S. and U.K. to unlawfully coordinate political entities in order to evade campaign finance limits.”

Cambridge Analytica’s primary owner, Mercer, was also the John Bolton Super PAC’s single largest funder. Details in the complaint show how the John Bolton super PAC unlawfully used strategic information that Cambridge Analytica derived from its work for the party or campaign to develop advertisements expressly advocating for Tillis’ election. Among other things, a Cambridge Analytica employee boasted on his online portfolio about the company’s role in “helping Thom Tillis' successful senatorial campaign create highly targeted advertising,” and as a sample of that work, posted a John Bolton Super PAC video ad expressly advocating for Tillis’ election. After a reporter asked questions about this, the employee altered the page.