CLC Complaint Alleges Shell Company Funneled Secret Money to Trump Super PAC

Piles of $100 bills lying on top of each other

Campaign Legal Center (CLC) has filed a complaint with the Federal Election Commission (FEC) alleging that “ML Organization, LLC,” William Pulte and other unidentified individuals violated federal campaign finance laws in connection with a $500,000 contribution made to a pro-Trump super PAC.

The complaint alleges that ML Organization was not the true source of a $500,000 contribution made in its name to Make America Great Again, Again! Inc. — which brands itself as the "ONLY Trump approved super PAC" and has plans to support Trump-endorsed candidates in the 2022 midterm elections.

It also alleges that Pulte (or another unknown person) was the true contributor.

CLC uncovered that in 2016, Pulte purchased the residential property at the address for ML Organization disclosed on FEC reports, and Pulte has personally used that address in multiple filings with the state of Florida related to companies that he manages or directs.

Pulte has made multiple contributions since 2016 but always disclosed a different address — the office location for one of his businesses — in connection with those contributions. As such, there is no connection on FEC disclosure reports between Pulte and the ML Organization address.

There is no record of ML Organization having any business activity or generating any income since it was registered as a Delaware domestic limited liability company (LLC) in April 2018. That lack of activity or income indicates that ML Organization lacked the means to contribute $500,000 without receiving funds for that purpose.

The complaint concludes, based on the available facts, that ML Organization is most likely owned and operated by Pulte or someone else in his household and was used as a conduit to funnel $500,000 to a super PAC, such that both ML Organization and Pulte (and/or the other unidentified contributors) violated the Federal Election Campaign Act’s straw donor ban.

Straw donor contributions like those alleged here are serious violations of federal campaign finance law that have led to criminal indictments and convictions in recent years. In some cases, straw donor schemes have even been used to conceal corruption or foreign influence in American elections. 

Shell companies like ML Organization, LLC are often used to funnel secret money to super PACs, concealing the true contributor’s identity using an illegal tactic that erodes transparency. The FEC should act on CLC’s complaint to protect voters’ right to know when wealthy special interests are spending money to influence elections and rig the political system in their favor.  

Brendan is a Senior Communications Manager for Campaign Finance and Ethics issues at CLC.
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