Elections are big business. Federal candidates and political parties routinely raise and spend millions of dollars to seek public office. Outside groups like super PACs unleash torrents of additional money to back their favored candidates. It comes as no surprise, therefore, that political ad spending in the 2026 midterms is projected to top $10 billion.
Voters have a right to know not only where this money comes from, but also how it is being spent. Such transparency not only ensures an informed electorate: it helps deter the corruption that can flourish when these millions of dollars are spent in secret, without public accountability.
Federal campaign finance laws require candidates and committees to report how they spend their money — including disclosing the actual recipients and purposes of their disbursements.
Unfortunately, for a variety of reasons, some groups unlawfully skirt these reporting rules. Campaign Legal Center recently filed three complaints with the Federal Election Commission (FEC) alleging that committees violated their reporting obligations by funneling their campaign spending through shell companies, concealing the true recipients of millions of dollars in spending to influence upcoming federal elections.
Each of these committees reported making the vast majority of their disbursements — upwards of 80% or 90% of their reported spending — to opaque, often newly-formed entities (usually an LLC or corporation) about which virtually nothing is publicly known. It’s inconceivable that these new, non-publicized entities are actually providing the wide range of reported goods and campaign services attributed to them; instead, they appear to be subcontracting the provision of those goods and services to more established vendors whose identity is being concealed from voters and the public.
This setup is illegal. Federal law prohibits using a shell company to avoid disclosing the identity of subvendors that are ultimately being paid to provide particular goods and services to a political committee. In such cases, the committees must disclose their subvendors and what goods or services they were paid to provide.
Leading the Future: The AI industry’s super PACs
Campaign Legal Center filed a complaint against Think Big and American Mission, a pair of super PACs affiliated with the “Leading the Future” network of political organizations, which opposes strict regulations on the artificial intelligence (AI) industry.
These super PACs were funded by a handful of ultrawealthy tech investors — including the founders of venture capital firm Andreessen Horowitz and executives at OpenAI and Palantir — and have spent millions of dollars on the 2026 midterm elections while unlawfully obscuring the true recipients of that spending.
Think Big reported paying 96.8% of its disbursements, over $6.4 million, to a newly formed entity called “Lantern Production Consultants LLC.” American Mission similarly reported paying 94.4% of its disbursements, over $4.1 million, to a different newly formed entity, “Summit Ridge Media Group LLC.”
Both LLCs appear to exist only on paper and were formed on the exact same day, just a few weeks before the super PACs began spending millions of dollars on political ads. Each super PAC reported receiving a wide array of goods and services from its corresponding LLC, which were almost certainly being provided by other, more established vendors.
It’s possible that these super PACs concealed who was providing their campaign services to help those vendors avoid the likely public scrutiny of working with political groups opposing efforts to regulate AI — a controversial position.
Indeed, Leading the Future has already attracted considerable media scrutiny for attacking Alex Bores, a 2026 congressional candidate who has vocally supported robust regulation of the AI industry. Political vendors may also have been squeamish about openly working with a bipartisan effort, since they face pressure from politicians to serve only one side of the aisle.
Lead Left: The pop-up primary influence operation
CLC likewise filed a complaint against Lead Left PAC, a “pop-up” super PAC that has reported spending over $2.4 million on political ads targeting Democratic candidates in primaries across the country.
Lead Left has strategically gamed reporting deadlines to avoid disclosing its funding sources — at least until after the primary elections it is spending money to influence. While this strategy is not currently prohibited, it plainly undermines transparency and the spirit of federal disclosure requirements. But Lead Left’s scheme goes further and appears to include the unlawful concealment of the true recipients of its election spending.
Lead Left reported making disbursements to just two entities, Piruzi LLC and OTG Media LLC, both of which were formed within weeks of the super PAC’s formation. Neither LLC appears to exist outside of its corporate filing papers, and Piruzi was actually incorporated by Lead Left’s treasurer.
Media reports suggest that Lead Left may, in fact, be funded by Republican-affiliated groups attempting to boost Democratic primary candidates they perceive as easier for Republican candidates to defeat in the 2026 general elections.
Because most established political vendors tend to work consistently with one major party or the other, if Lead Left reported its spending as the law requires, that might tip its hand — revealing the operation’s covert partisan affiliation and undermining the effectiveness of its ads. This may explain why the group has not only exploited loopholes in reporting rules to avoid disclosing its donors, but it also has unlawfully failed to report its vendors by funneling payments through shell companies.
Texas Strategy Group: Brandon Herrera’s one-stop shell vendor
Campaign Legal Center’s most recent complaint alleges that Texas congressional candidate Brandon Herrera has illegally failed to report the true recipients of several million dollars in campaign spending across two election cycles.
Herrera’s campaign, as well as his leadership PAC and an authorized joint fundraising committee, have reported spending the vast majority of their funds on payments to “Texas Strategy Group” (TSG), an entity that remarkably does not even appear to exist in corporate registration records anywhere in the country.
Despite its dubious existence, TSG has reportedly received millions of dollars from this trio of Herrera-affiliated committees, including over 99% of Herrera’s 2026 campaign committee’s disbursements, for which TSG has reportedly provided an incredible array of goods and services. Through this absurd reporting scheme, Herrera’s committees appear to be unlawfully concealing who is actually receiving these funds.
The FEC must enforce transparency laws
Federal reporting requirements help ensure transparency and accountability in our elections. These committees are not the first to undermine those important goals by using opaque shell companies — along with other, similar tactics — to avoid reporting the actual recipients or purposes of their spending.
It is vital that the FEC fulfills its mission and purpose by enforcing the law when groups deliberately deprive voters of essential campaign spending information.