The John Bolton Super PAC illegally coordinated with Cambridge Analytica in violation of federal campaign finance laws, according to the findings of an independent, third-party investigation.

In response, non-partisan public interest watchdog, the Campaign Legal Center, (CLC), filed an ethics complaint with the Federal Election Commission late Thursday afternoon alleging multiple violations of the Federal Election Campaign Act (FECA).

Law&Crime was able to obtain a copy of the complaint immediately after it was filed this afternoon. Spread across 17 pages, CLC’s complaint accuses the John Bolton Super PAC of making “excessive and unreported contributions in violation of FECA’s reporting requirements and contribution limits, and in violation of its status as an independent expenditure-only Super PAC.”

The complaint centers around alleged coordination during the 2014 election cycle when Bolton’s Super PAC contracted with Cambridge Analytica while the shadowy data firm was “simultaneously providing services to the North Carolina Republican Party and the Thom Tillis Committee.” The complaint notes:

Based on a Cambridge Analytica staffer’s online portfolio and other published reports, there is reason to believe that the John Bolton Super PAC used strategic information that Cambridge Analytica derived from its work for the party or campaign to develop advertisements expressly advocating for Tillis’ election.

Thom Tillis (R-NC) ran the most expensive Senate campaign in the country in 2014–ultimately defeating Democratic incumbent and now-former senator Kay Hagan (D-NC). The Thom Tillis Committee was Tillis’ primary campaign organization.

According to CLC’s complaint, the data sharing between those three Cambridge Analytica clients–(1) the John Bolton Super PAC; (2) the North Carolina Republican Party; and (3) Tillis’ campaign organization–rose to the level of unlawful coordination in violation of federal law. The complaint notes, on page 10:

John Bolton Super PAC has made illegal, excessive and unreported in-kind contributions to the North Carolina Republican Party and/or the Thom Tillis Committee by financing coordinated communications through the use of a common vendor, Cambridge Analytica.

The complaint also notes that Bolton’s Super PAC lost its legal status as a Super PAC after making those alleged in-kind contributions. Page 13 of the complaint reads, in relevant part:

The in-kind contributions…violated John Bolton Super PAC’s sworn statements to the Commission that it would raise funds in unlimited amounts under the condition that it would only make independent expenditures and would not make contributions to a candidate committee. As such, John Bolton Super PAC ceased to be an independent expenditure-only political committee…

Cabell Hobbs is the FEC-designated treasurer for the John Bolton Super PAC.

Hobbs previously worked in the George W. Bush White House and also served various stints on both Bush/Cheney campaigns in 2000 and 2004–including two years as the assistant treasurer for the Bush/Cheney Compliance Committee. Hobbs currently manages the Compliance Consulting Company of Virginia, which he co-founded in 2006.

In addition to his work for the John Bolton Super PAC, Hobbs also served as the treasurer for the Opportunity Alliance PAC in 2014. An article from USA Today quoted Hobbs then as saying, “I just do the accounting and the FEC (Federal Election Commission) reports.”



Law&Crime reached out to Hobbs for comment, but no response was forthcoming at the time of publication.

[image via Ethan Miller/Getty Images]

Follow Colin Kalmbacher on Twitter: @colinkalmbacher

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