A freshman Democratic congresswoman and her husband shuffled money between their bank accounts and businesses in steering huge sums to her successful 2018 campaign in what congressional ethics officials allege might constitute breaches of federal law.

Rep. Lori Trahan (D-MA) is under scrutiny by the Office of Congressional Ethics over alleged efforts to circumvent federal campaign contribution limits. A series of transactions detailed in an OCE report released on Tuesday show how Trahan and her husband transferred money from bank accounts in his name to jointly held accounts, then from those accounts to Trahan’s campaign.

The transactions allowed Trahan to record hundreds of thousands of dollars in campaign income as loans from the candidate, which are not subject to contribution limits. But the OCE suggests that the money actually came from her husband, who was barred by law from donating more than $5,400 to her campaign during the 2018 cycle.

“In FEC reports, Rep. Trahan reported the loans to her campaign committee as personal loans originating from her own personal funds to comport with federal law,” the OCE found. “However, as discussed above, Rep. Trahan’s spouse, David Trahan, was the source of the $300,000 contributed to her campaign committee throughout 2018.”

“There is substantial reason to believe,” the OCE concluded, “that Rep. Trahan’s campaign committee accepted personal loans and contributions that exceeded campaign contribution limits.”

The OCE noted that neither Trahan nor her husband cooperated with its investigation. But in a lengthy letter accompanying its findings, Trahan’s lawyers denied any wrongdoing and accused the investigators overstepping their bounds—and even violating her legal privacy rights.

The OCE report focuses on a series of transactions during the spring and summer of 2018. On two occasions, Trahan wrote $50,000 checks to her campaign from a joint bank account maintained by her and her husband. The account had nowhere near enough money on either occasion to cover the deposits.

Within days, though, Trahan’s husband deposited funds from his own personal or business accounts to cover both of those transactions. And on both occasions, Trahan’s campaign waited until that money arrived in the joint account before depositing the checks, both of which were reported to the FEC as candidate loans.

Then Trahan upped the dollar amounts. In August 2018, her husband deposited $200,000 in their joint account. The next day, Trahan used that account to lend her campaign exactly $200,000.

The OCE report also details a $71,000 candidate loan to Trahan’s campaign that originated with a joint line of credit taken out by Trahan and her husband in September. Though they were jointly liable for the line of credit from which those funds were drawn, the report notes that it was Trahan’s husband who repaid the loan from his personal bank account.

Trahan’s attorneys with the firm Perkins Coie wrote off all of these transactions as a misunderstanding of both federal law and the private financial relationship between her and her husband. “To treat funds deposited by Representative Trahan’s husband into the joint account as political contributions has no basis in FEC rules or the reality of the Trahans’ shared life,” the attorneys wrote.

In fact, Trahan and her husband maintain joint control of all of their assets, regardless of whose name is on which bank account, the attorneys wrote. “The funds were, in fact, her “personal funds” before they were transferred to her joint account,” the letter states.

Trahan and her husband maintain joint control of all of their assets, regardless of whose name is on which bank account, the attorneys wrote. In fact, they even signed a prenuptial agreement stipulating that “[e]ach party shall have equal rights in regard to the management of and disposition of all marital property.” Accordingly, Trahan’s attorneys write, “The funds were, in fact, her personal funds before they were transferred to her joint account.”

The OCE did not determine that Trahan violated federal law, but it voted overwhelmingly—five to zero with one abstention—to investigate the matter further.