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Former Donald Trump campaign CEO and chief strategist Steve Bannon used a private jet apparently owned by a wealthy Chinese businessman to fly to events to promote Republican congressional candidates in 2018.

The previously unreported flights could run afoul of a campaign finance law that bars foreign money from U.S. elections, according to campaign finance experts, though it depends on several factors that are not known. One of the unknowns is whether Bannon paid Guo Wengui — the Chinese businessman, who is a vocal critic of the Chinese regime, and with whom he has other reported financial ties — for the use of the jet.

Bannon flew on the jet, a Bombardier Global Express that can seat up to 13 people, to 2018 events supporting Republican candidates in New Mexico and Arizona. He also flew on it to Mexico City and New York, and possibly to other cities. The flights were confirmed by footage taken for “The Brink,” a 2019 documentary about Bannon, and by videos of Guo on the plane, interviews and FAA flight records obtained through the Freedom of Information Act.

“The foreign-national prohibition is the broadest prohibition in the Federal Election Campaign Act,” said Brett Kappel, a government affairs partner at the Akerman law firm, speaking generally. “It prohibits foreign nationals from making any contribution or donation in connection with any election in the United States. It also precludes foreign nationals from making in-kind contributions, such as paying for campaign-related travel.”

The same law also prohibits receiving such a donation. Bannon’s one-way trip from New York to New Mexico alone would be worth around $35,000, according to public jet charter rates.

Lawyers for Bannon and Guo (who is also known as Miles Kwok) did not dispute that Bannon used the Chinese businessman’s plane for trips. But Cleta Mitchell, an attorney representing Bannon’s nonprofit, Citizens of the American Republic, wrote in an email, “The meetings and rallies hosted by COAR in 2018 were to promote the film, Trump\@War, and to encourage Trump supporters to vote in 2018. These were not candidate or campaign rallies.” Guo’s attorney said in a statement that “Mr. Guo has not participated in or supported, directly or indirectly, any political activity or party in the United States or elsewhere. To the contrary, Mr. Guo has consistently emphasized that he has no desire to participate in politics anywhere.”

Nothing about the trips appears to have been disclosed to the Federal Election Commission, either by Bannon or the congressional candidates he traveled to support.

Guo told Vice in 2017 that he owns two private jets. Han Lianchao, a Guo associate, told ProPublica, “I know he allowed Steve to use his private jet from time to time.” Han said he did not know the specifics of their arrangement. A Bannon aide also told Alison Klayman, the filmmaker who made “The Brink” and flew on the jet, that it belonged to Guo, Klayman told ProPublica.

In one scene in the film, Bannon is shown on the plane praising Guo’s analysis of Chinese politics while on a flight from New York to Dallas in October 2018.

Official records don’t identify the ultimate owner of the jet, which bears the tail number T7-GQM. The jet is registered in the tiny Republic of San Marino to Whitecroft Shore Limited. That, in turn, is incorporated in the British Virgin Islands, an offshore dominion known for secrecy. There are multiple videos online of Guo that appear to be taken on the plane that match independent photos of the interior and exterior of the jet with the same tail number. Other articles link the jet to Guo.

Bannon left the Trump White House in the summer of 2017 and has spent the past couple of years jetting around the country and the globe to promote right-wing causes, candidates and his own brand. It is a continuing mystery who is supporting his efforts. His use of the Guo plane helps fill out the picture.

The unlikely relationship between Bannon and Guo is one of the defining features of Bannon’s post-White House career. It continues through the present, with Bannon and Guo frequently appearing together on Bannon’s podcast and Guo’s news site commenting on Trump, China and the coronavirus, among other topics.

Guo, who has described himself as a successful real estate developer and investor, left China for the U.S. in 2015 and is reportedly seeking asylum. He is a critic of Chinese leaders, churning out a stream of online videos commenting on the news of the day, from the coronavirus to his “crusade against communism.” The Chinese government has, in turn, sought Guo’s arrest on corruption allegations, which he has denied. Guo frequently appears in videos with Bannon, who has predicted a war between the U.S. and China and says he is currently producing a “takedown” film about Chinese President Xi Jinping.

The New York Times recently reported that Bannon’s relationship with Guo began with a $150,000 loan to Bannon shortly after his 2017 departure from the Trump administration. Axios reported that a company linked to Guo had contracted with Bannon for at least $1 million for “strategic consulting services,” beginning in August 2018. (A Guo spokesman told Axios that the contract was for media investment and other consulting, and that Guo “had no involvement in [Bannon] being retained.”)

In fall 2018, Bannon and his dark money organization, Citizens of the American Republic, were pushing to keep Republican control of Congress during the midterm elections. A Bannon aide told ABC at the time that the group had an election war room focused on “explaining that a vote for any House Republican is a vote to stop the Democrats.”

Bannon made the trips to promote GOP candidates on the Bombardier jet in October 2018, under the aegis of Citizens of the American Republic. (The organization raised a total of $4.5 million in 2018 from a handful of donors, according to its filing with the IRS. But as a “social welfare” nonprofit organized under section 501(c)4 of the Internal Revenue Code, it is not required to reveal its donors.)

One of the trips was to Arizona in support of congressional candidate Wendy Rogers. Bannon told the Arizona Daily Star at the time: “If she can beat [Rep. Tom] O’Halleran, we’ll hold the House. We’ll hold the House by one or two seats. And that’s why it’s so important, and that’s why I wanted to come down here.”

Rogers, who ultimately lost the race, didn’t respond to requests for comment.

The trip to Roswell, New Mexico, featured U.S. Senate candidate Mick Rich and a screening of Bannon’s film “Trump\@War.” According to video from the Roswell event viewed by ProPublica, Bannon and Rich strategized about the campaign before Bannon’s public remarks. “Tell me about this race,” Bannon said in the video. “How are we going to win this thing? I’ll come back here as many times as — ” Rich interjected: “Getting you out here is number one.” Rich also asked if Bannon could get President Trump to tweet about the race, and Bannon said he would try.

During the public event, Rich introduced Bannon, who in turn praised the Senate candidate as a “real populist.” Bannon urged the audience members to vote for pro-Trump candidates.

Rich lost the 2018 race and is running again this year. A spokesman told ProPublica in a statement that “Mick and his campaign had no knowledge of Bannon’s transportation to or from the event. Mick and his campaign had no coordination of any kind with Steve Bannon or any Steve Bannon group before, during, or after this event.”

Three years into President Donald Trump’s term, the roster of his cabinet members and top advisers continues to churn at an unprecedented rate. Craig Holman, a campaign finance expert at Public Citizen, said that the New Mexico event “could well implicate Chinese billionaire Guo Wengui for violating the law that prohibits foreign nationals from paying for campaign activities,” if the Federal Election Commission deemed the event to be an “independent expenditure” by Bannon’s group, or a Rich campaign event.

The FEC doesn’t currently have a quorum and it, along with the IRS, have historically done little to scrutinize political nonprofits like Bannon’s.

Apart from the use of the jet, there’s also the question of whether the event would run afoul of the rules barring an outside group like Bannon’s from coordinating with the candidate, Rich.

Adav Noti of the Campaign Legal Center said political nonprofits are operating in a grey area because of the FEC’s failure to outline rules for what sort of contact they are permitted to have with a candidate. “To any rational person that looks at this, of course it’s a campaign event. But it might be allowed, which is the scandal.”

In a March 2018 filing in an unrelated lawsuit, an attorney for Guo noted the prohibition on Guo making expenditures in connection with U.S. elections. He wrote that “Because Plaintiff Guo is a foreign national, he is prohibited, by 52 U.S.C. 30121, from making any contributions, monetary donations or expenditures in connection with any federal, state or local election in the United States.”