On July 13, The Trace published an investigation into the National Rifle Association’s top election contractor, a mysterious firm called Starboard Strategic Inc. The article raised numerous questions about possible campaign finance violations committed by the gun group, and spurred action by a prominent election-spending watchdog: Three days after its publication, the Campaign Legal Center filed a complaint with the Federal Election Commission. State political reporters, in turn, have directed attention to U.S. senators who have benefitted from Starboard’s work.

Yet despite continued requests, the company’s partners, one of whom has challenged the story’s findings, have declined to answer journalists’ inquiries and provide documents that would head off concerns about illegal election activities.

Related Story Bang for the Buck The Mystery Firm That Has Become the NRA’s Top Election Consultant Since 2014, the gun rights group has paid more than $60 million to a little known contractor for ads in must-win political races. Did it break campaign finance laws in the process?

The article, published in partnership with Politico Magazine, examines whether Starboard is a fully operational company or a shell firm that exists principally on paper. After dozens of interviews and months of sifting through public documents, I could find no meaningful distinction between Starboard and OnMessage Inc., a successful conservative political consulting firm based in the Washington, D.C., area. Starboard and OnMessage share the same partners and office addresses, and internal emails indicate that executives shift between roles for both entities. Starboard’s website domain was registered by an OnMessage partner, though it appears that efforts have been made to obscure that connection. After my story came out, someone privatized the registration details.

Starboard was established in 2013, and it has virtually no other clients besides the NRA. In 2014, the gun group paid the firm millions of dollars for ads in support of three Republican Senate candidates: Thom Tillis, in North Carolina; Cory Gardner, in Colorado; and Tom Cotton, in Arkansas. At the same time, those candidates paid millions to OnMessage for its services. Tillis, Gardner, and Cotton all defeated Democratic incumbents. Two years later, a similar arrangement occurred in a Wisconsin Senate race, in which Republican Ron Johnson narrowly defeated Democrat Russ Feingold.

Here is a graphic we included in my original story, which shows the timing of the payments from NRA to Starboard, and from the candidates to OnMessage.

Federal law permits outside groups, like the NRA, and official campaigns to use common vendors. But the law stipulates that the firm working for either client must prevent employees from sharing election-related information. Typically, a firm averts coordination by enforcing a strict firewall policy that is read and signed by its employees. The document is an agreement to comply with the law and an acknowledgement that there are penalties for failing to do so.

In the months leading up to the publication of The Trace’s story, I repeatedly asked OnMessage’s partners for copies of the firm’s firewall policy and details about how it is enforced. I received no response.

Stay Informed Subscribe to receive The Trace’s newsletters on important gun news and analysis. Email address The Canon Sent every Saturday. Our guide to the week's most revealing, must-read reporting on gun issues.

The Daily Bulletin Sent weekday mornings. Get up to speed with The Trace’s latest articles and other important news of the day. Leave this field empty if you're human:

It was only after state political reporters started asking questions in response to The Trace’s article that the companies broke their silence. Speaking to outlets in Colorado and North Carolina, Brad Todd, a partner at Starboard and OnMessage, was adamant that both firms have firewall policies in place. When the North Carolina outlet asked for proof, however, Todd declined to provide it.

This week, I again contacted Todd and his fellow partners for comment. Again, they did not respond.

In its complaint, the Campaign Legal Center says there is “reason to believe” that the NRA violated campaign finance laws through its payments to Starboard, and calls on the FEC to conduct an “immediate investigation.”

Once the complaint is formally recognized, the FEC will give the NRA, OnMessage, and Starboard a chance to respond to its allegations. If the parties ignore the FEC’s inquiries, they could expose themselves to penalties.