Interior Secretary Ryan Zinke has directed millions of dollars in political contributions since 2014 to a network of Washington operatives that prominent conservatives have accused of profiting by misleading donors.

Beneficiaries of Zinke’s largesse include groups linked to Washington-area political operative Scott B. Mackenzie, organizer of a Virgin Islands GOP political action committee that hosted the secretary at a St. Croix fundraiser in March. Before that, when Zinke was a Republican congressman from Montana, his political operation steered significant portions of its spending to a handful of Washington, D.C.-area consulting firms that also have had ties to Mackenzie and his associates.


Zinke has continued this relationship even as other Republicans have recoiled from dealing with Mackenzie, whose critics say he operates "scam PACs" that raise small-dollar donations from conservative voters but then spend the bulk of the money on consultants and overhead. The critics include former Virginia Attorney General Ken Cuccinelli, who filed a suit accusing Mackenzie and other defendants of running a “national fundraising scam” after they gave his 2013 campaign for governor less than a half percent of the money they had raised in his name.

Similarly, Zinke’s own leadership PAC also relied heavily on small donors while spending heavily on consultants, in a departure from how most members of Congress operate those kinds of groups.

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The details about Zinke's fundraising and spending practices have not been previously reported, nor has his years-long relationship with Mackenzie’s Virgin Islands Republican Party, a group that some Republicans in the Caribbean island chain have accused of misrepresenting itself to donors. POLITICO’s analysis of Federal Election Commission filings, plus interviews with campaign finance lawyers and people familiar with the Virgin Islands group’s fundraising, offer a deeper picture of the political activism of the retired Navy SEAL who serves in President Donald Trump’s Cabinet.

None of the records indicate that Zinke violated the law or received any direct compensation from his association with Mackenzie, the Virgin Islands PAC or its consultants. But one campaign finance expert said the information shows that Zinke was not behaving like a typical politician.

“To say the least, this is highly unusual,” said Karl Sandstrom, a former Democratic FEC commissioner who now works at the law firm Perkins Coie.

An Interior Department spokeswoman declined to comment on the assistance Zinke has offered to the Virgin Islands group or his use of political consultants. Mackenzie declined to be interviewed, and officials from the Virgin Islands organization — also known as VIGOP — did not respond to requests for comment.

Zinke is separately facing investigations by Interior's internal watchdog and the independent Office of Special Counsel over his habit of mixing politics and official business.

Legal limits on Zinke’s partisan activities have tightened now that he’s Interior secretary, and he has cut ties with his PACs since being sworn in. Still, he has kept up appearances at fundraisers and other political events — averaging more than one per month — a pace that is unusual for a Cabinet member. Those include his appearance at the March fundraiser in the Virgin Islands, which occurred during a taxpayer-funded trip less than a month after he became secretary.

Complaints among Republicans about “scam PACS” have been on the rise for years, focusing on groups that target conservative voters as a source for donations. Those complaints have repeatedly focused on Mackenzie, the founder of a number of GOP-leaning PACs that have used slogans such as “Stop Hillary Clinton” to raise money from conservatives — then appeared to do little actual politicking.

Such groups make use of what past FEC leaders have described as a loophole in campaign finance law. The commission declined to take action against one of Mackenzie’s Virginia-based PACs, the Conservative StrikeForce, after former Rep. Allen West (R-Fla.) complained in 2012 that it had been “fraudulent” in raising money from his supporters while falsely implying it would aid his reelection campaign. While the PAC’s actions were "troubling," the commission’s attorneys wrote, they didn’t violate any laws or rules that the FEC has the power to enforce.

Cuccinelli made similar criticisms in his 2014 lawsuit, which accused Mackenzie, Conservative StrikeForce and other defendants of using the bulk of the money they had raised in his name to “enrich themselves.” The case was eventually settled, with Conservative StrikeForce agreeing to pay Cuccinelli's campaign $85,000 and turn over its donor lists.

Conservative commentator Erick Erickson warned campaigns as far back as 2010 that he might not endorse any Republican candidate who used one Mackenzie-linked consulting firm, then known as Base Connect and now called ForthRight Strategy. Montana Democrats accused Zinke of facilitating a "political Ponzi scheme" with his connections to Mackenzie-linked firms during his 2014 congressional campaign, though the charges apparently gained little traction.

More recently, Rep. Will Hurd (R-Texas) — who was angered last year when the Virgin Islands GOP used his photo without his permission on fundraising solicitations — said in a statement to POLITICO that the Virgin Islands group and ForthRight “are preying on seniors in a disgusting attempt to enrich themselves.”

Adav Noti, a former FEC associate general counsel who now works for the nonprofit watchdog Campaign Legal Center, said in an interview that he had dealt with the Virgin Islands group and Mackenzie as an FEC official, and that in his opinion, “They are a scam PAC.”

“Scott Mackenzie has a number of scam PACs,” Noti said. “He was probably the first, or one of the first, with the idea of bilking people out of money through PACs. People are being defrauded, and that needs to stop.”

The FEC is scheduled to decide Thursday whether to fine Mackenzie for less-serious discrepancies in campaign filings by two other PACs of which he’s the treasurer, Freedom’s Defense Fund and the Conservative Majority Fund.

None of the criticism has seemed to deter Zinke, who used part of a government-paid trip to the Virgin Islands in March to attend a VIGOP fundraiser, where — as POLITICO reported in early October — an invitation listed tickets costing as much as $5,000 a couple, and Zinke’s schedule indicated that high-dollar donors had a chance to take photos with him. It was at least the third VIGOP event Zinke had attended there since 2015.

VIGOP, which the FEC classifies as a "non-party" PAC, directed more than a third of its spending during the 2016 election cycle to a handful of Washington-area consulting firms, including ForthRight and at least three other companies that share its address on 15th Street Northwest, according to campaign filings and other documents. Those firms also received more than $3.2 million during the same period from Zinke’s congressional campaign, leadership PAC and a super PAC he founded before running for Congress, federal campaign records show.

Between the 2014 and 2016 elections, Base Connect had renamed itself ForthRight Strategy after a former executive pleaded guilty to child pornography charges. A number of the firm’s clients left, but Zinke's campaign and his newly formed leadership PAC not only stayed with the firm but also spent substantially more on it in the next election.

Zinke also publicly endorsed ForthRight's performance in his 2014 congressional race, offering a testimonial that was displayed on the firm's website until this month, when the watchdog group Campaign for Accountability filed an ethics complaint.

“Your results and personal commitment to Team Zinke were bar none!” the company quoted Zinke as saying on its website. “I greatly value the professional as well as the personal relationship we have developed over many years.”

This praise came even though Zinke’s campaign appears to have received less than it spent from its relationship with the firm.

ForthRight says it raised $1.9 million for Zinke’s 2014 race by sending out 1.6 million pieces of mail, attracting nearly 44,000 new donors whose average contribution was $44. About $550,000 of that haul went to Zinke’s campaign for "voter mail, radio ads, TV ads, get-out-the-vote activities and lawn signs," according to the firm's website. But that was less than the $608,000 that Zinke’s campaign spent on postage and direct mail from Century Data Mailing Service, a firm located at the same 15th Street address as ForthRight, according to FEC records.

In the run-up to last year's election, Zinke's campaign and his leadership PAC, known as SEAL PAC, spent about $3 million combined on ForthRight Strategy, Direct Support Services and Legacy Lists — all of which operate out of the same office and list ForthRight CEO Kimberly Bellissimo among their executives. (Bellissimo did not respond to POLITICO’s requests for comment.)

Special Operations for America, a super PAC that Zinke founded in 2012 before running for office, also paid firms at that address a total of about $1.8 million during the 2014 and 2016 campaign cycles.

Mackenzie is not listed on ForthRight’s website or business filings but was long associated with the firm under its previous names, Base Connect and BMW Direct, both of which listed him as a staff member as far back as 2007.

Besides sharing an affinity for the same consultants as Mackenzie’s VIGOP, Zinke’s SEAL PAC has also followed a similar fundraising model: It raised two-thirds of its money from small donors in 2016, then steered only 4 percent of its spending to other campaigns, with almost all the rest going to operating expenses and overhead.

Typically, members of Congress use their leadership PACs to cover expenses that cannot be funded from their campaign accounts and to contribute to fellow politicians, using donations of up to $5,000 from lobbyists and other PACs. But SEAL PAC relied on donations of less than $200 for about two-thirds of the $3 million it collected during the 2016 cycle, according to a review of the donations. The group then spent more than $2.6 million on overhead and gave just $118,000 to other congressional campaign committees.

Relying heavily on small-dollar donations is one hallmark of the “scam PAC” play, said Brett Kappel, a partner at the law firm Akerman LLP who specializes in campaign finance, lobbying and government ethics.

“Unfortunately, they generally target the most vulnerable segment of the population with the least disposable income — retired people living on fixed incomes,” said Kappel, who declined to discuss specific cases. “Frequently, these are elderly conservative voters who are upset with the direction of the country.”

Lorraine Hutchinson, of Butler, Pennsylvania, told POLITICO that these elderly voters included her mother, who she noticed was repeatedly contributing to SEAL PAC and other organizations, though she didn’t have the disposable income to spare. Hutchinson said Zinke’s PAC was one of the slowest to cease soliciting money when she asked them to stop. At one point, Hutchinson resorted to posting a plea on SEAL PAC’s Facebook page.

“It took a great deal of time and effort but I managed to get most of them to stop. The Seal PAC was one of the most persistent,” Hutchinson told POLITICO in a Facebook message last week. “I am convinced that these groups knowingly take advantage of the vulnerable elderly and this is a widespread problem without any easy solutions.”

Erickson told POLITICO in 2015 that groups that raise political donations without doing much actual politicking are “completely a drain” on the conservative movement, saying they threatened to sap the donors’ enthusiasm while achieving no concrete results.

But Bellissimo, the ForthRight CEO, defended direct-mail fundraising in a 2014 post for The Daily Caller.

Donors who send checks in response to mail solicitations "are some of the most patriotic, conservative, generous, and sophisticated people on the planet. ... They are also 'movement' people," Bellissimo wrote. "They are willing to sacrifice their dollars on a principled conservative even when they know that candidate is an underdog.”

Mackenzie has similarly defended his high operating costs, telling the FEC in response to West’s complaint that “fundraising is expensive and getting more so every year.”

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Bellissimo’s firm has played a crucial role in partnering with Mackenzie’s Virgin Islands PAC: Several months before Mackenzie filed the VIGOP's initial paperwork with the FEC in December 2013, Virgin Islands Republican Party Chairman John Canegata signed a contract with Base Connect Vice President Timothy Webster making the firm the exclusive fundraiser for the PAC, according to a copy of the confidential document reviewed by POLITICO.

Some Republicans in the Virgin Islands objected to the use of their name in fundraising mailers urging voters to “Stop Hillary Clinton,” and Canegata's involvement with Mackenzie has exacerbated divisions within the local party's governing body.

The anti-Clinton pieces, "at best, solicit donations under false pretenses," four members of the Virgin Islands Republican Territorial Committee wrote in a February 2015 internal report, a copy of which was obtained by POLITICO. The members reported that "not a single penny of the funds received through these solicitations have been used for any purpose identifiable to any effort to oppose the election of Hillary Clinton as president."

Bellissimo introduced Zinke to VIGOP in 2015, his first year in Congress, a source familiar with VIGOP’s operations told POLITICO. Zinke, his wife, Lola, and Bellissimo flew to St. Thomas to attend a VIGOP event in November of that year. Photos of the VIGOP members posted on Facebook show Zinke and Bellissimo mingling at the Caribbean venue alongside Canegata and Saul Anuzis, a Michigan-based GOP operative who helped raise money for VIGOP. Neither Anuzis nor Canegata responded to requests for comment.

In February 2016, Bellissimo posted a photo of Zinke speaking at the Hay-Adams hotel across from the White House and bragged that she had "the privilege of playing staffer for Congressman Zinke this afternoon." When a friend commented on the Facebook post, saying the then-House freshman should run for president, she replied: "Maybe someday.... Will you help me campaign for him?"

Zinke returned for another VIGOP event at the Ritz-Carlton in St. Thomas less than two weeks after the 2016 election, according to social media posts. Then came his appearance at the VIGOP fundraiser this past March — this time as a member of Trump’s Cabinet.