(CNN) The call sounds like it is coming from President Donald Trump's 2020 re-election campaign.

It even uses a recording of the President's voice: "I'm Donald Trump. Tonight I am asking you to defend our very dangerous southern border, out of love and devotion to our country." A deep-voiced narrator then comes on asking the listener to "be one of the hundreds thousands of patriots that helped President Trump finally build a the wall by making a one-time urgently needed donation to the campaign."

Calls like this one, said to number more than 200,000, have helped raise more than $100,000 in January alone, but that money isn't going to the Trump campaign, whose spokesperson told CNN they were not affiliated with the calls. Instead, the calls are coming from a political action committee that isn't affiliated with Trump's re-election effort and hasn't spent any money so far in this or last election cycle, according to records from the Federal Election Commission.

A CNN KFile investigation into the group behind the calls, Support American Leaders PAC, reveals it is run by 32-year-old Matthew Tunstall, who has a history of managing shadowy groups that target people with politically charged calls in order to raise money while doing very little -- if anything at all -- to put that money toward a political purpose. Tunstall made more than $300,000 through these groups in the 2016 presidential cycle, FEC records show.

The operation effectively amounts to an income cycle of wash, rinse, repeat: paying for ads to raise money to pay for more ads to raise more money and so on, with Tunstall taking home whatever money doesn't get used to pay for more ads. The enterprise may also be breaking spending rules policed by three different federal agencies on impersonation and ad disclosure.

Determining who was behind the calls was difficult. The recorded calls come from non-working numbers, do not identify the group responsible for them or provide a callback number. And when KFile reached multiple call center operators working for the group, they each provided the name of a PAC that does not exist.

Those practices appear to be in violation of Federal Trade Commission, Federal Election Commission and Federal Communications Commission rules on impersonation and requiring ads disclose the name of the organization making the calls.

In response to written questions from CNN, Tunstall claimed the calls followed required rules and said any calls beginning with "I'm Donald Trump" were the results of technical errors and that such calls were ceased following CNN's inquiry.

"This was a technical error if you heard this, there were many different variants that have been recently tested for different political ads regarding support for President Trump," Tunstall wrote CNN in an email. "I've been instructed by multiple legal sources that using voice clips from politicians is acceptable and not considered 'impersonating' because politicians are public officials and do not have rights to their likeness like normal private citizens and celebrities do."

History of playing both sides

Tunstall has a history of managing PACs that targeted conservative and liberal ends of the political spectrum. During the 2016 presidential election campaign, BuzzFeed reported that Tunstall was behind both Progressive Priorities PAC , a group that claimed to support Hillary Clinton & Bernie Sanders and the Democrats' agenda, and Liberty Action Group , which claimed to support Trump.

Nearly all of the money donated to both groups went to paying for radio ad and calls that solicited more donations, or to Tunstall and unspecified media consultants. According to FEC records, the groups did not donate to any actual candidates.

CNN's KFile reported in 2017 that Liberty Action Group raised nearly $3 million through radio ads and robocalls during the 2016 election by asking for contributions to help elect Trump, with Tunstall himself being paid more than $300,000.

Liberty Action Group used former presidential candidate Ben Carson's name without his consent on fundraising appeals in 2016, asking voters to sign a pledge they claimed was signed by Carson to support Trump.

In 2016 , the group was sued by a San Francisco man who said they illegally placed robocalls to his cell phone causing him to incur unwanted charges. Court records show the case was settled.

KFile also reported that in early 2017, several people received phone calls from Progressive Priorities PAC that played a recording of former President Barack Obama followed by a request to donate to "help Obama impeach Trump." A spokesperson for the former president told CNN's KFile at the time those calls were reported to law enforcement.

Unchanged practices

Despite past reporting, Tunstall doesn't seem to have changed his ways, but he claims his ads never intended to impersonate anyone and claims this time around he plans to spent the money to support candidates like President Trump.

"Regarding impersonation, Support American Leaders PAC has never willfully intended to do anything other than comply with the FEC regulations and support candidates like President Trump. Support American Leaders PAC is not the Trump campaign or affiliated with the Trump campaign," he added.

But recorded robocalls reviewed by CNN's KFILE and calls and data obtained from Nomorobo, a company with a widely used application to stop robocalls on cell phones and landlines, show Support American Leaders PAC did not have any required disclosures on their calls. Calls from Support American Leaders PAC began with clips of Trump and ended asking for callers to either connect with a call operator or unsubscribe.

CNN's KFile first discovered the calls on the Nomorobo website , which tracks robocalls through the 250,000 phone lines they own in order to block them on their application. In calls sent to phone numbers owned by Nomorobo, 1,688 calls received on 545 different lines, not a single instance recorded included a disclaimer of who was behind the calls.

An FEC spokesperson told KFile that they require that telephone solicitations by a candidate's campaign or a committee, "must include a clear disclaimer identifying the name of the committee that paid for the communication." Communications not sent by a committee authorized for a federal candidate must have a disclaimer that must "state the name of the committee paying for it and whether or not it was authorized by a federal candidate."

The FEC also prohibits fundraising that misrepresents "the person as speaking, writing, or otherwise acting for or on behalf of any candidate."

The FCC requires any pre-recorded political robocalls to identify the name of the committee behind the calls at the beginning of the message and a callback number must be provided either during or after the message. Section Five of the Federal Trade Commission Act bars deceptive practices in commerce when "a representation, omission, or practice misleads or is likely to mislead the consumer."

Despite this, Tunstall claimed his calls featured the required disclosure and said he made more than 200,000 calls.

"I can't comment on how much of the recording Nomorobo was able to record, but the name of the PAC and also the required phone number are at the end of the recording per FEC regulations for political voice broadcasts," he said. "200,000 calls were placed with different message variants for the pre-launch test, and in the coming months, we plan to reach over five million voters combined between radio, television, and phone calls."

Professor Richard Hasen, a University of California, Irvine professor of law and political science, says that Tunstall may be opening himself up to criminal penalties if his actions were intentional.

"Willful violations of federal campaign laws can subject someone to criminal liability in addition to civil penalties," Hasen told CNN.

Hasen pointed to an example of a GOP donor who was indicted earlier this month for using his super PAC to funnel more than $1 million in contributions to himself.

Tunstall and his PAC aren't easy to find

Because of the lack of disclosure in the robocalls, the PAC could only be reached by being connected with an operator if you received a call and pressing a number when prompted. Nomorobo had incoming calls from numbers associated with the PAC forwarded to the cellphone of a reporter for CNN.

Operators in call centers repeatedly told KFile in four calls that the group making the call was the Trump campaign. When pressed, operators said the money was going to Conservative Leaders PAC, a non-existent PAC. KFile only discovered the real name of the organization by making a donation to the group with a pre-paid debit card.

The transaction was charged as "Support Trump" through Rally, a payment processor used for fundraising solicitations. Rally, which informs donors where their money goes when asked, told CNN the money went to Support American Leaders PAC -- a PAC registered with the FEC.

Tunstall is the only name on paperwork for the group and a phone number listed for the PAC was previously not a working number.

Following an inquiry, Rally told CNN's KFile the processor had suspended Support American Leaders PAC based on previous reports on Tunstall.

Tunstall told CNN that call center operators were told to give the name of correct PAC and that the error was the result of incorrect scripts.

"The call center agents are trained to say that the contribution goes to helping Support American Leaders PAC, re-elect President Trump and support his agenda, which is true," he said. "The initial testing is still in the pre-stage where call center agents are still getting used to the scripting. This was an error or something that isn't on the script if you heard this. Agents are instructed to state the disclaimer at the end of the call per FEC regulations which is, 'This call was paid and authorized by Support American Leaders PAC. Contributions made are not tax deductible for income tax purposes.'"

Tunstall declined to give CNN the name of his call centers when asked.

For an organization without a website or any media attention, FEC records show Support American Leaders PAC raised $114,240 in January . But the records don't show any individual donations; instead the group lists only one donation for the entire amount raised as coming from a group called "Support America."

Tunstall could not say what "Support America" was on his FEC records.

"Donor information is only required for donations over $200 and we used best efforts and are still using efforts to collect the occupation and employer for these donors," Tunstall told CNN when asked about the lack of individual donors listed. "'Support America' might be the payment processor descriptor, or a check by mail donation."