— British contractors from Cambridge Analytica were "all over" state Republican Party offices in the closing months of North Carolina's 2014 U.S. Senate election, according to sources close to the party.

One North Carolina source said the company, under fire over its use of Facebook data and under investigation for its methods in British politics, had three employees embedded with the North Carolina Republican Party. Two other sources said there were at least two people.

That's consistent with what Cambridge Analytica whistleblower Christopher Wylie, who kicked off international inquiries of the company, has said – Cambridge Analytica had "three or four" full-time staffers, none of them U.S. citizens, in the state for the successful 2014 effort to elect U.S. Sen. Thom Tillis.

These would have been among the dozens of non-U.S. citizens The Washington Post has reported Cambridge Analytica assigned to GOP campaigns in the U.S. in 2014.

Federal election regulations limit the role foreign nationals can play in U.S. campaigns. Wylie and anonymous former Cambridge Analytica employees have also accused the company of using ill-gotten private information from more than 50 million Facebook users to build voter profiles that then were used to target political messages.

Documents released by the British Parliament this week include references to personality profiles built for North Carolina's 2014 elections: Lazy Liberals, Turnout Targets, Priority Persuasion and Wild Cards. The company and its parent, SCL, worked not only for the Tillis campaign and the state GOP in 2014 but also for a Super PAC headed by John Bolton, a former U.S. ambassador to the United Nations whom President Donald Trump recently named as national security adviser.

The companies did micro-targeting: predicting what messages would work for certain people and suggesting ways to tailor ads and get-out-the-vote efforts.

A complaint filed with the Federal Election Commission on Thursday – it is at least the second FEC complaint naming the company – accuses Bolton's Super PAC of making illegal contributions either to the North Carolina Republican Party or the Tillis campaign by financing coordinated communications through Cambridge Analytica, which was a mutual vendor.

A Bolton spokesman called these allegations "frivolous."

"There was no coordination, direct or indirect, between the John Bolton Super PAC and the Tillis campaign, and the John Bolton Super PAC did not discuss any election-related, or any other topics, with the individuals named in the complaint," spokesman Garrett Marquis said in an email.

In North Carolina, top Tillis campaign operatives and party leaders from 2014 have largely declined to discuss the company on the record, though Tillis has issued three written statements and former state GOP Chairman Claude Pope shared his limited memories of the company's involvement this week. The Tillis campaign responded to the new FEC complaint by saying that, "if anything improper was done by the vendor Cambridge Analytica during the course of the election, it was done without the campaign’s knowledge or consent."

The campaign paid Cambridge Analytica $130,000, or slightly more than 1 percent of its $10.5 million in direct campaign spending. Tillis has characterized the company's role as "limited."

Democrats have trouble accepting that. The bulk of payment from the Tillis campaign came in 2015, after the election, and has been characterized by the campaign as a "win bonus." Tillis campaign records show a number of 2014 vendors receiving payments in 2015, but it's impossible to tell from the records what was considered a win bonus for the 2014 campaign.

Tillis's 2015 payment to Cambridge Analytica was broken into four installments of $25,000 each: two in April, one in July and a final payment four days before Christmas. Campaign finance entries simply describe payments as "micro-targeting."

“There was no coordination, direct or indirect, between the John Bolton Super PAC and the Tillis campaign.” Garrett Marquis, spokesman for John Bolton

The Tillis campaign also said any foreign nationals on the ground in North Carolina worked for the state party, not his campaign. State GOP Executive Director Dallas Woodhouse, who was not with the party in 2014, told The Washington Post last week that "no foreign workers worked for us."

But Woodhouse told WRAL News he didn't know if any of the party's contractors had foreign nationals working for them, and he has actively dissuaded party leaders from 2014 from speaking to reporters, saying the party must speak with one voice. Woodhouse said the party simply contracted with a vendor and wouldn't have known its workers' nationalities.

Sources who worked with the party in 2014 said it was obvious.

"I totally remember the British guys coming down," one said. "Everybody raved about how good they are."

Another said the consultants "ran around ... and told everybody to do this message or that message."

Without acknowledging this, Woodhouse has said repeatedly that it wouldn't be illegal to use foreign workers on a campaign because they wouldn't have made decisions. That's an important distinction under federal election rules, as well as a gray area.

Common Cause, a left-leaning watchdog group, filed a Department of Justice complaint seeking a criminal investigation into Cambridge Analytica and SCL, which has been described both as a parent company and a sister company. The group filed a companion complaint with the FEC.

Based on Wylie's claims, news reports and the way other former Cambridge workers have described their work, "there is reason to believe" foreign contractors participated in "the decision making of US political committee clients," the twin complaints state.

Woodhouse and other North Carolina sources deny that happened here. One former party staffer, who would not comment without anonymity, said party leadership made "every single decision in terms of messaging, allocation of resources for mail, digital."

Pope said the British consultants "certainly made recommendations," but decisions depended on much more input.

"(They said), 'This precinct you ought to target before this other precinct,'" Pope said. "But ultimately, where we deployed people was kind of in concert with the [Republican National Committee] and the state party and whatnot. And that also depends on your resources."

Cambridge Analytica denies charges

Cambridge Analytica has denied most of the accusations against it.

It has said repeatedly that Wylie left the company in July 2014 and "has no direct knowledge of the company’s work or practices since that date." The company also has pointed to a memo from its legal team that summarizes company policy: non-U.S. nationals can work on U.S. campaigns "only in non-strategic (i.e. functionary) roles."

"We strictly adhere to this policy in all of our US political work," the company said in a written statement.

Cambridge Analytica who's who Cambridge Analytica: Political consulting company focusing on data analysis. Whistleblower Chris Wylie says the company stole data from Facebook. SCL: The parent company of Cambridge Analytica (though some reports call it a "sister" company). Alexander Nix: Suspended CEO of Cambridge Analytica Aleksandr Kogan: An academic scientist who worked for Cambridge Analytica. He got the Facebook data legally then started his own company, Global Sciences, and contracted the data out to Cambridge Analytica. Tim Glister: A former Cambridge Analytica employee who boasted on his website that he helped U.S. Sen. Thom Tillis win his 2014 election. Campaign Legal Center: A nonpartisan government watchdog group, it has filed a complaint with the Federal Election Commission against the John Bolton Super PAC, saying it had made illegal contributions to the Tillis campaign. Common Cause: A left-leaning watchdog group, it has asked the Department of Justice and the FEC to look into Cambridge Analytica's involvement in Tillis' 2014 campaign. John Bolton and John Bolton Super PAC: Bolton is now President Donald Trump's national security adviser. His PAC was active in both Tillis' 2014 campaign and U.S. Sen. Richard Burr's 2016 campaign. Steve Bannon: Former adviser to President Donald Trump, was on the board of Cambridge Analytica Mercer family: GOP activists in the U.S., they funded Cambridge Analytica. Robert Mercer: Top donor to John Bolton Super PAC Claude Pope: Former chairman, N.C. Republican Party Dallas Woodhouse: Executive director, N.C. Republican Party

Cambridge Analytica's London offices were raided earlier this month by Britain's Information Commissioner's Office, which is reportedly interested in work the company did on the country's 2016 vote to leave the European Union. Also, Chief Executive Alexander Nix was suspended after a British television station publicized video of him discussing entrapment and bribing politicians, including the potential of using beautiful Ukrainian women in company operations.

In the U.S., special counsel Robert Mueller is reportedly probing the company as he investigates Russian meddling in the 2016 presidential election.

One potential connection is Alexsandr Kogan, the Cambridge University researcher who obtained the personal Facebook data of up to 50 million people for academic study, then formed his own company and contracted out the data to Cambridge Analytica. At the time, Kogan was also working on a research project on social media in Russia at St. Petersburg State University.

Other links between the company and the Trump campaign include Steve Bannon, Trump's former campaign manager and adviser, who was on the board of directors at Cambridge Analytica. Also, the company was funded by the Mercer family, which is a major player in U.S. Republican politics and helped fund the Trump campaign.

Robert Mercer was also the top donor for the John Bolton Super PAC, which focused largely on foreign policy and national security issues and not only worked to elect Tillis in 2014 but also to re-elect U.S. Sen. Richard Burr in 2016.

The PAC used Cambridge Analytica in both election cycles, spending about $341,000 in 2014 and $811,000 in the 2016 cycle. The PAC supported several candidates in several states, including both Tillis and Republican U.S. Sen. Richard Burr in North Carolina.

A Burr spokesman did not return a request for comment. The Bolton PAC has denied wrongdoing in blanket statements, largely responding to concerns from 2014, saying its agreements with Cambridge Analytica included assurances the company had rights to the data it used and that "no individuals at Cambridge Analytica, foreign or otherwise, made any strategic decision regarding election-related activities."

Pope, the former state GOP chairman, described company's role in North Carolina as one vendor of many doing the same sort of analytical work that former President Barack Obama's presidential campaign pioneered, largely catching Republicans flat-footed in 2012.

The state GOP spent $215,000 with Cambridge Analytica in 2014 and 2015, and Pope said the 2015 payments were likely costs invoiced in 2014 but not paid until the next year. The party was the company's fourth-largest client in 2014.

"You can try to connect dots," Pope said. "I don't really think there are dots to connect. I didn't even know who Steve Bannon was."

Another source from the party's 2014 operations said there was a "very strict firewall" between the Cambridge Analytica team and party leadership.

One of the FEC complaints against Bolton's Super PAC states that firewalls can be created, but "the evidence indicates that any such firewall was ignored" in the PAC's case. This complaint, from the Campaign Legal Center, accuses the Bolton PAC of making "excessive and unreported contributions" to the state GOP or the Tillis campaign "by financing coordinated communications" through a vendor all three had in common in 2014: Cambridge Analytica.

The center's founder and president is Trevor Potter, a former FEC chairman appointed by President George H.W. Bush.

Wylie testified before Parliament this month that Mercer used the company to skirt campaign finance laws by putting money into the firm and then having the firm work on political causes – at least in Britain – for less than market rate.

North Carolina sources have said Cambridge Analytica seemed eager to break into U.S. politics, and one source told WRAL News the company lowered its initial asking price substantially to get the contract with the state GOP.

Cambridge employee's online portfolio changed

Many of the accusations in the Campaign Legal Center's complaint track back to a former Cambridge Analytica employee's online portfolio.

Tim Glister was one of the company's workers in North Carolina in 2014, according to reporting first done by Bloomberg and according to Glister's portfolio and social media accounts.

Glister's website initially said he spent three months on a team, "helping Thom Tillis' successful senatorial campaign create highly targeted advertising that harnessed SCL's national database of voter issue sentiment and psychographic profiles." The video advertisement Glister's site featured was an ad paid for by the Bolton Super-PAC.

After Rachel Maddow's MSNBC news show reached out to Glister, the site changed, saying Glister "provided a local political party with voter sentiment analysis they used in support of Thom Tillis' successful senatorial campaign."

Glister's website has since become password protected, but WRAL News obtained screenshots of the changes, which were also featured on Maddow's show. Glister did not return messages WRAL left for him at his current job in England.

Like Glister, Cambridge Analytica bragged online about its role in the Tillis election, saying it was "able to accurately predict partisanship, turnout, issue importance and build psychographic profiles for all voters in North Carolina" and that it identified national security as the top issue among targeted voters here. This information was used to criticize Democratic U.S. Sen. Kay Hagan's poor attendance record at Senate Armed Services Committee hearings, which was the subject of numerous ads in the 2014 race.

North Carolina sources have said Cambridge Analytica is overstating its role in a massive operation, as political consultants often do after a victory. Tillis told reporters during a short walk-and-talk interview in Washington, D.C., that he had "very limited interaction" with British contractors during that race. He said that included one encounter with Nix, the suspended CEO, but that he didn't remember anything about it, "except I was in the same room."

Tillis also said his campaign team looked into the allegations when the Cambridge Analytica story first broke and that the firm played "a relatively small part" in his election campaign.

"We think it was a de-minimis influence, but we're looking at it," he said. "If it was something that was inappropriate, then we'll be the first to call it out."

What constitutes campaign decision-making?

Federal law bans campaign donations of "money or other thing of value" from foreign nationals, but it doesn't actually say it's illegal for foreign workers to make decisions in a campaign.

That language comes from FEC regulations that expand on the law and say foreign nationals "shall not direct, dictate, control, or directly or indirectly participate in the decision-making process" of campaigns.

The regulation gives limited examples: They can't make "decisions concerning the making of contributions, donations, expenditures, or disbursements in connection with elections ... or decisions concerning the administration of a political committee."

Just what that means in practice is difficult to say.

“We knew that everything was not above board, but we weren't too concerned about it. It was the Wild West.” unidentified Cambridge Analytica employee

"Foreign nationals might be able to work on campaigns, but they could not provide strategic decisions and help on strategy/substantive decision making," said Common Cause Chief of Strategy & External Affairs Stephen Spaulding, who has also been special counsel to an FEC commissioner.

Marshall Hurley, a campaign finance attorney in North Carolina who served as general counsel for the state Republican Party from 2004 to 2009, said decision-making on a campaign can be "a pretty nebulous thing."

"When I was running it, we were always on guard against the contributions from foreigners," Hurley said. "And we were just talking about checks. We weren't talking about activisim."

Michael Weisel, who does campaign finance work in North Carolina for Democrats, said in an email there are no clear guidelines and that the FEC has given conflicting advice in this area over the years.

A memo written by an attorney for Cambridge Analytica and widely reported by national media warned against using foreigners on high-level analysis or strategy, saying they could serve in minor roles as "functionaries" handling data, for example.

"Remember, it is the ability to influence the expenditures of campaign dollars, at the federal state or local level, that is prohibited," the memo states.

According to The Washington Post, former Cambridge Analytica workers said they regularly discussed concerns about legality of their work.

"We knew that everything was not above board, but we weren't too concerned about it," one unnamed source told the newspaper. "It was the Wild West. That's certainly how they carried on in 2014."

Republicans urged not to talk

WRAL News reached out to more than 20 Republican operatives and vendors who worked for the party, the Tillis campaign or both in 2014.

Most wouldn't speak. Woodhouse said many called him instead.

"I'm going to shut it down every time," he said. "I don't want numerous people, four years later, speaking for the party."

Woodhouse has been speaking for the party, even though he was an outside political consultant in 2014 not employed by the state GOP.

Todd Poole, who held Woodhouse's position in 2014, declined to comment for this story, as did Paul Shumaker, a lead consultant for both the Tillis and Burr campaigns, and Jordan Shaw, Tillis' 2014 campaign manager.

Woodhouse has pushed back against the idea that foreign contractors worked out of the party's Raleigh office, despite a trio of sources who told WRAL News they did.

"None," he said at one point. "There was nobody camped out here."

At another point, he said he could "accept other people said it. I just can't independently verify it."

Woodhouse and others have also sought to minimize the role Cambridge Analytica played, calling them one source of data, not the source of data. Woodhouse said neither the party, nor Shumaker, would limit themselves to single data source "because, if they're wrong, you lose."

"Whatever they did ... at some point, it comes to us, and we decide," Woodhouse said.

Editor's Note: This story has been edited to clarify that certain statements came from the Tillis campaign, not from Sen. Thom Tillis himself. Dallas Woodhouse, executive director of the North Carolina Republican Party, has issued a statement contesting several elements of this story; you can read his full statement here. WRAL stands by its reporting and the accuracy of this story.