The Trump campaign funneled money to ad buyers alleged to have facilitated illegal coordination between the campaign and the NRA by routing funds through a secretive LLC that appears to be little more than a shell company, an investigation by the Center for Responsive Politics has found.

While the Trump campaign stopped reporting payments to ad buyers alleged to have facilitated illegal coordination between the campaign and the NRA after the 2016 election cycle, Trump’s 2020 campaign has continued to deploy the same individuals working for the firms at the center of the controversy through payments to Harris Sikes Media LLC — a low-profile limited-liability company operating with no website or public-facing facade whatsoever.

Facing the illegal coordination allegations are National Media, Red Eagle Media Group and American Media & Advocacy Group (AMAG), closely tied consultancies that share staff, resources and adjacent storefronts in Alexandria, Va.

CRP’s analysis of Federal Communications Commission (FCC) records found that Trump campaign political ad disclosures on file with stations across the country have continued to include signatures and names of individuals working for National Media, despite no mention of National Media or its known affiliates on any FCC or Federal Election Commission (FEC) disclosures. Those individual ad buyers’ names have simultaneously continued to be included in ad documents for the National Rifle Association (NRA) and America First, but with the ad buyers’ affiliation listed as National Media or one of its affiliates.

Common vendors are one of the factors federal regulators consider when determining if communications may constitute illegal coordination between a campaign and outside group.

Harris Sikes Media does not appear to have any contacts independent of National Media, and all of the individuals listed on FCC filings submitted by Harris Sikes Media have also been featured in filings by National Media or its affiliates.

But unlike Red Eagle Media Group and other National Media affiliates like AMAG — which share the same neighboring Alexandria addresses — incorporation records list Harris Sikes Media’s address as 11350 Random Hills Road, Suite 700, in Fairfax, Va., which houses multiple law offices and advertises options to rent virtual offices, coworking space and meeting rooms. The Trump campaign’s FEC disclosures reveal $214,319.92 in payments to Harris Sikes Media but list a slightly different address: Suite 700 at 11350 Random Hills Road in Alexandria. There is no Random Hills Road in Alexandria.

One FCC filing lists Harris Sikes Media’s address as 817 Slaters Lane in Arlington, an address even closer to the location that houses National Media and its other affiliates, without any mention of them by name. There is no Slaters Lane in Arlington.

Harris Sikes Media’s registered agent is Joel L. Dahnke, an attorney who is also the registered agent for National Media Group LLC, National Media Research Planning and Placement, LLC and National Media President Robin Roberts’ firm.

The three ad buyers whose names have popped up the most on political ad records for all three groups are Ben Angle, Megan Burns and Jonathan Ferrell.

Although all three individuals’ names have appeared on filings from Harris Sikes Media, they are listed as employees of National Media and its affiliates — their names or signatures showing up on FCC political ad filings for Red Eagle, AMAG and National Media during that time period.

Using CRP’s unique full-text search tool to scour data scraped from FCC filings, CRP discovered that each individual ad buyer’s name has been listed on FCC filings by the Trump campaign as well as outside groups spending on ads supporting Trump’s agenda during the 2018 election cycle.

Many other orders and invoices only list the agency and leave the field requesting the name of an individual buyer blank. Even without a buyer disclosed, the bulk of those records do include signatures. In most — if not all — cases, that signature belongs to Jonathan Ferrell.

As recently as October 2018, the Trump campaign and NRA made ad buys at the same local radio station within days of each other in filings that list the same individual ad buyer but with Trump’s campaign listing Harris Sikes Media as the firm and the NRA listing Red Eagle.

Unlike the NRA’s ads during the 2016 election cycle, most of the more recent ads are focused on issue advocacy or supporting other campaigns — arguably making the risks of coordination with Trump’s campaign less dire. But the lengths to which the Trump campaign has gone to distance itself from disclosing payments to National Media affiliates while still paying the same individual ad buyers through other channels raises a number of questions, especially as 2020 approaches and ads begin to focus more on Trump’s re-election.

It’s Not Just the NRA

The NRA is not the only outside group supporting Trump that has become embroiled in an alleged campaign coordination scheme routing payments through National Media’s affiliates, suggesting a symptom of a much larger epidemic of increasingly blurred lines between campaigns and the groups supporting them.

The Trump campaign abruptly cut off payments to known National Media affiliates shortly after reporting scrutinizing the closely tied firms sharing addresses and employees while being paid by Trump’s campaign and a super PAC supporting him during the 2016 election. The group at issue for the payments was Rebuilding America Now, a single-candidate super PAC supporting Trump.

Rebuilding America Now was recently named in a partially redacted court filing by prosecutors working for special counsel Robert Mueller regarding a $125,000 wire transfer to former Trump campaign chair Paul Manafort to cover a debt he owed — a payment Manafort lied to federal investigators about, according to the filing.

During the 2016 election, Manafort dispatched two associates he hired as Trump’s campaign chair to the super PAC, potentially violating federal campaign rules that require a cooling off period.

Rebuilding America Now has also come under scrutiny for allegedly accepting money from foreign federal contractor barred by federal campaign finance rules from donating to a super PAC.

Rebuilding America Now spent more than $22.7 million during the 2016 election cycle, with nearly half-a-million of that going through National Media.

Shell Games and Blurred Lines

Following Trump’s inauguration, America First — a collaboration between the America First Action super PAC and its affiliated 501(c)(4) nonprofit America First Policies — stepped up to bat, quickly establishing a cozy relationship with the Trump campaign and White House.

The America First groups have run with the model pioneered by President Barack Obama’s Organizing for Action, tightening the operation’s relationship with the president’s campaign and agenda even further.

Unlike Organizing for Action before them, which did not exist as a 501(c)(4) until after Obama’s re-election in 2012, America First has been active throughout almost the entirety of President Trump’s first term as he navigates the roles of both candidate and president following an unprecedented move to register as a candidate for the 2020 presidential election on his first day in office.

America First has been open about its revolving door of staffers bouncing between its affiliated groups, Trump’s campaign and White House. But the operation has not been so transparent about all of their activities.

Perhaps most notably lacking in transparency is the operation’s fundraising. America First Policies, the 501(c)(4) arm of the operation, does not disclose donors — leaving millions of dollars unaccounted for.

The group’s fundraising tactics have raised some eyebrows. Despite rules prohibiting coordination between a campaign and outside group supporting them, candidates are allowed to “attend, speak at, or be featured guests at fundraisers” for those same groups. The America First operation has continued to push these rules to their limits, drawing in high-dollar donors to events at the Trump International Hotel just blocks from the White House with President Trump himself as their special guest. And so long as President Trump does not personally ask for more than $5,000, the groups are in the clear.

America First’s limited disclosure around how that money is spent has also raised questions about the groups’ finances that have yet to be answered.

The America First groups have even gone as far as paying firms closely tied to key individuals employed by the campaign.

CRP’s review of FCC political ad disclosures shows that the ties between Trump’s campaign and the primary groups supporting it may have reached another level.

National Media and its affiliates have become a well-known institution of the swamp Trump pledged to drain, but this tactic of routing funds through Harris Sikes Media — which appears to be a previously unreported shell company that was not known to be affiliated with National Media — appears to be something new, and Trump is the first major federal candidate known to have been a part of it, according to CRP’s review of FCC records.

The only other political ad disclosures in FCC records dating back to 2015 that mention Harris Sikes Media are for Rep. Jeff Landry (R-La.) and Louisiana Rising, the political action committee associated with Scott Angelle’s failed gubernatorial campaign.

Using shell entities to circumvent campaign coordination rules is hardly a new concept, and something that often occurs without consequence — giving consultants free rein to exploit these tactics.

Trump’s re-election campaign and the America First operation have run multiple ads submitted by the same ad buyers, many of them seemingly complimentary in time, focus and location.

Many of the ads America First’s operation has run thus far — years away from the 2020 presidential election — resemble issue advocacy, focusing more on health care, tax reform and Trump’s nominees than the far-off election. At almost every ad’s core, however, the issue is Trump, with FCC political ad disclosures even listing the issue in the ad as “pro-Trump agenda.”

As the election nears, this all-encompassing support of Trump may make it difficult to tell the difference between ads supporting Trump’s agenda as president and his agenda as a presidential candidate — effectively allowing a group run by a candidate’s former staffer to pay the same individual ad buyers paid by the campaign to make purchases at the same time where the only issue listed is supporting the candidate’s agenda.

While some of the issues presented by the Trump campaign’s approach to outside groups may seem novel, Trump is hardly the only candidate with blurred lines between his campaign and outside groups supporting him. And in a political environment where many candidates face allegations of flagrantly violating campaign coordination rules without consequence, it’s unlikely his campaign will be the last to adopt this approach.

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