Make America Number 1, the pro-Trump super-PAC controlled by hedge-fund billionaire Robert Mercer and his daughter Rebekah, has paid law firms associated with Rudy Giuliani $563,003 in 2015 and 2016.

The PAC, originally called Keep the Promise 1, supported Ted Cruz before shifting to Donald Trump after he secured the Republican nomination this spring. It began paying Bracewell & Giuliani for legal and compliance services in June of 2015, making $336,495 in payments until February 14, 2016. It stopped using Bracewell a couple of weeks after Giuliani left the firm in January.

Ted Cruz dropped out of the Republican presidential field on May 3. Sometime that month, Rebekah Mercer and Kellyanne Conway, who led the PAC when it was backing the Texas senator and is now Trump’s campaign manager, had lunch with Ivanka Trump and Jared Kushner. There, the Washington Post reported, “Ivanka and Rebekah bonded over parenting young children and being the daughters of hard-charging, successful fathers, according to people familiar with their conversation.”

Also in May, on the 12th, the PAC retained Giuliani’s new firm, Greenberg & Traurig, initially paying $99,470 for legal and compliance services. In June, the PAC changed its name and aligned itself squarely with Trump. On its website, the group described itself as “supporting conservative principles, upholding the rule of law, and opposing ethically challenged candidates… It’s (sic) first special project entitled, ‘Defeat Crooked Hillary’, will shed light on what the Clinton’s (sic) want to keep in the dark.”

On July 22, the PAC paid Greenberg $9,698 for “legal consulting services.” That payment came the day after the Republican National Convention, which Giuliani spoke at and attended with his wife. If the payment had anything to do with covering the expenses of a convention speaker, that might well violate the federal guidelines — including operating independently of a campaign — that Giuliani’s firm was supposed to oversee as part of its compliance services.

Three payments in September and October tallied $118,340, also for “legal consulting services.”

A call to Giuliani’s aide at the Greenberg firm was not immediately returned. Hogan Gidley, the communications director for the PAC, said he could not answer the Beast’s questions but that he would try to get someone else at the PAC to respond.

After I reported in the New York Daily News in September that Greenberg Taurig represents both Trump and Kushner Companies, the real estate firm headed by Trump’s son-in-law Jared, Giuliani took a leave of absence, saying he would return after the election. Kushner is one of Greenberg Taurig’s top development clients; Trump has used the firm himself for small Florida matters. Shortly after Giuliani joined Greenberg in January, Trump announced that the former mayor, who’s become one of his most prominent surrogates, was acting as an informal adviser to the campaign.

Conway joined the Trump campaign on July 1 and was later promoted to campaign manager. She was briefly replaced at the PAC by David Bossie, the longtime head of Citizens United who has made a career of his war against the Clintons. Steve Bannon, who became chair and CEO of the Trump campaign on August 17, had previously been the executive chairman of Breitbart News, which counts the Mercers as major investors. After just weeks at the outside group, Bossie rejoined Conway as Trump’s deputy campaign manager and Rebekah Mercer herself then took charge of day-to-day control of the PAC.

While his firm has been on the PAC payroll, Giuliani has been fanning the flames of every Clinton controversy. But he has made it clear that he thinks the Clinton Foundation issues are the worst, saying on Fox this week: “This was the one I always thought was clearer.” Invoking his history as a federal prosecutor, Giuliani said he could make a case against the Clintons on the foundation “in two months.” The foundation has long been a fixation of the Mercers as well. They fund the Bannon-led non-profit Government Accountability Institute whose president, Peter Schweizer, author of “Clinton Cash,” an innuendo-strewn book about the foundation that apparently became fodder for a probe initiated by FBI agents from the New York office earlier this year. Rebekah Mercer serves on the Institute’s board and co-produced, with Bossie, a documentary based on the book that was released just before the Democratic National Convention.

Giuliani confirmed in a Fox interview Friday what the Beast reported Thursday—namely, that he has been talking to agents about the Clinton cases. He didn’t say if he’d told those agents that his firm represents a Trump super-PAC run by one of Trump’s biggest donors, the Mercers, who’ve given at least $15.5 million. Or that his firm’s clients include Trump and the Kushners. Giuliani described his conversations with “outraged agents” as if they were one-sided exchanges, with agents complaining about FBI and Justice Department brass blocking legitimate probes for political reasons, and him just taking it in. “I did nothing to get it out,” he said today, referring to the Comey letter renewing the email probe and subsequent leaks that have rocked the presidential campaign. Later that day, though, he said that he had spoken only to retired agents.

If Giuliani’s firm had been charged with compliance oversight for the PAC, the results have been questionable, and not just because of the timely disbursement to his firm in July. The PAC has a substantial relationship with two companies that have been connected to Bannon and had shared the same Beverly Hills address as Breitbart, paying millions for video and data services from production house Glittering Steel (which has worked with the Mercers’ PAC in both its Cruz and Trump incarnations) and political data firm Cambridge Analytica.

There may have been nothing questionable about that before August, but the two entities have been paid more than $4 million by Make America Number 1 since the Breitbart head — who said Friday that he intends to return there after the election — took over the Trump campaign. A film industry source this week described Glittering Steel to The Daily Beast as little more than “a front for Bannon.”

If the Federal Election Commission—presently deadlocked between its two Republican and two Democratic commissioners—actually looks at campaign violations, it might want to work out what interest, exactly, the CEO of Trump’s campaign has in the two biggest vendors for a super-PAC.

Avoiding legally prohibited coordination between campaigns and PACs, after all, is just the sort of conflict that they pay lawyers to ensure they’re in compliance with.

Anna Lenzer contributed research to this report.