What began as an unseemly scandal for Cambridge Analytica is drifting into the realm of potential illegality. Last week, former Cambridge employee Chris Wylie recalled in an interview how the data-mining firm took discrete steps to comply with U.S. campaign-finance rules, establishing its operation with deliberate finesse. Such attention to detail, however, was apparently short-lived. Despite an explicit warning from an attorney to abide by laws limiting foreign involvement in domestic elections, Cambridge Analytica reportedly assigned at least 20 non-U.S. citizens to work on congressional and legislative campaigns for Republican candidates in 2014, former employees told The Washington Post:

The assignments came amid efforts to present the newly created company as “an American brand” that would appeal to U.S. political clients even though its parent, SCL Group, was based in London, according to former Cambridge Analytica research director Christopher Wylie.

Wylie, who emerged this month as a whistleblower, provided The Washington Post with documents that describe a program across several U.S. states to win campaigns for Republicans using psychological profiling to reach voters with individually tailored messages. The documents include previously unreported details about the program, which was called “Project Ripon” for the Wisconsin town where the Republican Party was born in 1854.

In a memo, New York attorney Lawrence Levy reportedly advised the company’s leadership that British C.E.O. Alexander Nix would have to be “recused from substantive management of any such clients involved in U.S. elections.” Foreign nationals could collect and process data, the memo warned, but “may not play strategic roles including the giving of strategic advice to candidates, campaigns, political parties or independent expenditure committees.” Yet Nix was reportedly part of multiple conference calls in which strategic matters were discussed. Worse, according to Wylie, the task force working on the program was virtually entirely foreign. “It’s a dirty little secret that there was no one American involved in it, that it was a de facto foreign agent, working on an American election,” said Wylie, who provided documents to the Post detailing a staff of 41 employees and contractors, and a budget of some $7.5 million between April and July 2014. Cambridge Analytica, Levy, and Nix all declined the Post’s request for comment.

According to Wylie, Levy’s memo was raised in multiple conversations between co-founder Steve Bannon and Nix, who was recently suspended from the company after an undercover video was released that appeared to show him discussing possible bribes and extortion schemes to ensnare political rivals. (Bannon, too, declined the Post’s request for comment.) Speaking anonymously for fear they may have breached U.S. law in their campaign work, two other Cambridge Analytica workers told the Post that anxieties around the legality of Cambridge Analytica’s work in the United States were commonplace, especially after the 2014 vote. Some within the company suspected that it gave its foreign employees inaccurate immigration documents indicating they were not in the U.S. to work on advising campaigns. “We knew that everything was not above board, but we weren’t too concerned about it,” said one former staff member, who spent several months in the U.S. “It was the Wild West. That’s certainly how they carried on in 2014.”