In the summer of 2018, congressman-turned-lobbyist Jim Moran was trying to recruit his former colleagues to put pressure on the Kingdom of Saudi Arabia. Moran was doing so on behalf of one of his clients, the government of Qatar. And he had a pot of money, left over from years of donations to his reelection campaigns, that he could steer to his lobbying targets.

Throughout June and July, Moran, a “senior legislative advisor” at the firm McDermott Will & Emery, reached out to at least a dozen House and Senate members of both parties as part of the effort. He provided them with suggested text for the letter, which he hoped the legislators would send to the Saudi ambassador to the U.S. urging him to ease travel restrictions between Saudi Arabia and Qatar.

One of the congressmen Moran pitched was Rep. Charlie Crist (D-FL). On June 15, 2018, Moran’s assistant emailed Crist’s chief of staff with a draft letter they hoped the congressman would send under his name. Moran’s staff even followed up with suggested edits.

Crist obliged. On June 20, he sent a letter to the Saudi ambassador that lifted huge portions verbatim from Moran’s suggested language.

A month later, Moran wrote a $1,000 check to Crist’s reelection campaign. But the money didn’t come from Moran personally. Instead, the former congressman used his campaign committee, which remains active to this day, more than four years after he left the House. It was the first time Moran, either personally or through his campaign committee, had contributed to Crist. Neither Moran nor Crist responded to requests for comment.

Moran is one of at least 17 former members of Congress who are registered as U.S. agents of foreign governments and have also kept their campaign committees active since retirement—or converted them, along with their cash reserves, into other types of committees that can disburse funds to political allies. And according to a joint investigation by The Daily Beast, the Campaign Legal Center, and the Center for Responsive Politics, at least nine of those former members have used those committees to donate to the same legislators they’ve reported lobbying on behalf of their foreign government clients.

“It is common knowledge that some politicians leave Congress and head to K Street, where they leverage the connections with former colleagues and insider knowledge developed during public service to promote their lobbying clients’ interests,” CLC writes in its report accompanying the investigation. “But the Congressional revolving door and cash-for-access systems become even more concerning when politicians-turned-lobbyists use leftover campaign funds to promote the interests of foreign governments—not to mention their own lobbying careers.”

“Examples like these,” CLC says, “add another dimension to the familiar but ever-expanding story of money, influence, and access in Washington.”

Moran spent 24 years in Congress before spinning through Washington’s revolving door. He spent many of those years as a top House appropriator with a spot on the subcommittee that doled out defense spending. And he represented a suburban D.C.-area district, Virginia’s 8th, that, in 2015, brought in more defense contractor dollars than any other nationwide.

Crist was just one of six members of Congress whom Moran pitched on the Saudi ambassador letter, and to whom he had also steered leftover campaign money. And at least one of the others also came through in a big way.

According to Justice Department filings, Moran first reached out to Rep. Dutch Ruppersberger’s (D-MD) office about the proposed letter on June 12. On the very same day, Moran donated $500 to Ruppersberger’s reelection campaign. The letter went out on Ruppersberger’s official congressional letterhead on July 10, 2018, and the entire missive was copied nearly verbatim—with just some minor rearranging of its structure—from Moran’s suggested text.

A Ruppersberger spokeswoman said the two lawmakers worked closely while serving in Congress together and that Ruppersberger sent the letter because he agreed with its contents.

“We reviewed the matter for nearly a month and found we agreed,” Jaime Lennon, a spokeswoman for Ruppersberger said. “He raised legitimate concerns about the blockade separating families and creating unacceptable national security risks for our airmen. If we didn’t agree, we would not have sent a letter, plain and simple. Campaign contributions have never and will never have any bearing on Congressman Ruppersberger’s policy decisions.”

Donors who had chipped in to support Moran’s 12 successful House campaigns were, whether they knew it or not, now financing the former congressman’s support for politicians he was simultaneously lobbying on a foreign government’s behalf. And those politicians were delivering.

The amounts donated were not huge—$500 or $1,000 is a drop in the bucket for most congressional campaigns—but such contributions can amount to a showing of public support for a legislator. Timed correctly, they can win a bit of favor at just the moment that a donor needs a meeting or a favor.

Like Crist, Sen. Bob Menendez (D-N.J.) had never received a contribution from Moran or his campaign committee until Moran started shopping around his Saudi ambassador letter. Moran for Congress donated $1,000 to Menendez on June 20, 2018, a few weeks before his chief of staff got an email with suggested text for the letter. Menendez doesn’t appear to have sent one.

In early mid-2017, another recently retired member of Congress joined Moran at McDermott Will & Emery and signed on to lobby for Qatar. Former Rep. Jeff Miller, a Florida Republican, ended his House tenure with about $220,000 in leftover campaign funds. And he’s used those funds in a manner similar to Moran.

By law, former members of Congress are prohibited from “represent[ing] a foreign entity before any officer or employee of any department or agency of the United States,” including members of Congress, “with the intent to influence a decision of such officer or employee in carrying out his or her official duties.” They’re also barred from aiding or advising foreign governments seeking such influence.

That prohibition covers a former member’s first year after leaving Congress. Miller officially left in January 2017 and registered to represent Qatar six months later. In his FARA registration form in July 2017, Miller said he would “be lobbying the Executive Branch.” In an email, he noted that he had not contacted any federal official during that cooling-off period. He did not respond to follow-up inquiries regarding the precise nature of his representation for the first six months of his time on the Qatari account.

Miller defended his post-Congress tenure, telling The Daily Beast, “I made no legislative or executive branch contacts on behalf of Qatar during my one year ‘cooling off’ period. After my one year restriction expired, in 2018, I did make such contacts.”

During eight House terms, Miller earned some powerful policy positions. He chaired the Veterans Affairs Committee during his last six years in Congress, and sat on the House Intelligence and Armed Services Committees. His connections in military and diplomatic circles would soon come in handy.

In early 2018, Miller began making overtures to the office of Rep. Joe Wilson (R-SC), a member of the Congressional Caucus on Qatari-American Economic Strategic Defense, Cultural and Educational Partnership. In February, Miller reached out about arranging a dinner meeting. It was the first of at least 10 contacts with Wilson’s office over the following year.

At the same time, the money from Miller’s still-active campaign committee began flowing. In May 2018, Jeff Miller for Congress contributed $1,000 to Wilson’s reelection effort. That donation came a month after Wilson held a public event with Qatar’s finance minister in Charleston. In October, Miller donated another $1,000.

Miller was the only former lawmaker contacted for this story who responded to questions about his post-retirement use of leftover campaign funds. His contributions to former colleagues were perfectly above board legally, he stressed.

“In 2018, I made lawful contributions to sitting Members of Congress and candidates from my remaining campaign funds,” Miller said.

Miller’s contacts with Wilson continued into 2019. In March, Miller reached out to Wilson’s chief of staff to provide a white paper on Qatari investment in and economic ties to South Carolina.

Qatar’s sizable presence on K Street—McDermott Will & Emery is just one of just two dozen firms the country employed last year alone—is one side of a Washington proxy battle that has pitted some of Washington’s top influence-peddlers against a similarly formidable lobbying apparatus employed by Qatar’s chief Gulf rival, Saudi Arabia.

As Moran and Miller have used their political war chests to bolster their side of that fight, lobbyists on the other side have done the same.

It was just 10 days since the late Sen. John McCain announced his retirement, and former Rep. Buck McKeon was already making overtures to McCain’s likely successor atop the Senate Armed Services Committee.

On May 11, 2018, McKeon struck up an email exchange with the chief of staff to Sen. Jim Inhofe (R-OK), who was widely expected to chair the panel come 2019. McKeon reached out in his capacity as a lobbyist for the government of Saudi Arabia, which had hired his eponymous firm, the McKeon Group, to “undertake special advocacy assignments with regard to legislative, public policy or public affairs matters,” according to Justice Department filings.

McKeon reached out to Inhofe’s office to discuss the 2019 National Defense Authorization Act. The House Armed Services Committee, which McKeon, a California Republican, had chaired during his time in Congress, had marked up the legislation two days earlier. Democrats made repeated attempts to insert language rolling back U.S. support for the Saudi offensive in Yemen. They were expected to do so in the Senate as well.

The May 11 email was the first of at least five instances in which McKeon, in his capacity as a Saudi lobbyist, reached out to and Inhofe and his staff over the following year. And as he made overtures to the future Senate Armed Services chairman, McKeon was also cutting checks to Inhofe’s campaign.

McKeon had never donated to Inhofe before July 1, 2018, when he wrote the senator a $1,000 check, the first of four such contributions he would make over the next five months. Inhofe’s campaign deposited the check on July 23, the same day that the chairmen and ranking members of the House and Senate armed services panels published their NDAA conference report.

McKeon, whose firm declined to comment for this story, didn’t make those contributions personally. Instead, he used his campaign committee, which, like Moran’s remains active more than four years after his January 2015 departure from the House.

During his 22 years in Congress, McKeon had landed the powerful chairmanship of the House Armed Services Committee, where he served for four years and held sway over many of the same military and foreign policy issues on which his lobbying practice has since focused. Contributions from Friends of Buck McKeon, his campaign committee, have gone towards many of the legislators atop committees overseeing those issues. And those contributions have often lined up with the dates of FARA-reported meetings and contacts.

Like Inhofe, former House Foreign Affairs Committee chairman Ed Royce had never received a contribution from McKeon or his campaign committee before the lobbying campaign began. McKeon donated $2,700 to Royce on February 2, 2017, $2,000 from his campaign committee and another $700 personally.

Those donations came less than two weeks after McKeon met with Royce in order to introduce him to another one of his foreign clients, a center-left Albanian political party. In April, McKeon reported another four contacts with Royce’s office, culminating in a meeting with the congressman and a mysterious shell company linked to McKeon’s Albanian client.

Sen. Roy Blunt (R-MO), the chairman of the Senate Appropriations Subcommittee on Defense, also had never received a McKeon contribution. That changed right before the panel took up the 2019 Defense appropriations bill. McKeon’s campaign committee donated $1,000 to Blunt on June 30, 2018.

Over the next few months, McKeon met with Blunt twice, specifically to discuss an amendment proposed by Sen. Chris Murphy (D-CT) that would have cut off U.S. support for Saudi Arabia’s Yemen offensive. The amendment didn’t make it into the appropriations bill.

Federal law restricts the use of campaign funds to activities supporting a run for office, the official duties of an officeholder, and a small number of other expenses. But while federal prosecutors have recently scrutinized members of Congress who use campaign funds for personal use, there are few legal guardrails governing how those funds can be used once a member retires.

The Federal Election Commission has been nearly silent on the topic. It has never written rules governing how retired members can use leftover campaign funds, and it has not limited how long a campaign committee can stay active after retirement.

“Many former members appear to have treated their old campaign accounts as slush funds,” CLC writes in its report. “The examples in this report... underscore why the FEC should issue clear rules for so-called “zombie campaigns’—both to lay out permissible uses for campaign funds once members leave office, and to prevent former officeholders from keeping their dormant campaign committees open indefinitely.”

An investigation by the Tampa Bay Times in 2018 revealed the extent of the “zombie campaign” problem, with an emphasis on the personal, often exorbitant, expenses for which retired members use their leftover campaign funds.

Those former members use that money “to finance their lifestyles, advance new careers and pay family members,” the Times and its reporting partners found. “Their spending makes a mockery of one of the fundamental principles of America’s campaign finance laws: Donations must be spent only on politics, not politicians’ personal lives.”

The use of such funds to bolster former members’ foreign lobbying campaigns adds another problematic dimension to that controversy. The Daily Beast’s joint investigation with CLC and CRP focused on FARA registrants for practical reasons: they are required to disclose far more detail than domestic lobbyists about the officials they contact and the dates of those contacts.

To the extent that former members’ contributions support their foreign lobbying activities, the practice is also more egregious. Donors who chipped in to fund years-old reelection efforts probably didn’t expect that their money would eventually prop up K Street influence-peddling practices. They surely weren’t donating to advance the interests of deep-pocketed foreign governments and their esoteric agendas in Washington.

But with few rules on the books explicitly limiting such uses of those funds, there’s little recourse for hoodwinked donors. “This is why the FEC should prevent former officeholders from keeping their dormant campaign committees open indefinitely, in addition to clarifying permissible uses for the funds while the committees do remain active,” CLC writes. “If the FEC won’t act, then Congress must.”

The obvious defense of the practice is that former members of Congress are simply lending a hand to politicians they support, and that overlap with the targets of their lobbying practices are simply coincidental. And indeed, every one of the nine former legislators examined in CLC’s report have lobbied members to whom they have not donated, and donated to members whom they have not lobbied.

That’s a more difficult sell when former members use their campaign committees to donate to legislators whom they have never previously supported, as Moran, Miller, and McKeon all have. It’s also undercut, in many cases, by near-simultaneous contributions from the very lobbying firms that employ those former members.

In 2018, Kit Bond Strategies—the lobbying firm headed by former Sen. Kit Bond (R-MO)—was representing Mexico’s Office of Economic Affairs on trade matters, in particular the renegotiation of the North American Free Trade Agreement.

At the time, Sen. Dean Heller (R-NV) sat on the Senate Finance subcommittee on international trade, a panel with jurisdiction over U.S. free trade agreements. Bond’s firm reached out to Heller’s office in February 2018, and met with Heller personally that May. Within three days of the latter meeting, Heller got campaign $1,000 contributions from Bond personally, his firm, and KITPAC, the political group to which Bond converted his campaign committee after leaving office. Neither Bond nor his firm had donated to Heller previously.

Former Senate Majority Leader Trent Lott (R-MS) likewise converted his campaign account into a different form of political action committee after he resigned in late 2007. But like KITPAC, Lott’s New Republican Majority Fund hasn’t received a dime in contributions since his departure from Congress. That means money contributed to Lott’s and Bond’s past reelection campaigns are still paying for their contributions to legislators whom both have lobbied on behalf of their foreign government clients.

Lobbying on behalf of foreign governments is a small slice of Washington’s influence industry. The level of disclosure detail required by the Foreign Agents Registration Act makes it easier for the public and the press to discover and dissect the instances which a retired politician’s campaign contribution intersect with his or her lobbying activity. But the practice is undoubtedly widespread among traditional domestic lobbyists as well, even where more lax disclosure requirements make it harder to detect.

Nor does the data compiled here include so-called “shadow lobbyists,” or influence industry professionals who help advance special interests in Washington in ways that fall short of the official definition of lobbying. It doesn’t include, for instance, former Sen. Saxby Chambliss (R-GA), a partner at the firm DLA Piper whose still-active campaign committee donated $34,400 to Sen. Johnny Isakson’s (R-GA) joint fundraising committee on the very same day in 2015 that his firm reported meeting with Isakson on behalf of the United Arab Emirates.

Regardless of former lawmakers’ particular roles in the influence-peddling ecosystem, CLC says the lack of rules governing how their leftover campaign funds can be used invites efforts to steer that money towards post-public service professional pursuits.

“This is why the FEC should prevent former officeholders from keeping their dormant campaign committees open indefinitely, in addition to clarifying permissible uses for the funds while the committees do remain active,” the group writes in its report. “As former members get farther and farther from their time in public office, the universe of plausible officeholder-related expenses shrinks ever smaller, so keeping campaigns open for years can invite abuse.”

“Such steps could go a long way toward curbing the abuses documented in this report, and they could also help chip away at the broader systems of money, access, and influence that helps abuses like these thrive.”

—with additional reporting by Jackie Kucinich