“This is not based on a third party complaint,” Emadi said. “Our investigation is based on campaign contribution disclosure reports and personal finance disclosure reports that he filed with our commission.”

Warren would not speak to a reporter when approached at the Corn Boilin’. And he did not respond to emails or phone messages over the past two weeks. His campaign treasurer, Brett McClung, said he had personally reviewed Warren’s campaign filings and stood by them.

McClung blamed some of the missing information in the disclosure forms on software, but declined to answer specific questions about the money raised at the Corn Boilin’.

Incoming contributions listed as ‘petty cash’

Warren’s campaign filings from the past four years include thousands of dollars in campaign contributions labeled as coming from “petty cash,” with a P.O. Box that matches the campaign’s own mailing address.

McClung said that is how the campaign records checks it writes to itself for petty cash, insisting that all funds have been properly accounted for.

But Rick Thompson, former head of the state ethics commission, said the sheriff’s filings merit investigation.

Thompson was especially concerned about the “petty cash” contributions. He said if those cash infusions were indeed from Warren’s own campaign, the funds — and their sources — should have already been disclosed on previous reports.

“I’ve been doing this since 1994 and I can’t think of any reason why you would actually show petty cash coming in as income,” Thompson said.

Cobb County Sheriff Neil Warren presents a $10,000 check to the Cobb County Youth Museum during the annual Corn Boilin’ event at Jim Miller Park. The event is Warren’s largest political fundraiser, and generates $10,000 a year for the Cobb Youth Museum. But the sheriff’s financial disclosures do not reveal how much the Corn Boilin’ raises for the sheriff’s political campaign. Christina Matacotta/Christina.Matacotta@ajc.com

Other contributions that would likely draw investigators’ scrutiny include a $300 contribution in 2016, an election year, from “Cobb County Government.”

In addition to the unattributed petty cash donations, Warren’s campaign filings also contain some questionable expenditures.

The campaign gave a $300 “sponsorship” to a woman who shares a last name and address with Chief Deputy Sheriff Milton Beck for her to attend Georgia State University. Beck is second in command under Warren.

While contributing to an educational non-profit would be an acceptable expense, Thompson said, “if you’re helping your buddy’s daughter go to college, that may need some explaining as to why that’s an appropriate expenditure.”

Other payments the campaign made to or on behalf of Sheriff’s Office employees raise similar questions, he said.

“It shouldn’t specifically go to benefit somebody that’s in your organization,” Thompson said. “That’s just not the spirit of the law.”

Bryan Tyson, an attorney who specializes in campaign finance, offered a similar assessment.

“There really just isn’t enough detail to make a determination about the purpose of the expenditures,” Tyson said. “That’s something that needs to be addressed.”

Blurred lines between Sheriff’s campaign and office

Milton Beck is among several Sheriff’s Office employees who have been paid or reimbursed for work on their boss’ campaign, sometimes without a clear justification, according to a review of the disclosures.

Under state law, employees are allowed to engage in political activity outside of work. Cobb County policy prohibits anyone covered by the civil service commission from doing so, but many Sheriff’s Office employees, including Beck, are exempt from those rules.

However, county payroll records raise questions about whether Sheriff’s Office employees who worked on the campaign were given special treatment.

Last year’s Corn Boilin’ was held July 16. That same day, more than 70 sheriff’s office employees were allowed to take annual leave, despite chronic under-staffing in the department. Some of those employees also appeared at the event or in the campaign filings.

With a reported 1,200 attendees, and tickets selling for $25 each, the 2018 Corn Boilin’ should have raised well over $10,000. But Warren’s campaign only reported $7,990 from non-itemized small contributions during that period.

The disclosures give some insight into how much of the money from the event goes to the Youth Museum. Last year, as he did this year, Warren presented a giant novelty check for $10,000 to the Youth Museum. Warren told local media that he has raised more than $200,000 for the museum over the years.

Cobb County Sheriff Neil Warren greets Georgia Gov. Brian Kemp during the annual Corn Boilin’ at Jim Miller Park in Marietta. The event is Warren’s largest political fundraiser, and generates tens of thousands of dollars every year. The sheriff’s campaign is currently under investigation by the state ethics commission, and a review of his campaign finance reports found incomplete disclosure of contributors and spending. Christina Matacotta/Christina.Matacotta@ajc.com

Of that $10,000 in 2018, the Sheriff’s campaign kicked in $1,075. The year before, it gave $600.

Kristi Storey, the executive director of the museum, said the rest of the money comes from third-party donations that are solicited by Warren and referred all questions about it to the Sheriff's Office. She said sometimes the museum picks up the checks from the Sheriff's Office, and sometimes the money is delivered to the museum by someone in uniform.

“The Sheriff’s Office keeps track of who is donating what to the Youth Museum,” Storey said. She added that she doesn’t know or care how the money is processed, or by whom.

“They help us keep our doors open.”

Commander Robert Quigley, the Sheriff’s Office communications director, denied it was coordinating the museum sponsorships. Quigley has also worked on the sheriff’s campaign, including his attendance at a promotional photo shoot for the corn boil that ran in a local newspaper.

“I was on my lunch break,” he said.

Our reporting

The Atlanta Journal-Constitution reviewed four years of Cobb County Sheriff Neil Warren’s campaign finance disclosures, state campaign finance law, county policies and interviewed the executive director of the state ethics commission along with other experts in campaign finance. The AJC also repeatedly reached out to Warren, who refused to answer questions, and the sheriff’s campaign accountant.