On Wednesday morning, The Daily Beast published a report detailing how Donald Trump’s presidential campaign and four associated PACs have been using a GOP compliance firm to pay legal fees, obscuring who is the ultimate recipient of millions of dollars in legal payments.
By Wednesday night, the Trump campaign and the four PACs were facing a new ethics complaint over the arrangement.
The complaint, which nonprofit watchdog Campaign Legal Center filed with the Federal Election Commission Wednesday afternoon, argues that Trump and his associated PACs aren’t just violating federal reporting rules; they’re also violating the ban on corporate contributions.
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The arrangement—in which the five Trump committees have reimbursed GOP compliance firm Red Curve Solutions for millions of dollars in advanced legal costs—makes Red Curve the single largest recipient of Trump’s legal payments over the last year, and suggests that the company has been unlawfully fronting those costs for Trump’s political committees, the complaint argues.
The problem, of course, is that Red Curve is a political accounting firm with no history of providing legal services, raising questions about who Trump is really paying for this legal work, who they represent, and how much they’re actually being paid.
CLC is asking the FEC to investigate the payments immediately, citing the fact that the arrangement is ongoing.
In a statement to The Daily Beast, CLC director of federal reform Saurav Ghosh called the arrangement “unprecedented” in size, arguing that the scheme deprives the public of its right to know exactly who Trump’s political groups are paying with donor funds—an especially urgent matter given the salience of Trump’s legal spending this election.
“Available information points to the conclusion that Trump’s 2024 presidential campaign and other Trump-affiliated committees violated federal law by obscuring who they paid for legal services and how much they paid for those services,” Ghosh said in the statement. “Voters have a right to know exactly how these Trump-affiliated committees are spending their money, particularly since it is unprecedented to see political candidates or committees spending such massive amounts of money on legal expenses."
Citing The Daily Beast’s reporting, the complaint lays out the reimbursement arrangement, in which five Trump-affiliated committees have steered legal payments to Red Curve since December 2022. All five of the committees also pay Red Curve for compliance services, the complaint notes, and all of them list the same Red Curve official as their treasurer: Bradley Crate, who also serves as treasurer for more than 200 other federal committees.
According to the complaint, FEC filings show that Red Curve “routinely advanced money or paid for the cost of legal services provided by other vendors, for which Red Curve was reimbursed.”
The fact that the committees and the company—which specializes in campaign finance reporting services—did not properly itemize these reimbursements “undermines the bedrock transparency” of public disclosure laws, the complaint says.
Additionally, Red Curve is a corporate entity, which means it’s prohibited from making in-kind contributions to campaigns and the types of PACs involved in this arrangement. As legal experts previously told The Daily Beast, this extends to advance payments that are later reimbursed.
“Both the substantial sums at issue and the duration of the reimbursement scheme support the conclusion that each of the Trump-affiliated Committees knew that it was paying Red Curve for legal services that were, in fact, being provided by another vendor whose name would thereby be hidden from public view,” the complaint claims.
The document also provides detailed comparisons with multiple examples of similar payment and reporting arrangements that the FEC previously ruled were in violation of federal law.
The complaint notes that the available public information does not clarify what, or who, these payments were for—Trump’s personal legal bills, costs for other people involved with Trump or these PACs, other witnesses or co-defendants, or, potentially, “whether they included payments for expenses unrelated to legal services.”
However, The Daily Beast reported that the filings reveal what appears to be a cost-sharing arrangement.
Pairs of Trump PACs frequently reimburse Red Curve in the same amounts, with payments in close proximity to each other. Many of the payments are identical twins—exact dollar figures, down to the penny—but there are also a number that are more like fraternal twins, where the payments are nearly the same, with payment dates slightly more staggered.
The complaint notes that public disclosure rules are designed in part to help regulate potential improper coordination between candidates, campaigns, and outside spending groups—including super PACs and “dark money” nonprofits—which is sometimes achieved through common vendors and former employees.
Red Curve runs the books not just for these five Trump committees, but also for a flotilla of Trump-aligned super PACs and nonprofits. The Red Curve payment arrangement began in December 2022, weeks after Trump officially declared his candidacy for re-election.
The complaint’s allegations will now fall to investigators in the FEC’s Office of General Counsel.
The agency’s Republican commissioners have blocked action in every one of the dozens of previous campaign finance cases against Trump.
