Office of General Counsel
Federal Election Commission
999 E Street, NW
Washington, DC 20463
 

Dear Counsel:

We write to file a complaint against the Hillary Clinton for President Committee for violation of Federal Election Law under the Commission's jurisdiction.

It is clear from recent news accounts that the campaign and its donors and fundraisers have violated 2 USC 441f, the provision of law that prohibits campaign contributions in the name of another, and that some donors may have violated 2 USC 441e which prohibits donations by foreign nationals without permanent resident status.   

A recent Los Angeles Times article, [available here], indicates that several reported donors to the Clinton campaign are non-existent persons, illegal immigrants, or were reimbursed by others for contributions. The article documents several instances in which reported donors could not be found, even by those living at the same address reported in the campaign’s FEC filing:

The Times examined the cases of more than 150 donors who provided checks to Clinton after fundraising events geared to the Chinese community. One-third of those donors could not be found using property, telephone or business records. Most have not registered to vote, according to public records. […]

Of 74 residents of New York's Chinatown, Flushing, the Bronx or Brooklyn that The Times called or visited, only 24 could be reached for comment.

[…]

The tenement at 44 Henry St. was listed in Clinton's campaign reports as the home of Shu Fang Li, who reportedly gave $1,000. […]

A tenant living in the apartment listed as Li's address said through a translator that she had not heard of him, although she had lived there for the last 10 years.

Census figures for 2000 show the median family income for the area was less than $21,000. About 45% of the population was living below the poverty line, more than double the city average.

In the busy heart of East Broadway, beneath the Manhattan Bridge, is a building that is listed as the home of Sang Cheung Lee, also reported to have given $1,000. Trash was piled in the dimly lighted entrance hall. Neighbors said they knew of no one with Lee's name there; they knocked on one another's doors in a futile effort to find him.

Salespeople at a store on Canal Street were similarly baffled when asked about Shih Kan Chang, listed as working there and having given $1,000. The store sells purses, jewelry and novelty Buddha statues. Employees said they had not heard of Chang.

Another listed donor, Yi Min Liu, said he did not make the $1,000 contribution in April that was reported in his name. He said he attended a banquet for Clinton but did not give her money.

One New York man who said he enthusiastically donated $2,500 to Clinton doesn't appear to be eligible to do so under federal election law. He said he came to the United States from China about two years ago and didn't have a green card.

As Clinton campaign bundlers, these community leaders also placed improper pressure on those who could least afford to donate:

Clinton has enlisted the aid of Chinese neighborhood associations, especially those representing recent immigrants from Fujian province. The organizations, at least one of which is a descendant of Chinatown criminal enterprises that engaged in gambling and human trafficking, exert enormous influence over immigrants. The associations help them with everything from protection against crime to obtaining green cards.

Many of Clinton's Chinatown donors said they had contributed because leaders in neighborhood associations told them to. In some cases, donors said they felt pressure to give.

[…]

"Everybody was making a donation, so I did too," [He Duan Zheng] said. "Otherwise I would lose face."

The New York Post story indicates that several unlikely donors, including cooks and dishwashers, made $1,000 contributions to the campaign.

A search of Chinatown donors yesterday by The Post found several bogus addresses and some contributions that raised eyebrows.

Shin K. Cheng is listed twice in federal records for giving $1,000 donations to Clinton's campaign on April 17.

But the address recorded on campaign reports is a clinic for sexually transmitted diseases, hemorrhoids and skin disease.

No one at the address knew of a Shin K. Cheng.

Another donation came from a Shih Kan Chang on Canal Street. But the address listed is a shop that sells knock-off watches and other pirated goods. The sales clerk there did not know the donor.

Hsiao Yen Wang, a cook in Chinatown, is listed as giving Clinton $1,000 on April 13. Contacted yesterday, she told The Post she had written a check.

But it was on behalf of a man named David Guo, president of the Fujian American Cuisine Council, and Wang told The Post that Guo had repaid her for the $1,000 contribution.

Accordingly, the Clinton campaign's disinterest in and failure to remedy these violations along with the potential scope of the abuse indicates that that the Commission should investigate and take action against those responsible for violation of the law.

The information in this complaint is based upon information and belief, and not on our personal knowledge.

Respectfully,