Memo

For: ​All interested parties
By:​ Scott Dworkin, Senior Advisor
RE:​ Steve Bannon reported to FBI for breaking federal campaign finance law
Date:​ November 15, 2016
Executive Summary
On Tuesday morning, the Democratic Coalition Against Trump reported Trump Senior Advisor and Former
Trump campaign CEO Steve Bannon to the FBI for breaking campaign finance law. Over the course of the Trump
campaign, Bannon was paid $950,090 by pro-Trump Super PAC, Make America Number 1, through his company
Glittering Steel LLC, both before and after Bannon assumed his role as campaign CEO.
According to federal campaign finance law, it is illegal for Super PACs to coordinate operations with campaigns.
Additionally, there is a 120-day “cooling off” period for when Super PAC employees leave to work on the campaign
their PAC was supporting to avoid any potential coordination. Steve Bannon was paid by Make America Number 1
on August 8, 2016, and then became Trump campaign CEO on August 17, 2016, directly violating the 120-day
cooling off period. Additionally, Bannon was paid by the PAC after he became campaign CEO, which likely means
there was coordination.
The FBI Public Corruption unit has jurisdiction to investigate election crimes, which include campaign finance
violations.

Please reach out to us with any questions or concerns by contacting Francesca Lucia, (914) 618-0446,
francesca@keepamericagreat.us​.
Democratic Coalition Against Trump | Keep America Great PAC
PO Box 36-20197
New York, NY 10129
www.keepamericagreat.us

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