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Ethics Watchdog Group Files Complaint Against Rep. Gwen Moore for Operating 'Scam PAC'

Scott Olson/Pool via AP

On Tuesday, Kendra Arnold of the Foundation for Accountability and Civic Trust (FACT), a nonpartisan watchdog ethics group, announced her group is filing a complaint against Rep. Gwen Moore (D-WI). FACT is thus asking the Federal Election Commission (FEC) to investigate the matter. As a press release shared with Townhall detailed, "Moore appears to have violated the Federal Election Campaign Act (FECA) by abusing her leadership PAC to the point that its activities demonstrate it to be a 'scam PAC.'"


Moore established the Giving Willingly Empowering Nationally (GWEN) PAC, which, as the complaint shared with Townhall points out, "must primarily be supporting candidates for office or causes" in order to be compliant with the law. The complaint makes reference to several sections of 52 U.S.C. as well as 11 C.F.R.

For the 2024 election cycle, at least 79 percent of GWEN PAC’s spending has gone towards operating expenditures, while 95 percent of expenditures have gone towards other purposes beyond contributions to political committees or organizations, which is supposed to be the PAC's purpose. "This is consistent with the operation of a scam PAC," the claim points out.

As the complaint also further lays out [Emphasis original]:

Federal candidates and office holders are not permitted to operate a scam PAC. Federal law sets forth a regulatory scheme under which federal candidates are only allowed to raise and spend funds as specifically identified in the Act. Essentially, if the Act does not specifically allow it, then they cannot do it. It is important to note that the law applies to any type of funds raised by a candidate or office holder.

In addition to their authorized campaign committee, federal law permits a Member of  Congress to spend funds from only one other source—a “leadership PAC” to “support other candidates for federal and nonfederal office.” Although a “scam PAC” can be registered as any type of PAC, including a “leadership PAC,” this is a guise because the scam PAC does not actually function as a leadership PAC and, in fact, is not a leadership PAC. Rather, it fundraises under the pretext that contributions will be used to support candidates or causes, but instead the funds raised are primarily spent on operating expenses. This is not a type of PAC a federal candidate or office holder is permitted to have under the Act.  


The complaint also lays out the specific figures to come to the 79 percent and 95 percent numbers. 

GWEN PAC reported that $223,002.99 was on operating expenditures, which brings us to the 79 percent figure, while $58,899.91 was on "contributions to federal candidates/committees and other political committees." However, $31,000 of the $58,899.91 was spent on fundraising consultants, including the congresswoman's own sister.

For the 2024 cycle, the PAC has made $14,500 in contributions to PACs or organizations. "This means that 94.8% of GWEN PAC’s spending went toward things other than the law’s required purpose of supporting candidates or causes," the complaint highlights.

Using data from the last two quarters of 2023 and the first quarter of 2024, the PAC raised $147,788.92 and spent over $153,762, though only $4,500 was made in political contributions. The rest of the money was spent elsewhere.

As a tally of expenses included:

  • Consulting services: $53,150.00
  • Office Supplies: $11,727.13
  • Catering: $9,279.00
  • Restaurants: $6,767.09
  • Hotels: $8,033.37
  • Food Delivery, Alcohol, Groceries: $3,940.09
  • Airlines: $8,934.26
  • Events/Gift Supplies: $3,318.01
  • Rideshare Expenses: $1,826.62

Political contributions were thus one of the expenses that the PAC put the least amount of money towards. Moore represents Wisconsin's 4th Congressional District, and yet food and travel expenses went towards the Lodge at Sonoma resort in California.


"GWEN PAC’s spending is clearly antithetical to that of a leadership PAC," the complaint expresses concern with, linking to a 2014 article from the Wall Street Journal, "Meet Capitol Hill’s Top Uber User: Rep. Gwen Moore."

"Consequently, GWEN PAC is not a leadership PAC but a scam PAC, and federal law does not authorize candidates or office holders to operate scam PACs," the complaint similarly reads towards the end, again reiterating the 79 95 percent figures. 

Arnold also provided a statement included in the press release. "The law only allows House Members to operate two kinds of organizations—and a scam PAC is not one of them. There should be no question that when 95% of a PAC's spending is not on its legally required purpose, it qualifies as a scam PAC. The bottom line is that this case is so extreme that anyone donating to GWEN PAC is either (1) being completely bamboozled by Rep. Moore or (2) is doing so knowingly in an attempt to influence the Member. I hope the FEC takes swift action in this case," she said. 

In concluding her complaint, Arnold asks that "Ultimately, if one or more campaign laws are found to have been broken, we request the FEC hold the respondents accountable."

As Spencer covered last December, Moore was considered by FACT to be one of the top ethics violators of the year. In late 2023 the piece mentioned that "...since its inception only a mere 22% of GWEN PAC's overall spending has gone towards political candidates and political committees..." 


Moore was first elected in 2004 and represents a heavily Democratic district, with Wisconsin's 4th Congressional District being considered "Safe" or "Solid Democratic" district. 


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