But that huge pile of money also emerges as a potential vulnerability. His chief fundraising vehicle, Save America PAC, is under new legal scrutiny after the Justice Department issued a round of grand jury subpoenas seeking information about the political action committee’s fundraising practices. The scope of the investigation is unclear. The grand jury subpoenas and search warrants issued by the Justice Department in recent days were related to several subjects, including Trump’s PAC, according to people familiar with the matter who spoke on condition of anonymity to discuss an ongoing investigation. The subpoenas seek records as well as testimony and ask at least some of the recipients about their knowledge of their efforts to engage in voter fraud, according to one of the people. The subpoenas also seek records of communications with attorneys allied to Trump who supported efforts to overturn the election results and planned to field fraudulent voters in battleground states. A particular area of focus appears to be on the “America Rollup” that preceded the Jan. 6, 2021, uprising at the U.S. Capitol, the person said. The probe is one of several criminal probes Trump is currently facing, including an audit of how classified documents ended up at the former president’s Mar-a-Lago club. Regardless of Save America’s ultimate role in the investigations, the flurry of developments has drawn attention to the PAC’s management, how it has raised money and where those funds have been directed. Trump spokesman Taylor Budowitz criticized the calls, saying a “weaponized and politicized Justice Department” was “casting a blind net to intimidate and silence Republicans fighting for his ‘America First’ agenda.” Justice Department spokesmen declined to comment. While Trump has more than $115 million in various committees, the vast majority of it is stored in Save America. The PAC closed July with more than $99 million in cash, according to fundraising records — more than the Republican and Democratic national campaign committees combined. Trump continued to raise small-dollar donations in the coming months, frustrating other Republicans struggling to raise money ahead of November’s midterm elections. Save America is set up as a “leadership PAC” designed to allow political figures to raise money for other campaigns. But the groups are often used by would-be candidates to fund political travel, polls and staff as they “test the waters” before potential presidential runs. The accounts can also be used to contribute money to other candidates and party organizations, helping would-be candidates build political capital. Much of the money Trump has raised was raised in the days and weeks after the 2020 election. That’s when Trump supporters were bombarded with a constant stream of emails and messages, many with capital letters and blatant lies about his stolen election. 2020, asking for cash for an “election defense fund.” But such a fund never existed. Instead, Trump has put the money to other uses. He has funded dozens of rallies, paid staff and used the money to travel as he teases an expected 2024 presidential campaign. Other expenses were more unusual. There was the $1 million donated last year to the Conservative Partnership Institute, a nonprofit that employs Cleta Mitchell and former Trump chief of staff Mark Meadows, both of whom fueled Trump’s failed bid to overturn his election. 2020. There was the “philanthropic contribution” of $650,000 in July to the Smithsonian Institution to fund portraits of Trump and the former first lady that will one day hang in the National Portrait Gallery, according to Smithsonian spokeswoman Linda St. Thomas. Much of the money has also funded a different kind of defense fund — one that has paid the legal fees of Trump confidants and aides who have been subpoenaed to testify before the Jan. 6 committee. In all, Trump’s sprawling political enterprise has spent at least $8 million on “legal advice” and “legal fees” to at least 40 law firms since the uprising, according to an analysis of campaign finance disclosures. It’s unclear how much of that money went to legal fees for staff after a congressional committee began investigating the origins of the attack. But at least $1.1 million has been paid to Elections LLC, a company started by Trump’s former White House ethics lawyer, Stefan Pasadino, according to campaign finance and business records. An additional million dollars was paid into a legal trust housed at the same address as Passantino’s company. Pasadena did not respond to a request for comment Monday night. Payments have also been made to companies specializing in environmental regulation and real estate matters. As of July, only about $750,000 had been allocated to congressional candidates, with an additional $150,000 to candidates for state office, the records show. Trump is expected to increase his political spending now that the general election season is in full swing, although it remains unclear exactly how much the notorious former president will ultimately agree to spend. Trump has long played down his 2024 plans, saying an official announcement would trigger campaign finance rules that would, in part, force him to create a new campaign committee bound by strict fundraising limits. Meanwhile, Trump aides are discussing the prospect of creating a new super PAC or repurposing an existing one as he nears an expected announcement. Although Trump could not use Save America to finance the campaign after the campaign began, his aides have discussed the possibility of moving at least some of that money to a super PAC, according to people familiar with the talks. Campaign finance experts dispute the legality of such a move. Some, like Richard Briffault, a Columbia Law School professor and campaign finance expert, said he didn’t see a problem. “There may be some hoops to jump through,” he said. But “I don’t see a problem with him going from one PAC to another … I don’t see what would stop it.” Others disagree. “It is illegal for a candidate to transfer a significant amount of money from a leadership PAC to a super PAC. You certainly can’t do $100 million,” said Adav Noti, a former Federal Election Commission lawyer who now works for the Campaign Legal Center, a Washington-based good government group that focuses on money and politics. And whether or not Trump would face any consequences is a different matter. For years, the FEC, which oversees campaign finance laws, has been deadlocked. The committee is evenly split between Republicans and Democrats, and a majority is needed to take enforcement action against a nominee. Indeed, legal experts say Trump has repeatedly violated campaign finance law since he began his bid for the White House in 2016, without consequence. More than 50 separate complaints alleging Trump violated campaign finance laws have been filed against him since his 2016 campaign. In about half of those cases, FEC lawyers concluded there was cause to it is believed that he may have broken the law. But the panel, which now includes three Republicans appointed by Trump, has repeatedly deadlocked. The list of dismissed complaints against Trump is extensive. In 2021, Republicans on the committee rejected the claim, backed by FEC staff lawyers, that Trump orchestrated the payment of hush money by his former lawyer to porn star Stormy Daniels as amounting to an unreported in-kind contribution. In May, the Commission deadlocked over whether his campaign broke the law by hiding how it spent cash during the 2020 campaign. And over the summer, the commission dismissed complaints stemming from Trump’s threat to withhold $391 million in aid to Ukraine unless Ukrainian officials opened an investigation into the relationship that President Joe Biden’s son, Hunter Biden, had. with a Ukrainian natural gas company called Burisma, which the FEC attorney found to be a possible violation of campaign finance laws. “There is no legal basis to believe that Congress intended the FEC to police official acts of government that may be intended to help re-elect an official,” the committee’s three Republicans said in a written statement late last month. That means any enforcement action would likely have to come from the Department of Justice. “He has nothing to fear from the Federal Election Commission until it changes its structure or there is turnover among the FEC commissioners,” said Brett G. Kappel, a longtime campaign finance lawyer who works at the Harmon Curran firm based in Washington and has represented both Republicans and Democrats. “That’s not to say he has nothing to fear from the Justice Department, which is already apparently investigating Save America. From what I can see, there are multiple allegations of wire fraud that could be the subject of a Department of Justice investigation.” Meanwhile, Trump and Save America continue to collect contributions from grassroots supporters, blasting fundraising appeals with aggressive demands like “this needs to be taken care of NOW” and threatening donors that their “Voter Verification” canvassing surveys are “OUT OF DATE,” even as some of the Republican Senate candidates Trump endorsed and helped cross the finish line in the primaries are struggling to raise cash. Senate Minority Leader Mitch…
