CREW and Democracy 21 respectfully request the Department of Justice & the Federal Bureau of Investigation investigate whether SCL Elections, Cambridge Analytica, Alexander Nix, Stephen Bannon, the John Bolton Super PAC, and the Trump campaign criminally violated federal law by directly or indirectly participating in the decision-making process of the John Bolton Super PAC and Donald J. Trump for President, Inc.

We further request that you investigate whether Stephen Bannon, the John Bolton Super PAC, and Donald J. Trump for President, Inc., conspired with or aided and abetted SCL Elections Ltd., Cambridge Analytica LLC, Alexander Nix, Stephen Bannon, and unknown other parties to violate 52 U.S.C. § 30121(a)(1) and 11 C.F.R. § 110.20(i).

The law prohibits foreign nationals from participating, directly or indirectly, in elections in the United States. That prohibition covers not only the making of financial contributions, but also any foreign national’s direct or indirect participation in the decision-making process of any person with respect to its federal or non-federal election-related activities. Nevertheless, SCL Elections Ltd., a
corporation based in the United Kingdom; Alexander Nix, a British national, through his work as manager at Cambridge Analytica, a company in which Stephen Bannon was a manager and director; and an unknown number of foreign nationals working with either corporation directly or indirectly participated in the decision-making process of John Bolton Super PAC, a registered political committee with the FEC, starting in as early as 2014, and appear to have played a similar role in the presidential campaign of Donald J. Trump.

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