CONTACT: Jordan Libowitz
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Washington—The FBI should investigate whether SCL Elections, Cambridge Analytica, Alexander Nix, Stephen Bannon, the John Bolton Super PAC, and the Trump campaign criminally violated federal law prohibiting foreign nationals from participating in American elections, according to a complaint filed today by Citizens for Responsibility and Ethics in Washington (CREW) and Democracy 21.

As recently reported by Britain’s Channel 4, numerous non-U.S. citizens appear to have participated in U.S. elections through work for SCL Elections Ltd., a corporation based in the United Kingdom, and Cambridge Analytica, its U.S. arm. Alexander Nix, a British national, directed much of this work in his role as a manager at Cambridge Analytica; Nix, in turn, was directed by Stephen Bannon, a co-founder of Cambridge Analytica. In particular, Nix and other SCL Elections Ltd. employees reportedly participated in strategic decision-making processes of John Bolton Super PAC, a U.S. political committee, starting as early as 2014, and according to Nix played a similar role in the presidential campaign of Donald Trump.

“The law prohibits foreign nationals from participating, directly or indirectly, in elections in the United States,” said CREW Executive Director Noah Bookbinder. “What’s worse than the fact that it apparently happened in this case is that the people involved apparently knew they were breaking the law and continued to do so anyway.”

In 2014, two weeks after the John Bolton Super PAC made its initial payment to Cambridge Analytica, a lawyer with Bracewell & Giuliani sent a memo to Bannon and Nix, advising them on the steps that they would have to take to comply with the prohibition on foreign national participation in United States elections related to activities with the Bolton Super PAC. SCL, Cambridge Analytica, Bannon, and Nix ignored the legal advice. In 2016, Bannon left Cambridge Analytica for the Trump campaign, which then hired Cambridge Analytica despite Bannon’s knowledge that the company apparently failed to follow U.S. law prohibiting foreign nationals from participating substantially in U.S. campaigns.

“These are very serious apparent violations of federal law,” Bookbinder said. “The Justice Department and the FBI should immediately commence an investigation into this matter and take appropriate action.”

Common Cause previously filed complaints asking the Federal Election Commission and Department of Justice to examine whether Cambridge Analytica and related parties violated election law by having foreign persons perform work related to a United States election; this complaint asks the Department of Justice to examine whether criminal laws were violated and includes the American organizations that were the recipients of the work.