By Matt Corley
January 29, 2016

An odd thing happened last November. The Florida-based branch of a yacht dealership with roots in Panama contributed $100,000 to a super PAC, but the super PAC didn’t use the money to run attack ads or to pay for get-out-the-vote work. Instead, it turned around the next day and gave the $100,000 to another super PAC that is currently working to elect Sen. Marco Rubio (R-FL) president.

The super PAC that facilitated the quick hand off, Conservatives for Effective Government, represents a new model of super PAC. Even though it’s what is formally known as an independent expenditure-only committee, the group doesn’t focus on independents expenditures supporting or opposing candidates. Rather, it serves as a pass through for big money, allowing donors to put an extra barrier between themselves and disclosure.

Take the $100,000 that ultimately ended up in the coffers of the pro-Rubio super PAC, Conservative Solutions PAC. A reporter looking at the group’s filings with the Federal Election Commission (FEC) would see that Conservatives for Effective Government was a major supporter, but wouldn’t know the true source of the money. An extra step would be required to discover that Evermarine LLC was actually helping foot the bill for Conservative Solutions PAC’s pro-Rubio work.

There are drawbacks to this approach though. The use of the super PAC as a pass through for Evermarine’s money, which was first flagged by ProPublica’s Derek Willis, makes the contribution look suspicious. Evermarine could have contributed directly to Conservative Solutions PAC, but didn’t. Why not? Did the company want to put distance between itself and the contributions that would be reported to the FEC by Sen. Rubio’s super PAC?

The company is run by Louis Sola, who previously put his financial support behind Sen. Rubio’s competitor, former Florida Gov. Jeb Bush, by giving $2,700 to Gov. Bush’s campaign in August. Maybe Mr. Sola didn’t want to take flak for switching his presidential support. If that was the case though, Mr. Sola and Evermarine would probably be otherwise quiet about their presidential leanings. But Evermarine’s Twitter account is filled with pro-Rubio retweets and the occasional pro-Rubio comment.

It is unclear what other motives the company may have for using a conduit to support the pro-Rubio group. Sen. Rubio is known to be a fan of boating and, in what may or may not be a coincidence, he participated in “a meet and greet” at the Fort Lauderdale International Boat Show just three days after Evermarine’s money was transferred to his supportive super PAC. His appearance at the show was arranged by Mr. Sola, who also introduced him.

Regardless of what the exact goal of the conduit contribution was, it is unlikely Conservatives for Effective Government made the contribution to Conservative Solutions PAC without Evermarine or Mr. Sola’s knowledge. The super PAC, which was formed in March 2015, has done nothing to date other than funnel contributions to other super PACs.

Its only other significant activity was contributing $113,000 to the Neighborhood Alliance PAC, which made independent expenditures in Memphis, TN’s mayoral race last year. Conservatives for Effective Government and the Neighborhood Alliance PAC share the same treasurer, Chris Marston, and use the same post office box in Alexandria, VA, which is also used by Mr. Marston’s consulting firm. Mr. Marston is a prolific Republican campaign compliance consultant who recently served as treasurer of the Koch network-tied political nonprofit Trees of Liberty, which was the subject of a recent IRS complaint filed by CREW and the Center for Media and Democracy.

Conservatives for Effective Government’s recent filing with the Federal Election Commission revealed that the $113,000 it gave to the Tennessee-focused PAC was originally provided by Tennessee donors, including $107,500 tied to a Memphis-based company called Tower Ventures Management LLC.

The timeline of money exchanges between the federal super PAC and the one registered in Tennessee suggests a concerted effort to obscure the source of the Neighborhood Alliance PAC’s funding. For instance, on September 9, William Ogrel, the president of Tower Ventures, contributed $50,000 to Conservatives for Effective Government. The same day, Conservatives for Effective Government gave the Neighborhood Alliance PAC $45,000, and that PAC then reported spending $45,000 on consulting, voter data, and phone calls to voters, still on that same day. Later, on September 28, Conservatives for Effective Government gave $18,000 to the Neighborhood Alliance PAC, which spent $17,825 that day on direct mail opposing incumbent Democratic Mayor A.C. Wharton in the Memphis mayor’s race.

The use of Conservatives for Effective Government as a pass through resulted in Memphis voters being kept in the dark about who was spending money to attack a candidate who eventually lost until well after the city’s October 8 Election Day. As the Memphis Commercial Appeal noted in early October, the Neighborhood Alliance PAC’s pre-election filing  with the Shelby County Election Commission didn’t “tell much about who is behind that group,” but did “show it’s well-financed.” Mr. Marston refused to talk to the Commercial Appeal about the secretive PAC. Over a month after the Memphis election, Mr. Marston registered the Neighborhood Alliance PAC as a super PAC on the federal level. It is unknown what he plans to do with it.

In short, it appears the purpose of Conservatives for Effective Government is to act as a roadblock to transparency, a form of temporary dead end disclosure. Before contributing to an independent expenditure committee, donors can give their money to the super PAC, which will pass it on in order for the original contributor to stay in the shadows for as long as possible.