Patterns to check | Docs | Dark Money Map

Some of the money in California politics is given so that the public record shows a name other than the one that paid. The techniques are few and well known: they show up again and again in enforcement cases brought by the Fair Political Practices Commission and in reporting on undisclosed money. Each leaves a shape in the filings the map is built from. The map looks for those shapes and, where it finds one, adds a Patterns to check section to the record with the evidence and a link here.

Leads, not findings

A pattern is a reason to look, not a conclusion. Every shape below also has ordinary, lawful explanations, listed with it. The map never says a rule was broken; it says what the records show and what would be worth checking next, usually in the committee's own filings on CAL-ACCESS and in the FPPC's enforcement records.

How the patterns are found

The patterns are worked out after the map's data is built (tools/build_money_signals.py), from two files: the campaign layer, with every committee's reported receipts, itemized givers and late contributions, and the donor index, with every itemized giver of $2,500 or more per committee. Each pattern is a fixed rule with fixed thresholds, given below, so the same records always give the same result. The rules read only what is filed; they use no outside data about any person or organization.

Money that never has to be disclosed leaves no shape at all. Donors to a nonprofit that stays under the multipurpose-organization thresholds, an LLC's members, and the funders of issue advertising that names no candidate are not in these records, and no pattern can find them. See Known limitations.

The patterns

Split giving

The technique. A giver breaks a large sum into many smaller contributions, to one committee or across several, so that no single piece reaches the amounts that draw attention or trigger a report.

What the map looks for. A giver whose contributions to one committee number four or more, average under $5,000 and total $10,000 or more; or an individual giving under $5,000 to each of five or more committees, $25,000 or more in all.

Ordinary explanations. Monthly giving, matching an employer's or union's payroll deductions, and support for many candidates of one party all look the same. Aggregate limits, not counts, are what the law sets.

Same-employer cluster

The technique. Employees or family members each give the same amount on the same days and are paid back by the real giver, which hides who gave and evades the per-person limit (Gov. Code 84301, contributions in the name of another).

What the map looks for. Three or more individual givers to one committee who share an employer, gave the same amount, and gave within two weeks of one another, $7,500 or more together.

Ordinary explanations. A firm's partners giving at a fundraiser, or an executive team giving the maximum at once, is legal and common. The FPPC pursues reimbursement only with evidence of repayment.

Conduit committee

The technique. A committee takes nearly all its money from one source and passes most of it on, so the campaign that finally spends it reports the committee, not the source, as its giver.

What the map looks for. A committee with $100,000 or more in receipts, four fifths or more of its itemized receipts from one giver, and half or more of its receipts given onward on these records.

Ordinary explanations. A party committee or a sponsored PAC is built to pool and pass on money, and says so in its name and its sponsor filing.

Single source

The technique. A committee formed and funded by one interest, often under a broad public-sounding name, so the campaign reads as a coalition.

What the map looks for. A committee with $100,000 or more in receipts, nine tenths or more of its itemized receipts from one giver.

Ordinary explanations. A candidate's own committee funded by the candidate, or a ballot measure committee openly sponsored by one company or union, is disclosed as such on its statement of organization.

Giver with no disclosed source

The technique. Money given by a nonprofit or an entity that reports nothing about where its own money came from: the classic dark money route, because donors to a 501(c)(4) or (c)(6) are not public.

What the map looks for. A giver of $100,000 or more in all whose name reads like an advocacy nonprofit or fund and for which no campaign statement of money received exists on this map.

Ordinary explanations. A nonprofit that spends over $50,000 in a year on California campaigns must register as a committee and name donors of $100 or more who gave for political purposes (multipurpose organization rules); check CAL-ACCESS for that filing. A major donor (Form 461) is required to report only what it gives. A hospital system, company or union gives from its own revenue, which is not campaign money; a federal committee's donors are in its FEC filings, not in California's.

LLC or partnership giver

The technique. An LLC formed to give, so the people behind the money appear only as a company name; California requires the recipient to name one responsible officer, not the members.

What the map looks for. A giver of $25,000 or more in all whose name is an LLC or partnership.

Ordinary explanations. Operating businesses give as LLCs every day. The Secretary of State's business filings name the officers and agent; a new LLC with no other footprint is what to look for.

Mostly unitemized receipts

The technique. Money reported only as a total, so no giver can be seen, whether through many small gifts or through the other receipt categories a statement allows.

What the map looks for. A committee with $100,000 or more in receipts of which half or more is not itemized by giver.

Ordinary explanations. Small-dollar grassroots fundraising, and a union's or membership organization's dues, are reported this way by law: contributions under $100 are never itemized.

Money both ways

The technique. Two committees give to each other, which can move money between accounts, refresh a limit, or make each look funded by the other.

What the map looks for. Money reported from A to B and from B to A on these records.

Ordinary explanations. Refunds, corrected transfers, and party committees exchanging earmarked money.

Long chain

The technique. Money passed through three or more committees before it reaches a campaign, each step putting another name between the source and the spending.

What the map looks for. A candidate, measure or committee reached by a chain of money through three or more committees on these records, every step $10,000 or more, following each record's six largest committee givers.

Ordinary explanations. Party and caucus committees routinely pool contributions and pass them to campaigns.

Late money into a committee with no statement

The technique. A committee formed close to an election, funded by one giver in late reports, spends before any full statement is due, so the source is visible only in scattered late filings.

What the map looks for. A committee with no Form 460 statement this year, $100,000 or more in late contributions listed, four fifths or more of it from one giver.

Ordinary explanations. A committee formed after the last statement date reports the same way until its first statement.

What to check next

The committee's own filings. Every record links to CAL-ACCESS. A committee's statement of organization (Form 410) names its sponsor and its treasurer, and its statements list every giver and every payment.
The FPPC. Enforcement decisions, which name the committees and the rule involved, are published at fppc.ca.gov, and a pattern that matches a past case is the strongest kind of lead.
The Secretary of State's business filings. For an LLC or a corporation, the statement of information names the officers and the agent for service, which is how one hand behind several companies is found.
The dates. Money given in the days around a vote, a hearing or a filing deadline is worth reading against the bill's history, which every bill record carries.