MUR #7636
WE BUILD THE WALLSummary
RESPONDENTS: We Build the Wall, Inc.; Curtis, Elizabeth; Kobach for Senate; Kobach, Kris
COMPLAINANTS: Campaign Legal Center; Christ, Margaret; Noti, Adav
SUBJECT: Committees-Candidate; Contributions
DISPOSITION: The Commission decided by a vote of 4-2 to take the following actions in MURs 7628, 7636, and 7992:1. Accept the conciliation agreement, as recommended in the Memorandum to the Commission dated November 8, 2022.2. Approve the appropriate letters3. Close the files.
The Commission decided by a vote of 4-2 to take the following actions in MURs 7628, 7636, and 7992:1. Approve the Factual and Legal Analyses, as recommended in the Memorandum to the Commission dated May 4, 2022 and subject to the edits circulated by Commissioner Weintraub’s Office on May 25, 2022 at 12:50 p.m.2. Approve the conciliation agreements, as recommended in the Memorandum to the Commission dated May 4, 2022.
The Commission decided by a vote of 4-2 to take the following actions in MURs 7628, 7636, and Pre-MUR 628:1. Open a Matter Under Review in Pre-MUR 628.2. Find reason to believe that WeBuildTheWall, Inc., violated 52 U.S.C. § 30118 by making a corporate contribution by renting an email list below market value to Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer.3. Find reason to believe that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30118 by knowingly accepting a corporate contribution by renting an email list below market value from WeBuildTheWall, Inc.4. Find reason to believe that Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30104(b) by failing to report the in-kind contribution from WeBuildThe Wall, Inc.5. Instruct the Office of General Counsel to accordingly modify the draft Factual and Legal Analyses, as circulated by Chairman Dickerson’s Office on March 24, 2022 at 11:30 a.m., and recirculate for Commission approval.6. Instruct the Office of General Counsel, upon approval of an appropriate conciliation agreement, to enter into pre-probable cause conciliation with Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity and WeBuildTheWall, Inc. reflecting an opening offer of the statutory penalties.7. Instruct the Office of General Counsel to prepare an appropriate conciliation agreement for Commission approval.8. Approve the appropriate letters.
The Commission failed by a vote of 3-3 to:a. Dismiss the allegation that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30120(a)(1) and 11 C.F.R. § 110.11(a) by failing to include a required disclaimer.b. Open a Matter Under Review in Pre-MUR 628.c. Find reason to believe that WeBuildTheWall, Inc., violated 52 U.S.C. § 30118 by making a corporate contribution by renting the email list below market value to Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer.d. Find reason to believe that WeBuildTheWall, Inc., violated 52 U.S.C. § 30118 by making a corporate contribution by permitting usage of its corporate logo to Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer.e. Find reason to believe that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30118 by knowingly accepting a corporate contribution by renting the email list below market value from WeBuildTheWall Inc.f. Find reason to believe that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30118 by knowingly accepting a corporate contribution by using WeBuildTheWall’s corporate logo.g. Find reason to believe that Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30104(b) by failing to report the in-kind contributions from WeBuildTheWall Inc.h. Dismiss the allegation that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30125(e)(1)(A) by receiving prohibited non-federal funds from WeBuildTheWall, Inc.i. Enter into conciliation with Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity and WeBuildTheWall, Inc., prior to a finding of probable cause to believe.j. Approve the Conciliation Agreements, as recommended in the First General Counsel’s Report dated August 4, 2021.k. Approve the Factual and Legal Analyses, as recommended in the First General Counsel’s Report dated August 4, 2021, and subject to the edits circulated by Commissioner Weintraub’s Office on March 23, 2022, at 8:58 p.m.l. Approve the appropriate letters.
The Commission failed by a vote of 2-4 to:a. Dismiss the allegation that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30120(a)(1) and 11 C.F.R. § 110.11(a) by failing to include a required disclaimer.b. Dismiss the allegation that WeBuildTheWall, Inc., violated 52 U.S.C. § 30118 by making a corporate contribution by renting the email list below market value to Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer.c. Dismiss the allegation that WeBuildTheWall, Inc., violated 52 U.S.C. § 30118 by making a corporate contribution by permitting usage of its corporate logo to Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer.d. Dismiss the allegation that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30118 by knowingly accepting a corporate contribution by renting the email list below market value from WeBuildTheWall Inc.e. Dismiss the allegation that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30118 by knowingly accepting a corporate contribution by using WeBuildTheWall’s corporate logo.f. Dismiss the allegation that Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30104(b) by failing to report an in-kind contribution from WeBuildTheWall Inc.g. Dismiss the allegation that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30125(e)(1)(A) by receiving prohibited non-federal funds from WeBuildTheWall, Inc.h. Approve the appropriate Factual and Legal Analysis, as recommended in the First General Counsel’s Report dated August 4, 2021.i. Send appropriate letters.j. Close the file.
The Commission decided by a vote of 6-0 to:a. Dismiss the allegation that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30120(a)(1) and 11 C.F.R. § 110.11(a) by failing to include the required disclaimer.b. Dismiss the allegation that Kris Kobach and Kris Kobach for Senate and Elizabeth Curtis in her official capacity as treasurer violated 52 U.S.C. § 30125(e)(1)(A) by receiving prohibited non-federal funds from WeBuildTheWall Inc.
Disposition
Disposition | Penalty | Respondent | Citation |
---|---|---|---|
Conciliation-PPC | Kobach, Kris | 52 U.S.C. §30118 | |
Kobach for Senate |
52
U.S.C.
§30104(b)
52 U.S.C. §30118 |
||
We Build the Wall, Inc. | 52 U.S.C. §30118 | ||
Curtis, Elizabeth |
52
U.S.C.
§30104(b)
52 U.S.C. §30118 |
Documents
Participants
Relationship | Name |
---|---|
Primary respondent | We Build the Wall, Inc. |
Previous respondent | Curtis, Elizabeth |
Kobach for Senate | |
Kobach, Kris | |
Complainant | Campaign Legal Center |
Christ, Margaret | |
Noti, Adav |