Consultant Overlap ● 3 verifiable · ● 1 partial · 4 steps

Fairshake → senators → crypto deregulation

The same political operatives run the crypto industry's $193M super PAC AND the AI industry's $100M+ political machine. The senators those PACs backed are now writing the bills that deregulate both.

Fairshake — the crypto industry's super PAC umbrella — raised and spent ~$193M in the 2024 cycle, making it one of the largest non-party independent expenditure operations in U.S. history. Its senior consultants overlap with senior consultants for AI-industry political spending vehicles, and the PAC's biggest beneficiaries (mostly Senate Banking Committee members) subsequently pushed major crypto-deregulation legislation through that committee in 2024-2025. The independence required by post-Citizens United doctrine is fact-bound: it depends on whether the same operatives moved messaging, strategy, or media spend across the legal firewall. The records show the consultancy overlap; what they cannot show, without subpoenaed internal communications, is whether substantial discussion occurred.

// Walk the loop, step by step

Verifiable $193M

Fairshake raised ~$193M in the 2024 cycle; largest non-party super PAC of the cycle by some measures.

EvidenceFEC filings for Fairshake and its affiliated entities (Defend American Jobs, Protect Progress) show combined cycle spend of ~$193M. Major donors include Coinbase, a16z, Ripple, Andreessen Horowitz, Brian Armstrong, Fred Ehrsam.

www.fec.gov/data/committee/?committee_id=C00835959 ↗www.opensecrets.org/political-action-committees-pacs/su… ↗

Verifiable

Same consultants run independent-expenditure entities and Senate campaigns simultaneously.

EvidenceFEC disbursements show the same consulting firms (and named operatives — Zac Moffatt's Targeted Victory; Josh Vlasto / SKDK alumni networks) appearing on both Fairshake's and individual Senate campaigns' payment ledgers within the prior-120-day common-vendor window that 11 C.F.R. § 109.21(d) treats as a coordination indicator.

www.fec.gov/data/disbursements/?committee_id=C00835959 ↗www.opensecrets.org/political-action-committees-pacs/ta… ↗

Verifiable

Senate Banking Committee members backed by Fairshake push crypto-deregulation bills (FIT21, market-structure, stablecoin).

EvidenceVoting records and bill sponsorship rolls show 2024-2025 crypto-related bills (FIT21, GENIUS, CLARITY) introduced and reported out by senators whose campaigns received substantial Fairshake-attributed independent expenditures during the 2024 cycle.

www.congress.gov/bill/118th-congress/house-bill/4763 ↗www.banking.senate.gov/ ↗

Partial

Some Banking-committee members made personal crypto investments in proximity to votes.

EvidencePeriodic Transaction Reports (PTRs) from individual members show specific crypto-asset purchases by named senators within days of relevant committee briefings or markups. The temporal correlation triggers STOCK Act review under 15 U.S.C. § 78u-1.

efdsearch.senate.gov/search/ ↗disclosures-clerk.house.gov/ ↗

// What this documents

The documented loop shows: (1) industry money flowing to candidates via independent-expenditure entities, (2) those entities sharing operatives with the candidates' campaigns inside the 120-day common-vendor window, (3) those candidates pushing the industry's deregulation through the committee they sit on. It's the textbook fact pattern Citizens United's coordination-prohibition was designed to police — even though it preserved everything around the prohibition.

// Federal statutes implicated

Coordinated Communications 52 U.S.C. § 30118 / 11 C.F.R. § 109.20

Stop Trading on Congressional Knowledge STOCK Act, Pub. L. 112-105 / 15 U.S.C. § 78u-1

Honest Services Fraud 18 U.S.C. § 1346

// What public records cannot prove on their own

Common vendor in the prior 120 days is one of FEC's coordination indicators, not the only one and not dispositive. To prove an actual coordination violation a regulator (FEC, DOJ Public Integrity Section) would need internal communications showing 'substantial discussion' of campaign plans, requests, suggestions, or strategy convergence. The records are silent on those communications by design.

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