[ Enter Database → ]
Campaign Finance 52 U.S.C. § 30118 / 11 C.F.R. § 109.20

Coordinated Communications

Federal Election Campaign Act and FEC regulations prohibit independent expenditure committees (super PACs) from coordinating expenditures with candidates or campaigns. Coordinated communications are treated as in-kind contributions subject to limits.

  • A communication paid for by a person other than a candidate or party committee.
  • The communication was made in coordination with a candidate, candidate's committee, or party committee.
  • Coordination is shown by either (a) common vendor / common employee within prior 120 days, (b) republication of campaign material, (c) request or suggestion, or (d) substantial discussion of campaign plans.
  • The communication was for the purpose of influencing a federal election.
  • Same vendor/consultant/operative simultaneously running independent-expenditure entities and candidate campaigns.
  • Public records of consultant payments from both PAC and campaign within the same cycle.
  • Strategic messaging convergence between PAC and campaign timed to specific events.
  • The specific communications between consultants and campaigns establishing 'substantial discussion.'
  • Internal firewall arrangements (or their absence) at the consultancy.
  • Intent to coordinate vs. parallel-but-independent strategy.
Citizens United v. FEC, 558 U.S. 310 (2010)
Permitted independent expenditures by corporations and unions; preserved the prohibition on coordinated expenditures.
FEC v. Wisconsin Right to Life, 551 U.S. 449 (2007)
Refined what constitutes 'express advocacy' for coordination purposes.
Reminder. This is an analytical mapping, not an indictment. Determinations of guilt require grand juries, indictments, trials, and proof beyond reasonable doubt — none of which a public OSINT site can substitute for. Use this map the way an ethics watchdog or investigative journalist would: as a framework for asking the right questions of the records that already exist.