At first glance, "Matte Nox" looks like your typical thirty-something wannabe Internet influencer, flaunting a lavish lifestyle on his public Instagram and TikTok accounts.
He drives a black Porsche Panamera around Los Angeles at night, often to the soundtrack of club music. He lives in a luxury high-rise apartment downtown and parties with aspiring models at nightclubs. He posts shirtless selfies, displaying a prominent chest tattoo that reads, "God Will Give Me Justice." He shows off his crystal-encrusted Gucci rings, Yves Saint-Laurent sunglasses and a handmade designer hat with his name engraved.
"Your life doesn't need a purpose, just money," Nox writes in one post.
Nox is an "award-winning writer" and "executive producer," according to his online bio. In his LinkedIn accounts, he describes himself as an investor in "women-led ventures," including a modeling agency and a beauty company that sells face masks.
But like so many things on the internet, "Matte Nox" is not who he appears to be. "Matte Nox" is the assumed name and online persona of Matthew Tunstall, a 34-year-old from Texas who over the past three years has raised millions of dollars operating two political action committees that impersonated the Trump campaign.
Founded in 2018 and 2019, Tunstall's two PACs, Support American Leaders and Campaign to Support the President, have together raised a total of $3.4 million to date, according to federal filings. While much of that money pays for the billions of robocalls the two groups make, almost all of which feature recorded soundbites of public statements from Trump, a CNN KFile analysis shows that the PACs paid Tunstall at least $738,000 of that money to date.
In just the 2020 cycle alone, the Support American Leaders PAC paid Tunstall more than 360 separate times -- by far the PAC's largest number of expenditures. The majority of their contributions come from retirees, according to their filings.
None of the money the two groups have raised went directly to Trump or his campaign during the 2020 cycle. Even though Tunstall reports on his federal filings that his PACs have spent approximately $407,000 toward supporting Trump, a close analysis of those independent expenditures shows that approximately $380,000 of that money was spent on robocalls and operating expenses; about $27,000 was spent on advertising.
Tunstall, meanwhile, has been paid nearly double what he claims to have spent on supporting Trump.
CNN first reported on Tunstall in 2019, noting his robocall practices appeared to run afoul of multiple federal rules. At the time, telemarketers making the calls for Tunstall's Support American Leaders PAC falsely told CNN that the calls were made by the Trump campaign. Following CNN's report, the Trump campaign filed a disavowal notice, formally saying they had nothing to do with the PAC.
Tunstall told CNN at the time that the robocalls using Trump's voice were the result of a technical error and that his PAC had ceased to use calls like it. But he kept at it and over the next two years built the most prolific political robocall campaign in the country, according to data shared with CNN from NoMoRobo, a widely used application that blocks robocalls.
Tunstall's two Trump PACs have placed an estimated 3.48 billion robocalls since October 2019, according to NoMoRobo. That averages out to about 184 million robocalls every month to Americans' phones across the country.
Tunstall did not reply to CNN's numerous attempts to contact him for this story.
A system ripe for abuse
PACs have been around since the 1940s and were designed to pool donations in support of a candidate or a cause. But in recent years, so-called scam PACs have become more prevalent.
Adav Noti, the senior director of litigation at the Campaign Legal Center, says a scam PAC is typically seen as one that "exists primarily to raise money that is then paid to the PAC's own operators rather than to engage in bonafide political activity."
There is no hard-and-fast rule that limits how much an operator can pay themselves, nor is there a legal definition of what exactly constitutes a scam PAC, making the line between what's legitimate and what's not fuzzy and hard to enforce.
"Self-enrichment is the defining characteristic of a scam PAC, regardless of what they're saying they're doing or in fact doing with the money," said Paul S. Ryan, the vice president of policy and litigation at the watchdog group Common Cause. "Just saying that you spent the money on robocalls doesn't negate allegations of scam PAC-i-ness."
The Federal Election Commission, which regulates PACs, lacks criminal enforcement authority, leaving it up to the Department of Justice to bring prosecutions, and so far, the nation's top law enforcement agency has focused on the most extreme violations, according to experts.
The DOJ didn't federally prosecute its first scam PAC operator until three years ago, when an Arizona man pleaded guilty to orchestrating multiple scam PACs that solicited tens of thousands of small-dollar donations purporting to support political causes. In actuality, the groups contributed less than 1% of donations to candidates for office, according to the DOJ, and virtually all of the money raised by the groups were used to pay the operator or perpetuate the fraud.
The operator was sentenced to two years in prison for conspiring to defraud tens of thousands of donors.
The Justice Department told CNN that it does not track the number of scam PACs it's prosecuted. Noti, who tracks scam PACs closely, estimated that DOJ has prosecuted one to two cases a year over the last few years.
Experts who spoke to CNN said that Tunstall's filings demonstrate the hallmarks of a scam PAC, which comes down to self-enrichment. His PACs appear to follow a simple, cyclical pattern: they raise money to pay for robocalls so they can raise more money to pay for more robocalls. Nearly all of the money not used to sustain the PACs goes toward paying Tunstall. Even the paperwork the PACs are supposed to file regularly with the FEC raises serious concerns, according to experts, and the PACs frequently miss reporting deadlines.
Tunstall has faced practically no consequences. The FEC has written his PACs more than two dozen letters raising issues with the PACs' filings and has levied a little more than $14,000 in administrative fines against him. Tunstall has paid just $10 toward those fines and has avoided any civil or criminal penalties.
Tunstall's operation is so egregious, it "could almost be construed as a performance art piece designed to showcase the FEC's fecklessness," said Rob Pyers, a campaign finance researcher who tracks scam PACs on Twitter.
"Hundreds of thousands of dollars of cash-on-hand have vanished off the ledger from one reporting period to the next," said Pyers. "None of the expenditures during their first year of operation are accounted for, and about a third of the operating expenditures they have deigned to report have gone to enrich the PAC's founder."
But recently there are indications that Tunstall has changed his tactics. In mid-June, not long after CNN first contacted one of the PAC's former treasurers, Tunstall's PACs stopped making robocalls. The last ones occurred on June 18, according to data from NoMoRobo. Just four days before that, Tunstall made a surprising amendment to his most recent quarterly report, stating that one of his PACs suddenly had a negative cash-on-hand balance of more than -$280,000. The filing does not list any outstanding debts, raising more questions about the report's accuracy.
To Pyers, though, the most recent amendment to Tunstall's paperwork is another example of how his record-keeping is a "trainwreck."
"Who knows what the cash situation actually looks like?" said Pyers.
"Hi, This is Donald Trump."
When someone answers one of Tunstall's robocalls, they are usually greeted by a recording of the former President saying, "Hi, this is Donald Trump."
Typically, the calls splice together recordings of a series of public statements made by Trump. A narrator then urges listeners to donate to support Trump by pressing a number on their keypad. Those who do are transferred to a call center where they sometimes donate as little as $1 and as much as $8,000.
Sometimes, the calls directly mimic pitches sent by the Trump campaign, like a February 2019 call asking for money to send fake bricks to Democratic Congressional leaders at the same time the President's campaign was doing the same. At the time, the call contained no disclosure -- which would violate federal rules -- that the call was coming from Tunstall's PAC.
"This was a technical error if you heard this, there were many different variants that have been recently tested for different political ads regarding support for President Trump," Tunstall wrote CNN in an email in 2019. "I've been instructed by multiple legal sources that using voice clips from politicians is acceptable and not considered 'impersonating' because politicians are public officials and do not have rights to their likeness like normal private citizens and celebrities do."
Since then, the calls have included a sped-up recording at the very end that discloses the true nature of the robocall, telling listeners in a voice very quickly: "Paid for by Support American Leaders. Not authorized by any candidate or candidate committee."
But even that may violate the FEC's rules on advertising that stipulate "a disclaimer is not clear and conspicuous if it is difficult to read or hear, or if its placement is easily overlooked."
The phone number listed for Tunstall's PAC in the calls is not a working number. Nor are numbers on the website for Support American Leaders PAC. His PACs can only be contacted one way: if you receive a call and are connected to the call center soliciting donations.
Throughout and after the 2020 presidential election cycle the PACs urged call recipients to help "save President Trump from impeachment," and re-elect the President.
And later, after Trump lost the 2020 election, the PACs' robocalls' began to echo Trump's lies that the election was fraudulent and stolen. A "I'm Donald Trump" robocall in November and December 2020 opens with a recording of Trump asking people for "emergency support" to help "the campaign," and to help President Trump stop Democrats attempts to "steal this election."
The period after the 2020 election in which one PAC parroted election lies proved to be one of the most lucrative fundraising periods. In just a few weeks, Support American Leaders raised $536,000.
Tunstall paid himself almost $177,000 during that period.
Late filings and $500,000 in missing money
A closer look at Tunstall's PACs' FEC filings reveals, at best, late paperwork and, at worse, missing funds.
Since its founding in September 2018, the Support American Leaders PAC has raised nearly $3.2 million and spent nearly $2.6 million. Tunstall's other PAC, Campaign to Support the President, has raised approximately $193,000 since its founding in 2019, spending much of the money raised on "fundraising and travel," according to filings. Between the two PACs, Tunstall was paid at least $738,000.
During 2020, quarterly filings were routinely submitted months after they were initially due to the FEC. In one case, the PAC missed an FEC filing deadline by eight months.
The FEC sent four letters to each of Tunstall's PACs notifying them they failed to submit their 2020 reports on time and warned that the PACs could face administrative fines.
According to public records, which only show closed cases, in June 2020 the FEC fined the Campaign to Support the President $5,086 and the Support American Leaders $9,446 for failure to submit reports on time. And so far, each PAC has paid only $5 each toward its respective administrative fines.
A CNN KFile examination of the Support American Leaders PAC filings reveals that between the spending, filings and cash-on-hand, more than $500,000 is unaccounted for.
It's unclear where that money went, but a close look at two filings from 2019 show how much of it vanished from the books. At the end of the third quarter in 2019, Tunstall reported having cash of a little more than $423,000. But at the beginning of the next quarter, that turns into just about $1,400 -- meaning more than $420,000 was unaccounted for from one quarter to the next.
Among the dozens of letters the FEC has sent to the two PACs, one letter specifically noted the discrepancies between the cash-on-hand numbers between the 2019 filings referenced.
The law forbids the commission from disclosing any audits or enforcement actions until after the process is completed.
A symptom of a broken system
Election law experts see PAC operators like Tunstall as a symptom of an FEC that over the past decade has become dysfunctional thanks to fierce partisan deadlock, rendering it incapable of using the few tools it does have to regulate scam PACs. The result is a corner of the election economy where Tunstall can brazenly defraud people of millions of dollars.
"People complain to the FEC all the time about [scam PACs]. It's a scourge of the current finance system," said Noti, of the Campaign Legal Center, who previously worked in the FEC general counsel's office. "The FEC doesn't crack down on anything, but this, they would crack down on if they could."
"It's a matter of getting a law on the books that would let the FEC do it," Noti said.
The prospects of that remain bleak. For years, the FEC has asked Congress to empower it to address potentially fraudulent activity. And while lawmakers have introduced legislation in the past year to grant the commission that authority, nothing has gained traction. The most recent legislative effort to fix the FEC sought to alter the commission's makeup in order to ease the partisan gridlock that has paralyzed it. But that proposal was a part of the Democrats' ambitious voting rights bill, the For the People Act, which died before being debated in the Senate on June 22.
It may be years until the public has a clearer picture on whether the FEC ends up taking any enforcement action against Tunstall because their enforcement actions are confidential until complete.
It's also possible he also may shut down his PACs before they are able to.
Some experts speculate that Tunstall's recent actions, including his decision to list a negative balance for his PAC, could be part of a potential exit strategy where he shuts down his robocall operation and declares bankruptcy. Other experts suggested Tunstall's actions followed a pattern of egregious bookkeeping and that it was unclear what the recent filings meant.
But a worst-case scenario, according to Ryan, of the watchdog group Common Cause, would play out like this: the FEC fines would continue to grow but a PAC "so deep in the red could just shut down. It could close its bank account, close its office or P.O. Box and, for all intents and purposes, disappear," said Ryan.
And because PACs are typically corporations, said Ryan, "The people who set up the PAC are only personally financially liable under campaign finance law if they've knowingly and willfully violated the law."
Tunstall, meanwhile, could continue to escape consequences from the FEC and any creditors the PAC may owe money to.
CNN's Peter Valdes-Dapena contributed to this story.
CORRECTION: This story has been updated to correct the title of Paul S. Ryan, the vice president of policy and litigation at the watchdog group Common Cause.
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