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Election Watchdog Group: Wyoming Company Illegally Contributed $50,000 To Hageman PAC

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By Leo Wolfson, Cowboy State Daily

A complaint alleging a Wyoming company improperly contributed $50,000 to a political action committee supporting congressional candidate Harriet Hageman has been filed with the Federal Election Commission.

The Campaign Legal Center, an election watchdog group, filed the complaint with the FEC on June 22, alleging that Snow Goose LLC is a “shell company” formed to hide the actual identity of those who donated $50,000 to Wyoming Values.

Wyoming Values is a super PAC formed to support Hageman’s campaign against incumbent U.S. Rep. Liz Cheney.

“Shell companies like Snow Goose, LLC are one of the ways special interests funnel secret spending (also known as dark money) to super PACs and conceal the true contributor’s identity,” said Saurav Ghosh, director of federal reform at Campaign Legal Center. “Voters have a right to know who is spending that money and attempting to rig the system in their favor.”

However, a spokesman for Wyoming Values took exception to the complaint.

“This complaint from Liz Cheney’s liberal friends at CLC doesn’t even allege any wrongdoing by our PAC,” James Blair, one of the Republican strategists who oversees the PAC, told Cowboy State Daily Tuesday morning. “Wyoming Values has always fully complied with the law and will continue to do so.”

No accusations of wrongdoing have been raised against Wyoming Values.

In the complaint, CLC said Snow Goose, which was formed in December by Jackson attorney Matt Kim-Miller, has no known business operations, investments, assets, or commercial ventures.

It also said that Snow Goose donated $50,000 to Wyoming Values in February.

Kim-Miller did not immediately respond to a Cowboy State Daily request for comment.

Records from the secretary of state’s office show the company shares an office with Corporate Creations Network in Casper, which is Snow Goose’s registered agent. CCN is a national company which acts as a registered agent or companies across the country.

Elaine Gonzalez, a spokesperson for CCN, declined to answer questions about Snow Goose and who runs it.

The evidence indicates Snow Goose is a “shell company” created just to send money to a campaign, making it a “straw donor” under FEC rules, according to the CLC.

FEC law states single member LLCs like Snow Goose can make contributions to super PACs, but these contributions must be attributed to the single member, not the LLC.

CLC is requesting an immediate investigation into the allegations and appropriate sanctions. 

Ghosh told Cowboy State Daily it’s not one particular infringement made by Snow Goose that is at the heart of the issue, but rather, the whole cohesive picture of how the contribution was allegedly made in a manner to conceal the identity of the contributor.

He said his nonprofit organization combs through campaign finance documents to find LLCs it suspects of wrongdoing. Although $50,000 is a relatively small sum in a race where the top two candidates have raised millions of dollars, Ghosh said the Snow Goose donation still rose to the level where it was considered deserving of an official complaint.

“$50,000 is $50,000,” he said.

Straw donor investigations have led to criminal indictments and convictions in recent years.

Wyoming Values, the super PAC to receive Snow Goose’s donation, is overseen by Republican strategists Blair and Andy Surabian, with Donald Trump Jr. serving as honorary chairman. 

Trump Jr. has been active in lobbying for Hageman, appearing in a campaign commercial on her behalf and speaking at one of her campaign events in Alpine two weeks ago. 

Ghosh said although he agrees with Blair that Wyoming Values did nothing illegal in accepting the donation from Snow Goose, he said from an ethical standpoint, all super PACs should be vetting who they receive their donations from.

He added the investigation could yield more information the donation.


“There definitely could possibly be a story we don’t know there that the FEC might find,” he said.

According to FEC reports, Wyoming Values had spent $562,224 in support of Hageman’s campaign as of the last FEC filing date of March 31.

Wyoming Values helped organize a rally featuring former President Donald Trump in Casper in May.

Blair also declined to discuss the principals behind Snow Goose.

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