FEC referral secures criminal conviction in campaign finance matter

WASHINGTON—The Federal Election Commission’s referral of an enforcement matter to the U.S. Department of Justice resulted in a successful criminal prosecution.

A complaint by Heller for Senate (the Heller Committee) and HellerHighWater PAC (the PAC) alleged that Ryan Phillips, a former partner at In Compliance, Inc., knowingly and willfully violated the Federal Election Campaign Act of 1971, as amended (the Act), by converting Heller Committee funds to personal use and by commingling PAC funds with his personal funds.

Specifically, the complaint alleged that Phillips misappropriated $46,226.66 from the Heller Committee and $139,051.38 from the PAC through unauthorized withdrawals, checks, and transfers, and used those funds to make direct payments to himself or pay his personal expenses directly to merchants. Phillips allegedly made multiple false entries in the accounting and campaign software and then reconciled the committees’ bank statements with the accounting and campaign software to hide his illegal transactions.

On June 22, 2023, the Commission found probable cause to believe Phillips knowingly and willfully violated the Act. The Commission also voted to make a referral of the knowing and willful violations to the Department of Justice pursuant to 52 U.S.C. §30109(a)(5)(c). Phillips pled guilty to one count of making false statements to a federal agency, and on April 8, 2024, Phillips was sentenced to three years’ probation following criminal proceedings. On June 6, 2024, in light of the successful prosecution of Mr. Phillips, the Commission voted to take no further action and closed the file.

Documents in the matter, MUR 7615, are available through the closed enforcement matters section of the FEC website.