BEFORE THE FEDERAL ELECTIOD
COOLIDGE-REAGAN FOUNDATION
441 North Lee Street, Suite 100
Alexandria, VA 22314
Complainant,
v.
SENATOR BERNARD SANDERS
FEC Candidate ID P60007168
221 Van Patter Pkwy
Burlington, VT 05408
BERNIE 2016 CAMPAIGN COMMITTEE
FEC Committee ID C00577130
P.O, Box 905
Burlington, VT 05402
‘Susan Jackson, Treasurer
BERNIE 2020 CAMPAIGN COMMITTEE
FEC Committee ID C00696948
P.O. Box 391
Burlington, VT 05402
Lora Haggard, Treasurer
Respondents.
COMMISSION
MUR No.
VERIFIED COMPLAINT
1. Coolidge-Reagan Foundation brings this complaint before the Federal Election Commission
(“FEC” or “Commission”) seeking an immediate investigation and enforcement action against
United States Senator Bemard Sanders, the Bernie 2016 Campaign Committee, and the Bemie
2020 Campaign Committee for direct and serious violations of the Federal Election Campaign
Act (“FECA”).2. This complaint is filed pursuant to 52 U.S.C. § 30109(a)(1) and is based on information
providing reason to believe that:
3. Senator Sanders and Bernie 2016 permitted foreign nationals Erika Andiola, Cesar Vargas,
and Maria Belén Sisa to serve in advisory campaign positions, enabling them to directly or
indirectly participate in the decision-making process of persons with regard to election-related
activities of Bernie 2016 in violation of FEC regulations;!
4. Senator Sanders and Bernie 2016 knowingly accepted ten individual contributions from Ms.
Sisa, a foreign national, in the aggregate amount of $35.00 in violation of FECA;?
5. Senator Sanders and Bernie 2020 is permitting a foreign national, Ms. Sisa, to serve in an
advisory position which allows her to directly or indirectly participate in the decision-making
process of persons with regard to election-related activities in violation of FEC regulations.?
STATEMENT OF THE LAW
6. FEC regulations prohibit foreign nationals from directly or indirectly participating in the
decision-making process of any person with regard to any election-related activities.
7. In Weller, A.O. 2004-26, at 3 (Aug. 20, 2004), the Commission concluded although a foreign
national—the fiancé of a Member of Congress—could legally volunteer for a federal
campaign, § 110.20(i) prohibited her from “participat[ing] in [a candidate’s] decisions
regarding his campaign activities” or “the decisions” of the candidate’s committee. She also
could not be “involved in the management” of a candidate committee. Id.
8. FECA prohibits any foreign national from making “a contribution or donation of money or
other thing of value” in connection with a federal, state, or local election.*
HUES fsuataniyanl GAR |1TOoHey Sete ERNE TOI nna CER S029,
DILGER § 110200), Sea 7 Fe Reg, 3946 (Nov. 19# 202) (Explanation and sation fr 11 CR § 11020)
sa
SS2USC. §30121(aXIMAY; 11 CER. § 1102000)9. FECA prohibits persons from knowingly accepting or receiving a contribution from a foreign
national.‘ “Knowingly” means that a person must: (i) have actual knowledge that the source
of the funds solicited, accepted, or received is a foreign national; or (ii) be aware of facts that
would lead a reasonable person to conclude that there is a probability that the source of the
funds solicited, accepted, or received is a foreign national; or (iii) be aware of facts that would
lead a reasonable person to inquire whether the source of the funds solicited, accepted, or
received is a foreign national, but the person failed to conduct a reasonable inquiry.”
10. A “foreign national” is an individual who is not a citizen of the United States or a national of
the United States and who is not lawfully admitted for permanent residence.*
11. In February of 2018, a cease and desist order was issued in MUR 7035 (Bemie 2016 et al.)
requiring the Bernie 2016 committee stop violating 52 U.S.C. § 30121(a)(2).
STATEMENT OF FACTS
12, Senator Sanders and his presidential campaign committee, Bernie 2016 announced the hiring
of Cesar Vargas, a well-known immigration activist, Mexican national, and Deferred Action
Childhood Arrival (“DACA”) recipient in October of 2015.!° His assignment was to mobilize
young voters in the Southwestern United States. At the time of hiring, Mr. Vargas was quoted
as saying, “I joined the campaign because the Senator believes not only that we should meet
DREAMers but that DREAMers should be part of the conversation to champion policies for
£52 USC. §30121(a\2); 11 CER. § 1102068)
TTICER § 110200044)
52 USC. §30121(0)2); Adtonally, itis important o not thatthe memorandum outing DACA confeed “no substantive right,
‘miggtion satus or patvay to eiizeship.” Mem. From Janet Napoiano, Sec'y, DHS, Execsing Prosecueil Discretion wih Respect 0
Individuals Who Came tothe United States as Children at 1-2 June 15%, 2012).
"Inthe Mater of Bernie 2016 and Susan Jackson eral capacity as treasurer, MUR 1035 (Feb. 1°, 2018),
usw fe 0 legal mur/7035/1 8044037388 pl
Advan Carasqill, Bernie Sanders Hires igh Profle DREAMer Acts For Latino Outreach, BUz2Pe=D News (Oct. 22015),
pnw: rseehews com ce/adanceula/ormi-anders-hitesh ghia activist fr laid tek OMY Soe ala,
Dew York's First Undocumented Lamyer:'We All Have a Voice’, NEW AMERICANECONOMY,
Dip, pewamerianesonorn of festuenen-crke-fist-undogunetted-lawyer weal ave--voice/ (Feb, 1,208).
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