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Ethics Watchdog Files FEC Complaint Concerning Rep. Gwen Moore's Apparent Abuse of Leadership PAC

Rep. Moore's Leadership PAC Spending Clearly Illustrates it is a Scam PAC

Washington, D.C. --- September 7, 2023 ---- Today, the non-partisan ethics watchdog the Foundation for Accountability and Civic Trust (FACT), filed a complaint requesting the Federal Election Commission (FEC) investigate Rep. Gwen Moore for abuse of her leadership PAC, GWEN PAC, to the extent it was functioning as a 'scam PAC' in violation of the Federal Election Campaign Act (FECA).

A scam PAC is a PAC that raises funds under the guise of supporting candidates or causes, but in reality, spends the money it raises primarily on other costs that may be described as "administrative and fundraising expenses," often benefitting the founder.

Moore's PAC "Giving Willingly Empowering Nationally," or "GWEN PAC," is unfortunately giving extremely little and literally empowering almost no one. According to data submitted to the FEC by GWEN PAC, since its inception approximately 22% of GWEN PAC's overall spending has gone towards political candidates and political committees, while around 78% has gone to other spending---much of which appear to have likely benefited Rep. Moore. In one two-year-period alone, the 2019 election cycle, only 14% of its spending went to support candidates or causes while the remaining 86% was spent on other items. Moreover, so far in the current election cycle, only 9% of GWEN PAC's spending has gone towards candidates, while 91% has paid for other expenses.

In total, GWEN PAC has spent $361,565.83 on contributions to campaigns or committees compared with $1,269,839.73 on operating expenses. Of the nearly $1.3 million in operating expenses:

  • $366,692.65 was spent on fundraising-related services. Primarily going to individuals including Rep. Moore's own sister, Brenda Moore, who has received $57,235.

  • $430,336.89 was spent on travel, food, catering, lodging, and facility rentals. These expenditures included multiple large purchases at upscale restaurants, over $17,000 at a resort in California wine country, over $26,000 at Uber and Uber Eats (which from 2019-2022 averaged one Uber trip every four days and one Uber Eats meal every eight days); $5,573.23 at Starbucks; nearly $36,000 on tickets (including tickets to see the popular Broadway show "Hamilton") and a personal chef.

These spending ratios are clearly antithetical to the intent of a leadership PAC. Under FEC regulations, a leadership PAC is only authorized for the purpose of supporting other political candidates and causes. Clearly spending only 14% on these things is not a leadership PAC.

The Federal Election Campaign Act sets forth a regulatory scheme under which candidates are only allowed to raise and spend funds as provided for in the Act. Candidates are prohibited from soliciting, receiving, directing, transferring, or spending funds in connection with a federal election unless the funds are "federal funds," defined as funds that "comply with the limitations, prohibitions, and reporting requirements of federal law." Candidates are only authorized to have official campaign committees and leadership PACs, and they are not authorized to have scam PACs.

"Over the last few years scam PAC's have become an increasingly large problem for regulators and an increasingly common topic for journalists. While this has mainly focused on outside actors, it can also apply to our elected leaders. The universally accepted tell-tale sign of a scam PAC is that the majority of its spending is on 'overhead.' According to its own financial disclosures, not only is this threshold met here, but the disclosures show GWEN PAC is taking money given by donors to be spent on political candidates and causes and is instead spending it on a various assortment of other actives. This case would stand as a perfect example of a scam PAC based solely on the lack of spending on its mission, and that is even if it didn't include spending on such things as tickets to 'Hamilton,' trips to California wine country, and payments to her own sister, which rather unfortunately it does. The bottom line is that the statute, as plainly written, does not allow Members to operate what amounts to 'slush funds', and nor should it. We hope the FEC takes a close look at both the facts and the detailed legal arguments made in the complaint and that they--for the sake of her unsuspecting donors and all citizens--take action to stop this extremely unsavory practice," said Kendra Arnold, Executive Director of FACT.

A full copy of the complaint can be found here.

FACT is a nonprofit organization dedicated to promoting accountability, ethics, and transparency in government and civic arenas. For more on FACT, visit




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