Chakrabarti, 33, is a Harvard graduate and Silicon Valley entrepreneur who co-founded Mockingbird, a web-design tool, and was involved in the startup of payments processor Stripe Inc. He, Ocasio-Cortez, and her spokesman, Trent, all worked on Vermont Senator Bernie Sanders’s first presidential campaign. Trent also worked for Justice Democrats before joining the Ocasio-Cortez campaign.

As co-manager and then chairman of Ocasio-Cortez’s campaign in the final months of the 2018 election, Chakrabarti wore many hats. In addition to owning the company to which the PAC payments were made, he also co-founded the Brand New Congress PAC in 2016 and Justice Democrats in 2017.

‘Campaign in a Box’

The PACs were supposed to provide a “campaign in a box” tool set, complete with all the logistics needed to run for office. By outsourcing fundraising, communications and organizing, candidates were free to concentrate on campaigning. Chakrabarti has said he wanted to continue the momentum from the Sanders campaign by recruiting nontraditional House and Senate candidates who would pursue Sanders’s vision.

PAC Support Limit

Because of the $5,000 limit on PAC support for candidates, Chakrabarti formed the LLC to provide those services. The PACs would help candidates raise the money to pay for the company’s services. Thirteen campaign committees, including that of Ocasio-Cortez, signed on. Mitrani said Chakrabarti received no salary or other compensation from the LLC, the PACs or Ocasio-Cortez.

The arrangement was unusual but not unprecedented. Most campaigns rely on media buyers, fundraisers, consulting firms and other contractors, but generally don’t rely on PACs to provide them. FEC rules allow a candidate’s participation in such arrangements. “Ocasio-Cortez’s involvement would be akin to the hundreds and hundreds of candidates who run leadership PACs,” said Common Cause’s Ryan.

The LLC’s biggest customers, however, weren’t campaigns. Collectively, the 13 candidates paid only $173,102 to the company, $18,721 of which came from Ocasio-Cortez. Justice Democrats paid the company $605,849 and the Brand New Congress PAC paid it $261,165.

When Ocasio-Cortez and the other candidates filed spending reports, they listed the purpose of LLC payments as “strategic consulting” or “strategic consulting services.” This is what the NLPC asks the FEC to investigate.

‘Off the Books’