[EL] An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct
Smith, Brad
BSmith at law.capital.edu
Sat Jan 20 07:04:36 PST 2018
I hope that this is adding light, not just heat, especially to those not steeped in this aspect of election law.
Jeff writes:
"Issue ads" are known to be a falsely narrow dumb legalism by anyone who works in electoral politics.
This argument merely indicates an unwillingness to come to grips with the reason for the distinction between issue ads, that, per Buckley v. Valeo, have been largely unregulated, and political ads, which are much more heavily regulated. One might disagree that Buckley was right in making the distinction, but it's not a falsely dumb legalism by any means. The Buckley Court itself recognized the dilemma:
"the distinction between discussion of issues and candidates and advocacy of election or defeat of candidates may often dissolve in practical application. ... [but]
"constitutional deficiencies [of vagueness and overbreadth] can be avoided only by reading § 608(e)(1) [of FECA] as limited to communications that include explicit words of advocacy of election or defeat of a candidate, ...
"in order to preserve the provision against invalidation on vagueness grounds, § 608(e)(1) must be construed to apply only to expenditures for communications that, in express terms advocate the election or defeat of a clearly identified candidate for federal office. ...
"assuming, arguendo, that large independent expenditures pose the same dangers of actual or apparent quid pro quo arrangements as do large contributions, § 608(e)(1) does not provide an answer that sufficiently relates to the elimination of those dangers. ... The exacting interpretation of the statutory language necessary to avoid unconstitutional vagueness thus undermines the limitation's effectiveness as a loophole-closing provision by facilitating circumvention by those seeking to exert improper influence upon a candidate or officeholder. It would naively underestimate the ingenuity and resourcefulness of persons and groups desiring to buy influence to believe that they would have much difficulty devising expenditures that skirted the restriction on express advocacy of election or defeat, but nevertheless benefited the candidate's campaign."
424 U.S. 1, 42-45 (emphasis added).
In other words, the Court understood your argument, Jeff, but it put the distinction in place for other reasons--crudely put, to prevent FECA from swallowing up the First Amendment in its entirety.
So your argument is kind of like complaining that those nearly ubiquitous electronic pet fences we now see do nothing to keep stray animals or trespassers out of the owners yard. True, but that's not why people install them.
All this is why I ask in part how much disclosure and regulation will satisfy you, and what definitions you want to use.
For example, our listmeister Rick and I both do lots of stuff--op-ed writing, talking to reporters, amicus briefs, public speaking--that might influence how others eventually vote, and so do many others on this listserv. Our work is supported, in part, by donors to our respective academic institutions. Should those donations be publicly reported and disclosed? Should those donors be identified as paying for the dissemination of our views? I don't think so, and I doubt you do either. But what line do you want to draw? It's not good enough to just say "stuff that will influence an election" or is "intended to influence an election" or something like that, because at some point we will need to flesh out a legal definition--what both Rick and I do probably meets those vague definitions. I'm not saying that coming up with a workable standard can't be done, and there are perfectly good reasons for arguing it should be tried. I'm only saying it has to be done if we're then going to be able to talk about the merits of your proposal for a significant regulatory expansion over the discussion of public affairs.
In the meantime, the traditional definition of political advocacy is express advocacy and, since 2003, "electioneering communications" as defined by statute. And that is what proposals such as the California statute described by Trent aim to cover, what Sean was discussing, what is discussed in the article you link to and in Ciara's article that Rick linked to, what Jonathan Singer was discussing in the post from 2010 that you quoted in starting this thread.
So in terms of the original conversation, you are moving the goal posts. You wanted to take issue with my point that only about 3% of political spending is what is loosely called "dark money." Your argument for that, however, centers around a vague (but it appears quite significant) expansion of the definition of political spending. The traditional definition I use includes spending by political committees, independent expenditures, and electioneering communications (as defined by statute), and the number is 3 percent, more or less (less in 2016). That's what the great "dark money" debate has centered on for the past 8 years. And that was the subject of *your* original post that launched this thread.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
614.236.6317
http://law.capital.edu/faculty/bios/bsmith.aspx
________________________________
From: Jeff Hauser [jeffhauser at gmail.com]
Sent: Saturday, January 20, 2018 7:07 AM
To: Smith, Brad
Cc: Rick Hasen; Sean Parnell; Election Law Listserv
Subject: RE: [EL] An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct
"Issue ads" are known to be a falsely narrow dumb legalism by anyone who works in electoral politics.
Social media makes that even more so, since you build your fan base on Facebook via ads and then deploy through "organic engagement," which keeps most useful Facebook spending outside the time window.
And digital is very relevant because our knowledge of it is vastly less than that of TV ads, for which serious expenditure estimates are possible.
On Jan 19, 2018 10:29 PM, "Smith, Brad" <BSmith at law.capital.edu<mailto:BSmith at law.capital.edu>> wrote:
Ah, you want to include issue ads? But if that's the case, "enormous amounts" of non-digital spending are not disclosed, either. That gets to the question of what is "political spending."
But it's worth noting that we don't even try or purport to ban foreign spending on issue ads, not to mention lobbying.
In short, you are calling here for an enormous increase in the current regulatory regime. That may be justified, but we should be clear that that is what you are advocating. And at that point, "digital" has nothing to do with it--the relevant category is not the medium, but the message. What you need to define is what type of messaging you think should be subject to compulsory disclosure.
Meanwhile, the discussion of 501(c)(4) spending, including disclosure laws such as those advocated by Trent Lange, and Rick's concern about undisclosed (c)(4) spending, pertain to the traditional definitions of political spending. Again, using the standard for political advertising in effect since the 1976 decision in Buckley v. Valeo, plus its expansion to include "electioneering communications" in 2003, spending for which the "true" or "actual" source of funding is unknown is a very small percent of the total--about 3%.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
Professor of Law
Capital University Law School
303 E. Broad St.<https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+E.+Broad+St.%250D+Columbus,+OH+43215%26entry%3dgmail%26source%3dg&c=E,1,jBRVMvYChE16HSqn8i5rJPf44Mw7XBhuCyNw1w6_J4pJrtyE3b7NW7KRXlC1BEbh-syGiBQnzkRNxWGu7sitgVoSISgzGYqiQnWOpLJiLLlrgm_WIVQ_k-Qw13U,&typo=1>
Columbus, OH 43215<https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+E.+Broad+St.%250D+Columbus,+OH+43215%26entry%3dgmail%26source%3dg&c=E,1,nWMOgZ2pKyzObTnFENUopEkyBSPpw2OwPZSljelU8OBl5VP4eU9iCawu5wlpZyEAFDEortkxWNhXIVaeFr3bzKBaHnz4kCPgYR109HjkR51ZxJNdv5RzGrnc&typo=1>
614.236.6317
http://law.capital.edu/faculty/bios/bsmith.aspx
________________________________
From: Jeff Hauser [jeffhauser at gmail.com<mailto:jeffhauser at gmail.com>]
Sent: Friday, January 19, 2018 10:13 PM
To: Smith, Brad
Cc: Rick Hasen; Sean Parnell; Election Law Listserv
Subject: RE: [EL] An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct
You're claiming all c4 issue ads on the Internet about politicians are disclosed to the FEC? Is that seriously your claim?
And the fact that a Senator took the number of the first, nearly one year overdue concession from Facebook that ads purchased in rubles from St. Petersburg, Russia about politicians might be problematic doesn't mean that is even a tiny fraction of what was being spent in both ads and paid trolls.
On Jan 19, 2018 9:54 PM, "Smith, Brad" <BSmith at law.capital.edu<mailto:BSmith at law.capital.edu>> wrote:
Jeff,
What is your evidence for claiming that "enormous amounts of digital spending is not available to the FEC"?
52 U.S.C. 30104(c)(1): Every person (other than a political committee) who
makes independent expenditures in an aggregate amount or value
in excess of $250 during a calendar year shall file a statement
containing the information required under subsection (b)(3)(A)
of this section for all contributions received by such person.
That includes internet spending.
There is, of course, a fair amount of all kinds of spending that is not disclosed--independent expenditures by a person aggregating less than $250, some spending on membership communications, that sort of thing. But even including such longstanding provisions, which also apply to the web, what is your evidence, or even reason for believing, that "enormous amounts of digital spending is not available to the FEC"? I know of nothing to suggest that, and of course, by and large "enormous amounts" of unreported spending would already be illegal.
I'd note that in introducing the "honest ads" act, Senator Klobuchar stated that “$1.4 billion was spent on online advertising in the 2016 election." As her source, she cited https://www.borrellassociates.com/industry-papers/papers/2015-to-2016-political-advertising-outlook-august-15-detail<https://linkprotect.cudasvc.com/url?a=https://www.borrellassociates.com/industry-papers/papers/2015-to-2016-political-advertising-outlook-august-15-detail&c=E,1,QaaA7zw64OO4qJBNecL_PEdRKMaGQKob9uTvrv5rBaCgnMQneKfs0uyjJUvBuSJSe0dvtpso1-8YpHG98Uo69uGIlSBMWTGTssLT3V0aJxs,&typo=1>. https://www.borrellassociates.com/industry-papers/papers/2015-to-2016-political-advertising-outlook-august-15-detail.<https://linkprotect.cudasvc.com/url?a=https://www.borrellassociates.com/industry-papers/papers/2015-to-2016-political-advertising-outlook-august-15-detail.&c=E,1,T1N21LcaiSWoiQBOnyjWk7MaudG0xezVlOMK0rs8qedq1jxWtzXRwDhJzQAfxhLoSQBkn_rNEyb1m6SRwO5Cbf2LFnamDHzFknLylHT_0AWQ7NqM9r0n-wdH848B&typo=1> In turn, the legislative findings in Section III of the Honest Ads Act notes that Facebook reported "between June 2015 and May 2017, Russian entities purchased $100,000 in political advertisements."
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
Professor of Law
Capital University Law School
303 E. Broad St.<https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+E.+Broad+St.%250D+Columbus,+OH+43215%26entry%3dgmail%26source%3dg&c=E,1,_gCMEcFXcPC6nmrCmc4KcrJWP1u5aLhU4xKvIGBOedNdpHplJTPGgHRD3loCiVI_PTRNs0XWst2cNJ6719_yxq7OQ70LqBAdD-Jjlos4gYPwkJZ-tMHBlFKHJlg,&typo=1>
Columbus, OH 43215<https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+E.+Broad+St.%250D+Columbus,+OH+43215%26entry%3dgmail%26source%3dg&c=E,1,TveNBivOhp4efux3fQBGRLh4RTGAirWAM8mAGpf-MrwCLnb3AlAL0kGwKPr_yjemShOqOma9muuHQ9m4oCRi5Nx59sov-K5xRcsBNcGaBFE,&typo=1>
614.236.6317
http://law.capital.edu/faculty/bios/bsmith.aspx
________________________________
From: Jeff Hauser [jeffhauser at gmail.com<mailto:jeffhauser at gmail.com>]
Sent: Friday, January 19, 2018 12:54 PM
To: Smith, Brad
Cc: Rick Hasen; Sean Parnell; Election Law Listserv
Subject: Re: [EL] An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct
Brad first wrote," What would such a statute look like? I’ve never really seen one that solves the alleged problem without creating double reporting, and often providing misleading information to the public.
And always remember, we’re talking about approximately 3%, more or less (less last year) of political spending."
He then wrote, "I didn’t give any statisitics on digital spending. I gave stats on total spending. We at IFS derive those from Open Secrets and from FEC records."
But an enormous amount of digital spending is not available to either Open Secrets or the FEC.
If you purport to discuss the denominator of "political spending," you are purporting to know the actual amount of digital spending.
But since you cannot know the full amount of digital spending. you should not be making claims about "political spending."
On Fri, Jan 19, 2018 at 12:49 PM, Smith, Brad <BSmith at law.capital.edu<mailto:BSmith at law.capital.edu>> wrote:
I didn’t give any statisitics on digital spending. I gave stats on total spending.
We at IFS derive those from Open Secrets and from FEC records.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
Professor of Law
Capital University Law School
303 East Broad Street<https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+East+Broad+Street%250D+_Columbus,+OH+43215_%26entry%3dgmail%26source%3dg&c=E,1,6878QynwdMpnK9GVhwjPbemedLwLIH_8fEwSSXDgQ9QFY4ElackKG-vv2dK5tDzIAYuSv58uuGQ8SsaydVwCzUkGK4_dd52K4HmlTmV8ExyxHQ,,&typo=1>
Columbus, OH 43215<https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+East+Broad+Street%250D+_Columbus,+OH+43215_%26entry%3dgmail%26source%3dg&c=E,1,ZcV0uDmN9xndIIneN0YtMXyLq0Ff-eIwdAWPQZFvR3cpezrHoM5w7uByXqg3W8Swxw7NuIauQuYggSAuG4mUqv8UAwT5VlETmWSWuN78x7xtVwV9X_C9&typo=1>
(614) 236-6317
bsmith at law.capital.edu<mailto:bsmith at law.capital.edu>
http://www.law.capital.edu/faculty/bios/bsmith.asp
From: Jeff Hauser [mailto:jeffhauser at gmail.com<mailto:jeffhauser at gmail.com>]
Sent: Friday, January 19, 2018 12:46 PM
To: Smith, Brad
Cc: Rick Hasen; Sean Parnell; Election Law Listserv
Subject: Re: [EL] An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct
"And always remember, we’re talking about approximately 3%, more or less (less last year) of political spending."
Brad, what is your source of statistics on total digital political spending in 2016, and the proportion disclosed?
On Fri, Jan 19, 2018 at 12:43 PM, Smith, Brad <BSmith at law.capital.edu<mailto:BSmith at law.capital.edu>> wrote:
What would such a statute look like? I’ve never really seen one that solves the alleged problem without creating double reporting, and often providing misleading information to the public.
And always remember, we’re talking about approximately 3%, more or less (less last year) of political spending.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
Professor of Law
Capital University Law School
303 East Broad Street<https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+East+Broad+Street%250D+_Columbus,+OH+43215_%26entry%3dgmail%26source%3dg&c=E,1,S7bonyLVvU0kPXLO0VvCJ05LsPUKl_xAUWIrdanWxC1UNwSpHpjJ2fJbgL8LJglwPWU6dATnYbrzMcQBBZypXcy1pQRqc-AGtGMkE9rbffoKl64,&typo=1>
Columbus, OH 43215<https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+East+Broad+Street%250D+_Columbus,+OH+43215_%26entry%3dgmail%26source%3dg&c=E,1,-_-oWvTskmv9apWftdyGAG2EOw-gwMA4BDrbFhC95JMSBnT0MATCP7vSYI8tmqlT-RAtOTkVniOuJSRyRj0ummkO-me6wcrrSxyK0-LQI5Bhi30aw3fO1s0f&typo=1>
(614) 236-6317
bsmith at law.capital.edu<mailto:bsmith at law.capital.edu>
http://www.law.capital.edu/faculty/bios/bsmith.asp
From: Law-election [mailto:law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] On Behalf Of Rick Hasen
Sent: Friday, January 19, 2018 12:28 PM
To: Sean Parnell; Jeff Hauser
Cc: Election Law Listserv
Subject: Re: [EL] An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct
That seems like a pretty good argument for Congress to pass improved disclosure laws, regardless of the tax status of a particular organization, for any organization or person who spends or contributes BIG money (I’d raise thresholds dramatically) on election-related activity (we can discuss how that is best defined, but at least extending electioneering communications to digital ads seems like a good start).
This way we know where the ultimate source of money is, without allowing the kind of shell games to go on.
From: Sean Parnell <sparnell at philanthropyroundtable.org<mailto:sparnell at philanthropyroundtable.org>>
Date: Friday, January 19, 2018 at 9:22 AM
To: Jeff Hauser <jeffhauser at gmail.com<mailto:jeffhauser at gmail.com>>, Rick Hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>>
Cc: Election Law Listserv <law-election at uci.edu<mailto:law-election at uci.edu>>
Subject: RE: [EL] An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct
And the same goes for the public, of course, who would only see “We’re Totally Not The Russians LLC” listed on whatever form of disclosure is envisioned by Ciara and others in the “reform” community.
Sean
From: Jeff Hauser [mailto:jeffhauser at gmail.com]
Sent: Friday, January 19, 2018 12:11 PM
To: Rick Hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>>
Cc: Sean Parnell <sparnell at philanthropyroundtable.org<mailto:sparnell at philanthropyroundtable.org>>; Election Law Listserv <law-election at uci.edu<mailto:law-election at uci.edu>>
Subject: Re: [EL] An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct
Michael Cohen has been alleged by the Wall Street Journal to create an LLC to pay off an actress aleged to have an affair with Trump: https://www.wsj.com/articles/trump-lawyer-used-private-company-pseudonyms-to-pay-porn-star-stormy-daniels-1516315731?utm_source=The+Point+with+Chris+Cillizza+Alerts&utm_campaign=d827904afa-EMAIL_CAMPAIGN_2018_01_19&utm_medium=email&utm_term=0_ada7c7ac0a-d827904afa-83775533
If Russians created shell companies in Delaware to give money to the NRA, all the IRS would see is "Delaware LLC."
(the NRA would presumably make inquiries about any unexpected contributions, and I doubt they lack information on who is giving them big money)
On Fri, Jan 19, 2018 at 11:59 AM, Rick Hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>> wrote:
Has the NRA issued any public statements denying the receipt of money from Russian government sources/sources allied with Russian government which were used by its c4 for election-related activity?
From: Sean Parnell <sparnell at philanthropyroundtable.org<mailto:sparnell at philanthropyroundtable.org>>
Date: Friday, January 19, 2018 at 8:55 AM
To: Rick Hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>>, Election Law Listserv <law-election at uci.edu<mailto:law-election at uci.edu>>
Subject: re: An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct
I wanted to clear up what some might mistakenly infer from the piece by Ciara Torres-Spelliscy linked to below concerning the latest speculation regarding foreign money, Donald Trump, and those pesky Russians (hold on a sec, it appears the 1980’s are calling and wish to talk to me about something). She writes:
For many years now, good-government groups and campaign finance experts have warned that illegal foreign funds could be hiding in that dark money.
That’s because, in federal races, political spenders that go dark are exploiting a loophole between the campaign finance system overseen by the FEC, which typically insists on that all donors to campaigns identify themselves, and charities the Internal Revenue Service allows to collect funds donated anonymously.
Three things:
1. The National Rifle Association is not a “charity,” at least as defined by the IRS. It’s a 501c4 “social welfare” organization (it does have an associated foundation, which is a 501c3, but I don’t believe it’s alleged that this entity was funding any political ads, let alone Russian-funded ads).
2. While the NRA and other 501c organizations do not reveal donors to the public, they do reveal them to the IRS (or at least are required to) on Schedule B. Presumably, if there is a concern that the NRA took in millions of dollars from Russian sources (whether state or “private” to the extent there’s any distinction in Russia), it should be relatively easy for the FBI to get the information from the IRS (I’m not sure if it requires a subpoena or not in this particular instance, but law enforcement is able to get confidential tax records). I’d guess that someone at the NRA handed a few million dollars by a Putin pal would have realized this and handed it back, if such a highly-speculative transaction occurred, but then there are some imprudent people out there so who knows?
3. Anonymous contributions to charities are hardly a “loophole,” it is in fact a practice with a long and deeply ingrained history in philanthropy, praised in the Gospel of Matthew 6:1 – 6:4 and also by Seneca the Younger, among others. I’ve written an overview of anonymous charitable giving, published last year, if anyone is interested: http://www.philanthropyroundtable.org/file_uploads/Protecting_Donor_Privacy.pdf<https://linkprotect.cudasvc.com/url?a=http://www.philanthropyroundtable.org/file_uploads/Protecting_Donor_Privacy.pdf&c=E,1,yB8z6rp4LjNjM5ymoJ1dImrzWM79VhYNJoqxPC_XoXt9GjQT0InnValyOCkhJtMP_8pHZoIqhgWkOAemSMJDexQDkzwm71eIcqSOvJJOrtAElXaUNJul5RoCSQ,,&typo=1>
Best,
Sean Parnell
Vice President of Public Policy, The Philanthropy Roundtable
1120 20th Street NW, Suite 550<https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d1120+20th+Street+NW,+Suite+550%26entry%3dgmail%26source%3dg&c=E,1,ZSWvIYPRn84sKS13Ax9ZK6c-a2JJcOUgmhZh1u-6g3eKfV7j8xw-gLwMl08sCin-6g7wtZuMFxZmB-uGLA8YLHKgrMoMk86BMOji7S_G7S4,&typo=1> South
Washington, DC 20036
(202) 600-7883 (direct)
(571) 289-1374 (mobile)
sparnell at philanthropyroundtable.org<mailto:sparnell at philanthropyroundtable.org>
“An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct”<https://linkprotect.cudasvc.com/url?a=http://electionlawblog.org/%3fp%3d96992&c=E,1,BKi2Bl65mU5t49bOewqAU826TvtS3eDYa8NI60HN9UKbJwZj9V_sIszWT4hRZH5TMPfGuNrBkBlk_HzUjasx-ls5ZBiDEC-68FaeWbdVmqYtQ3BuUgXvZw,,&typo=1>
Posted on January 19, 2018 7:16 am<https://linkprotect.cudasvc.com/url?a=http://electionlawblog.org/%3fp%3d96992&c=E,1,3Vamj5-VOxEeYqxdG_0blzHJ_2qRAmm75-uAR2swPatBXSs7ZH531VACjxuix2nc-mHZX-jT4DVvLzUnxoTizF19Ja3SzFcXdCbB4v8u1bx8gYB9rZ-WLLLDuQ,,&typo=1> by Rick Hasen<https://linkprotect.cudasvc.com/url?a=http://electionlawblog.org/%3fauthor%3d3&c=E,1,SmymVOI1x1o5FHgDBghPFJE8Hid_DkCm86r_yypWpQTeY8-KPIdE14N1JZQb4O6F_-vpZzg3JqhoHNCGleWkr37i6H98w7w83AhogQ0c9tNg5evNeuyq&typo=1>
Ciara Torres-Spelliscy<http://www.nydailynews.com/opinion/insidious-foreign-dark-money-threat-article-1.3765048> NYDN oped.
Posted in campaign finance <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D96992&title=%E2%80%9CAn%20insidious%20foreign%20dark%20money%20threat%3A%20New%20reports%20about%20Russian%20money%20going%20to%20the%20NRA%20could%20prove%20watchdogs%E2%80%99%20fears%20correct%E2%80%9D>
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