Following two published reports and months of follow-up conversations via phone and email, the Trump campaign has consistently refused to answer the question of what happened to an unlawful $2,800 donation which ended up on its balance sheets in 2019.
Outside of an accidental $225 donation from a Canadian Muslim in April 2016, Kazan's donation is the Trump campaign's only known illegal foreign contribution.
The Trump campaign told Salon that it had refunded the $225 donation, but there is no FEC record indicating that it did so. When asked, the campaign failed to provide proof.
The $2,800 donation in question was made by Rabia Kazan, a Turkish writer and author living in the U.S. on a student visa, who made the contribution in exchange for access to a March 2019 campaign event at Mar-a-Lago, where she met the president.
BuzzFeed News first reported the contribution this February, and Kazan did not know she had violated the law until journalists informed her of it.
Kazan made the payment on the website for Trump Victory, which is the official joint fundraising vehicle shared between the Trump campaign and the Republican National Committee. Trump Victory transferred the money off of its ledgers and into the Trump campaign account the same day, FEC records show.
The transfer was made in Kazan's name — not Trump Victory.
"This is actually one of the rare areas where election law is quite clear," Brennan Center fellow and Stetson University election law expert Ciara Torres-Spelliscy, told BuzzFeed at the time.
"Unless you've got a green card, foreign nationals can't give money to campaigns," she added. "And campaigns can't accept that money."
However, it also appears that neither Kazan, Trump Victory nor the campaign committed actions at the time which would have risen to the standard of "willful intent" required for a criminal conviction.
Upon the story's publication, Trump Victory refunded Kazan's money Feb. 6, which is confirmed in FEC filings, as well as in receipts shared with Salon by Kazan and an RNC spokesperson.
However, the Trump campaign offered Salon no documentation of its own transactions regarding the donation. Additionally, there is still no evidence in the campaign's most recent filings that it ever disgorged the $2,800 from its balance sheet in any way.
Though Trump Victory and Kazan would be spared "willful intent," the Trump campaign has known for months that this money on its balance sheet is unlawful.
Federal law requires campaigns to return all known illegal contributions. If money cannot be otherwise returned to a donor or committee, it must be disgorged to the Treasury Department. The campaign has yet to do so.
When Salon asked spokesperson Courtney Parella what the Trump campaign had done about the unlawful $2,800 on its balance sheet, she ceased email and phone communications about the subject matter.
Kazan, who converted from Islam to Catholicism while in the U.S., had for years been a familiar face at the Trump International Hotel in Washington and on the "Make America Great Again" booster circuit. However, Kazan renounced Trump and MAGA-world in late 2019. She denounced the president's supporters as a "cult" amid claims that she had been harassed, threatened with deportation and even shaken down for cash.
Kazan told Salon she is currently at work on a tell-all about her four years inside the movement.
She also shared with BuzzFeed, and later with Salon, evidence that two Trump campaign surrogates from her old world, Amy Kremer and Ximena Barreto — who both knew her Turkish background — had unlawfully solicited donations from her, as well as from her sister, Betul, who lives in Turkey. Kazan did not make those donations.
Curiously, there is also no FEC record indicating that the campaign ever delivered on its 2016 promise to refund its only other known foreign donor.
Shahriyar Nasir — a "proud Muslim" who lives in Toronto and does not support the president — made the donation after having lost a bet with a friend when he skipped a workout day.
He claimed that the rules of their bet required the loser to donate to an "anti-charity," which in this case was the Trump Foundation. However, he donated to the campaign by accident.
Hope Hicks, at the time a campaign spokeswoman, said the campaign was in the process of refunding Nasir's $225. However, there is no record of a refund.
Nasir did not respond to Salon's request for comment, but the campaign claimed — without providing evidence — that the money was repaid.
Though it seems clear that Trump Victory has knowingly eaten the cost of a comparatively petty refund to one of only two known foreign donors on behalf of the campaign, it is unclear why.
It is possible, experts tell Salon, that the committee wants to shield the campaign from the embarrassment of an illicit donation of this particular nature — even though doing so may further extend wrongdoing.
Trump has been dogged by serious allegations of soliciting and accepting political assistance from foreign nationals, including possibly millions of dollars through complex schemes, as well as through spending at his various properties in the U.S. and abroad. This continual pattern of behavior led directly to his impeachment last year.
Following a brief, shining one-month window of enforcement capability, the FEC lost its quorum once more when Republican commissioner Caroline Hunter resigned late last month. Without a quorum, the agency cannot enforce its own laws.
Shortly after Hunter's announcement, the White House said it would nominate Allen Dickerson to replace her. Dickerson, however, is the legal director at the Institute for Free Speech, an organization known generally to oppose campaign finance regulations.
In a statement, Dickerson called the nomination "a tremendous honor."
"I am grateful for the president's confidence and hope to have the opportunity to serve the American people in this important role," he said.
But even amid an election which promises to shatter fundraising and spending records, the pressure to restore the agency's basic functionality does not guarantee that Dickerson will be confirmed anytime soon.
The Republican-controlled Senate refused for years even to hold hearings for Trump's 2017 FEC nominee, James Trainor. After several renominations, he was granted a hearing this March and was sworn in two months later.
It is unclear exactly how campaigns, committees and dark-money groups will behave among what appears to be effectively a lawless zone during what is shaping up to be the most consequential election in U.S. history.
When asked about available recourse, a senior FEC official told Salon: "Anyone can file a complaint if they think a violation of campaign finance law or Commission regulations has occurred."