Heading into the 2014 midterm elections, polls showed the Republican Party had an opportunity to retake control of the Senate. Such a change would severely limit President Barack Obama’s legislative agenda during his final two years in office, an outcome that was especially attractive to the National Rifle Association. In the wake of devastating events like the 2012 mass shooting at Sandy Hook Elementary School, the president had become an aggressive promoter of new gun regulations.

To get its message out, the NRA turned to an unknown consulting firm, Starboard Strategic Inc., paying it $19 million. More than a third of that money was invested in must-win Senate seats in Colorado, North Carolina, and Arkansas — three of the most expensive in the country — paying for a host of television, radio, and internet ads.

It was not unusual for the NRA to spend large sums of cash in an election cycle. What was odd was where the money was going. Before 2013, Starboard Strategic had never appeared in Federal Election Commission reports. Someone curious about the firm would have found a skeletal website that listed no staff, clients, address, phone number, or previous work. There was just some generic branding language (“Good advertising and good ground operations start with good strategy”) and a basic email address: [email protected]. Yet at a moment when the stakes were high — Republicans needed six seats to claim a majority — the firm had come out of nowhere to become the NRA’s top election contractor.

Acquiring business of this magnitude would be an incredible feat for a firm with no reputation. The question is whether it was really accomplished by Starboard, or another outfit called OnMessage Inc.

Well-established and well-connected, OnMessage is as transparent as Starboard is opaque. What the FEC and the public do not know is that the two entities appear to be functionally one and the same.

In 2014, among OnMessage’s most prominent clients were three Republican challengers vying for Senate seats in the same races where the NRA would pay Starboard some of its biggest outlays of the cycle: Thom Tillis, in North Carolina; Cory Gardner, in Colorado; and Tom Cotton, in Arkansas. All of these candidates would defeat Democratic incumbents, cementing the result for which GOP leaders and the NRA had mobilized: a Republican majority in the upper chamber to match the one in the House. Each challenger paid OnMessage between $5 million and $8 million, far more than they paid any other vendors.

Campaign finance rules prohibit coordination between official campaigns and outside groups, like the NRA, who support the same candidate. Those restrictions, in turn, give force to a fundamental law governing political spending. Outside groups can independently disburse unlimited sums to influence elections. But they can give no more than $5,000 when giving directly to a candidate.

Official campaigns and the outside groups supporting them may use a common vendor, such as a political ad firm. However, the rules mandate the vendor ensure employees and partners working for each client don’t share information. There is no evidence of any meaningful distinction between Starboard Strategic and OnMessage. Public records show the two entities share corporate officers and identical office addresses — one in Alexandria, Virginia, and the other in Annapolis, Maryland. Internal emails indicate executives toggled between roles for both firms. A former OnMessage employee who worked out of the Alexandria location in 2014 says Starboard had no separate dedicated presence there. “Beyond some Starboard-labeled thumb-drives lying around, I don’t recall anything within our office that was called or associated with Starboard,” said the former employee, who requested anonymity to avoid retribution.

Two former FEC chairs, one Republican and the other Democrat, reviewed the findings of Politico Magazine and The Trace, and said they found them troubling. “This evidence raises substantial questions about whether OnMessage and Starboard Strategic were used as conduits for coordination between the NRA and the candidates it was supporting,” Trevor Potter, the Republican, said. “It’s pretty serious,” added Ann Ravel, the Democrat. “It doesn’t seem right.” Both former chairs independently came to the same conclusion: “The FEC should investigate.”

In a close race, coordination can provide a candidate with crucial advantages. “When a group like the NRA is operating independently, there’s a potential for its messaging to conflict with that of the candidate it’s supporting,” Brendan Fischer, the director of the Federal Reform Program at the Campaign Legal Center, a nonpartisan watchdog group, said. “There’s also a good chance inefficiencies will arise. The NRA could target the wrong set of voters, or the same voters as the candidate, which would make its spending redundant.” Sharing information, Fischer went on, allows an outside group and an official campaign to unfairly operate in harmony. “So if candidates are spending a lot of money between 7 a.m. and 9 a.m., for example, then perhaps the NRA’s money is better spent between 5 p.m. and 6 p.m.

Typically, a firm serving as a common vendor to campaigns and outside groups seeks to prevent its employees from inappropriately sharing information by requiring them to read and sign what’s known as a firewall policy. The text amounts to an agreement to comply with the law, and makes clear the penalties for failing to do so. It is not known if, or how, OnMessage enforced firewalls in races where Starboard was active on behalf of the NRA. Neither the NRA nor OnMessage nor its partners responded to multiple requests for comment that included written sets of detailed questions about whether Starboard is a fully operational company or a shell company that exists principally on paper.

The FEC is widely considered a toothless agency, paralyzed by partisan infighting, and campaign finance laws are often honored in the breach. But listing a shell company in FEC filings, according to Brett Kappel, a campaign finance expert, “would be a violation of the reporting requirements.” The filer “should have identified whoever was actually performing the work.” Indeed, according to a 2016 FEC General Counsel report, “The Commission has determined that merely reporting the immediate recipient of a committee’s payment will not satisfy the requirements … when the facts indicate that the immediate recipient is merely a conduit for the intended recipient of the funds.”

In May, the United States Court of Appeals for the Eighth Circuit issued an opinion that is consistent with the analysis of the FEC’s top lawyer, and even goes a step further. According to the ruling, using the name of a shell company to report the recipient of money spent by a political committee could violate a criminal statute that prohibits the falsification of records to deceive a federal agency. Such a crime could result in a 20-year prison sentence.

Meanwhile, the NRA’s relationship with Starboard persists. The gun group paid Starboard more than $40 million in 2016, a sum that surpassed the total federal election payments made to OnMessage in the same year by all candidates and groups by more than $10 million, according to campaign finance data. During that election cycle, Senator Ron Johnson, the Republican incumbent in Wisconsin, was defending his seat in a tight race. Johnson’s campaign hired OnMessage. Later, the NRA, listing Starboard as its vendor, paid for ads boosting his candidacy. Johnson won his race by fewer than 100,000 votes.

This year, at least one of the contests that will determine control of the Senate features a candidate who has tapped OnMessage while benefitting from the firm’s work on behalf of the NRA, according to the former OnMessage employee. In Florida, Governor Rick Scott is challenging Bill Nelson, the Democratic incumbent. In his last gubernatorial campaign, Scott hired OnMessage. The NRA, the former employee says, tapped the firm for pro-Scott work. But in Florida campaign finance records, which do not require filers to disclose the races in which money is spent, it’s Starboard that appears as a vendor. Scott’s chief political adviser is Curt Anderson, a partner at both OnMessage and Starboard, and Scott’s Senate campaign has signed up OnMessage as a contractor. The NRA, which bashed the gun control package Scott signed in March after the Parkland school shooting, has yet to wade into the race, but its federal agenda depends on preserving a Republican majority in the Senate. The Florida race is likely to be the most competitive, and most expensive, of 2018, making any edge for either candidate potentially decisive.

OnMessage was founded in 2005 by three veteran Republican operatives: Curtis and Wesley Anderson, who are brothers, and Bradley Todd. Later, they added three more partners — GOP strategists Timmy Teepell, Guy Harrison, and Graham Shafer — and now have roughly a dozen employees. “If you want to talk about establishment Republican consulting firms, OnMessage is definitely one of the more prominent ones,” Rick Wilson, a GOP strategist, said. “They’ve had a lot of wins over the last few years. They work the system in D.C. very effectively for their purposes.”

A full-service political consulting shop, OnMessage is especially known for its award-winning, often cinematic ads. Its sizzle reel features a pounding soundtrack over snippets of emotionally charged campaign spots that alternately play for the heart or the gut. Candidates who OnMessage is retained to help elect are depicted jamming on a guitar or jawing with their dad on the family farm. Those it is hired to oppose may be portrayed by actors in elaborate scenarios, or more straightforwardly pummeled with unflattering juxtapositions and biting language. One of OnMessage’s many industry accolades is for a merciless 2014 ad against Charlie Crist, Scott’s opponent. The spot earned a Reed Award for “Best Bare-Knuckled Street Fight TV Advertisement.”

Of all of the OnMessage partners, Todd has the most public profile. He writes editorials for major network news sites, including a recent piece on Fox Opinion that takes NFL players to task for kneeling during the national anthem. On Twitter, he derides the “loony left,” and appears on cable news shows to explain the conservative electorate to a media that he views as out of touch and uncomprehending. In the summer of 2016, during an appearance on MSNBC, he famously stated, “The voters take Donald Trump seriously as a candidate, but they don’t take him literally. The press takes Donald Trump literally, but they don’t take him seriously.” In May, Todd and Salena Zito, a syndicated columnist, co-authored The Great Revolt: Inside the Populist Coalition Reshaping American Politics. The book examines the mindset of Trump’s supporters, and has been enthusiastically endorsed by the president, who said it “does much to tell the story of our great election victory.”

Over the years, OnMessage has built an impressive roster of clients. In addition to Tillis, Gardner, Cotton, Johnson and Scott, the firm has worked with the National Republican Senatorial Committee; the National Republican Congressional Committee; the Republican National Committee; and former senators Scott Brown and Thad Cochran, among many others. Another high-profile client has been the NRA.

Todd and the NRA’s top lobbyist, Chris Cox, both attended Rhodes College in Tennessee and graduated together in 1992. “They’re buddies,” said a former employee of Cox’s, who worked in the group’s lobbying wing, the Institute for Legislative Action, and spoke on the condition of anonymity out of concern for professional consequences. “I’d occasionally see Brad around the office, and sometimes, before sending out an email to NRA members, Chris would have me run the language by Brad.” A second former ILA staffer, who requested anonymity for the same reason, said, “Brad was definitely around the office, not regularly, but when he was, he was in the executive suite. There was consulting with Brad over high-end issues that were deemed controversial. It was, ‘How do we say this?’ Or, ‘What language do we use?’” (Cox did not respond to request for comment.)

In 2010, the NRA for the first time listed OnMessage as a vendor in its FEC filings. That year, the gun rights group paid the firm about $3.19 million for its services, including the production of ads in support of Republican Senate candidates like Roy Blunt and Patrick Toomey. The following cycle, in 2012, the NRA’s expenditures linked to OnMessage greatly increased, totaling $11.25 million, making the firm the NRA’s top federal election vendor by more than $5 million. Large portions of the money went toward ads attacking President Obama, who was up for re-election. During those two election cycles, OnMessage also produced ads and other messaging for candidates’ campaigns, but never in races where it was working for the NRA.

In January 2013, according to a website registration document, Wesley Anderson registered Starboardstrategicinc.com. The document provides an address for the “admin contact” and the “tech contact,” which begins “OnMessage Inc. ATTN STARBOARDSTRATEGIC.COM.” The site has never included any details about the new company. But some of the language it does employ is nearly identical to language that can be found on the website of OnMessage. For example, each site has a tab for “Crisis Management.“ OnMessage’s reads, “The political environment is constantly changing. Being prepared to respond to that change is an important part of any campaign and we are prepared to do it.” On the Starboard site, the word “campaign” is replaced with “fight.”

Two months later, in March 2013, corporate documents show that the partners at OnMessage — with the exception of Harrison, whose name would be added to filings in the years to come — incorporated Starboard Strategic Inc., and, as subsequent annual reports demonstrate, would function as its principals. OnMessage would never appear in the NRA’s FEC reports again.

The following year, during the fall of 2014, as the midterm election season was well underway, the NRA paid Starboard millions of dollars for ads supporting Tillis, Gardner and Cotton. In the same period, money flowed from these candidates to OnMessage.

“With respect to the work being done for these particular campaigns, certain partners — not just employees — would have had to have been firewalled off from each other,” Fischer, the director of the Federal Reform Program at the Campaign Legal Center, said. Kappel, the campaign finance expert, explained, “One way to guarantee separation is to keep employees working for the outside group at one office, and those working for the campaign at another.”

In the three big 2014 Senate races, all expenditures made to Starboard carried one of two addresses where OnMessage maintains workspace. For Tillis and Cotten, the two companies supporting the same candidates would frequently appear in FEC reports at identical locations in Annapolis. Gardner’s campaign sent work to OnMessage in Alexandria, where, shortly before Election Day, it overlapped with an NRA payment to Starboard of more than $525,000. Representatives of Cotton, Tillis, Gardner, Johnson and Scott did not respond to requests for comment for this article.

After the three candidates won their races in November, and Republicans regained control of the Senate, the Onmessageinc.com biography page belonging to Todd — the partner who is friends with NRA lobbyist Chris Cox and well known to Cox’s employees — was updated. It now says, “Todd’s 2014 clients defeated three incumbent Democratic U.S. Senators in a single election cycle, a feat unmatched by any Republican media consultant in 34 years.”

Despite Starboard’s impressive run in 2014, there appeared to be no attempt to market the new company to other prospective clients. In fact, according to FEC reports, other than a small sum it received from the National Republican Congressional Committee — business worth less than $20,000 — it has never had another federal election client besides the NRA. Moreover, none of Starboard’s partners has publicly affiliated himself with the company; four of them have LinkedIn pages, for instance, and their profiles only mention OnMessage. One of them is Todd, who used the email address [email protected] to offer the former OnMessage employee a job.

There is also no indication that Starboard has a distinct team of employees working within the offices of OnMessage. As with the partners, there are no staff members who publicly list themselves as working for Starboard, though a second email shows acknowledgement of double duty. Vicki Tomchik is OnMessage’s longtime chief financial officer; the job is the only one she lists on her LinkedIn page. But in 2014, when the former OnMessage employee received an email from Tomchik, there were two references below her signature. One was OnMessage, and the other was Starboard. (Tomchik did not respond to a request for comment.)

That same year, the NRA invested heavily in Scott’s gubernatorial re-election effort in Florida, a race that the incumbent eventually won by a single percentage point. In the NRA’s state campaign finance filings, more than a million dollars’ worth of independent expenditures are attributed to Starboard, but none to OnMessage, which was working for Scott’s campaign. Unlike the federal regulations, Florida law does not require outside groups to disclose whether money was spent to support or oppose a particular candidate. But an ad the NRA published online in the fall can be traced back to OnMessage by the former OnMessage employee. The ad tied Scott’s Democratic opponent, Charlie Crist, to Michael Bloomberg, and accused the candidate of supporting the former New York City mayor’s “gun control agenda.” (Bloomberg provides funding to Everytown for Gun Safety, whose 501c3 arm makes grants to The Trace.)

“I remember seeing people from OnMessage work on this ad,” the former OnMessage employee said. Yet none of the NRA’s 2014 Florida expenditures was attributed to OnMessage. (It is not clear if there was any coordination in this race, but in Florida, coordination is generally permissible.)

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In 2016, the NRA’s federal election payments to Starboard ballooned to $40 million, a massive portion of the gun rights group’s total independent spending for the year, which came to almost $53 million. That cycle, when Johnson was defending his Wisconsin Senate seat for the first time, his campaign paid OnMessage almost $4 million. The payments stopped in August. Just over two months later, the NRA aided in the re-election effort, and tapped Starboard for nearly $200,000 worth of advertising.

The sum the NRA paid to Starboard in 2016 was split between the group’s Political Victory Fund and its Institute for Legislative Action. The transactions paid by the ILA accounted for roughly $23.4 million. Unlike the Victory Fund, a free-standing organization affiliated with the gun group, the ILA is a component of the NRA’s nonprofit corporation, which means its financial records are subject to oversight by the Internal Revenue Service. In the NRA’s tax filings, it is required to disclose its top five independent contractors for any given year, and that includes contractors retained by its divisions, like the ILA. In 2016, Starboard was not included on the list, even though, based on what it received from ILA, it would have ranked as the NRA’s second highest-earning contractor.

“If Starboard was paid by the Institute for Legislative Action for services, then Starboard was a contractor, and if Starboard was one of the NRA’s largest contractors, then it should be listed on the NRA’s 990,” Marcus Owens, the former head of the IRS division overseeing tax exempt enterprises, said.

As far as the FEC and the public know, OnMessage did no campaign work for the NRA in 2016 — the firm is nowhere mentioned in the group’s filings. More than half of the money the NRA paid Starboard that year, about $25.7 million, was spent in the service of electing Donald Trump to the presidency. After the Republican candidate defeated Hillary Clinton, however, OnMessage celebrated the work it produced for the NRA.

On January 20, 2017, the day of Trump’s inauguration, Brad Todd wrote a blog post on OnMessage’s website. “When no other outside group on the Republican side of the aisle believed in this race, the NRA made its biggest investment in any Presidential election,” he wrote. “They went in early and they went in big.” Todd added, “OnMessage Inc. was proud to partner with the NRA and produce their ads in this election.”

A month later, OnMessage received a Reed Award for an NRA spot it had created the previous year. The category was “Best Ad For Independent Expenditure Campaign — Presidential,” and the winning entry features a woman in bed who is awakened by a burglar. In one hand she grips a phone, and with the other she opens a gun safe, which suddenly disappears before her eyes. “Don’t let Hillary leave you protected with nothing but a phone,” a narrator warns. Currently, the ad can be viewed on OnMessage’s website, by clicking the tab labeled “Our Work.”