Stephen Bannon has led an itinerant life -- living at various points in either Southern California or Florida or New York or Washington, D.C., or London. But one address -- 8383 Wilshire Boulevard, Suite 1000 in Beverly Hills, CA -- has been a fixture in Bannon’s business and financial transactions.

According to California public records and media reports, the white nationalist website Breitbart was at one point registered at that address. So, too, was Glittering Steel, a film production company helmed by Bannon. As were Freemark Financial, a business management firm that handled Bannon’s financials; the Government Accountability Institute, a Bannon-tied right-wing group that purports to investigate government corruption; and a handful of other Bannon-connected companies, including Bannon Strategic Advisors Inc., and Bannon Film Industries Inc.

According to The Daily Beast, Freemark Financial, run in part by Steves Rodriguez, “is managing the money of” Bannon and has also worked for Breitbart, as well as the London-based data modeling firm Cambridge Analytica (on whose board Bannon once sat) and Glittering Steel. Bannon has reportedly told utility officials in the past to mail “bills to the office of his business manager on Wilshire Boulevard in Beverly Hills,” according to The Washington Post.

Seemingly, all Bannon-connected companies are currently -- or were, until recently -- registered to the same Beverly Hills address, and the financials are managed by Rodriguez and his partners at Freemark Financial.

Federal Election Commission (FEC) reports also show Make America Number 1 -- a pro-Trump super PAC ran by Bannon and Trump confidante Rebekah Mercer -- paid millions of dollars both to Glittering Steel and to Cambridge Analytica, which was also used by Donald Trump’s presidential campaign. And though Cambridge Analytica has no publicly listed address in California, the super PAC payments were curiously sent to the Bannon-centered Beverly Hills address, prompting legal complaints of campaign finance violations. Newly amended FEC reports show Make America Number 1 continued to pay Cambridge Analytica at the Wilshire Boulevard address throughout the fall, raising a host of questions about whether financial transactions centered around Bannon's office are all above board.

Make America Number 1's Payments To Cambridge Analytica Went To … Bannon’s Beverly Hills Office

Rebekah Mercer is a multimillionaire GOP mega-donor with ties to Bannon and several other allies in Trump’s inner circle, including Kellyanne Conway, David Bossie, and Trump himself. She and her father Robert are major investors in Breitbart News (to the tune of $10 million) and the Government Accountability Institute, and they’ve employed Glittering Steel -- all Bannon-affiliated groups.

Robert Mercer is also the principal owner of Cambridge Analytica, which specializes in “political microtargeting,” and Rebekah Mercer reportedly “used her influence in Trump’s circle to ensure that Cambridge Analytica … would be brought on board by Trump’s campaign team.” The Trump campaign ultimately utilized Cambridge Analytica’s services directly.

Rebekah Mercer in September assumed all control of the pro-Trump Make America Number 1 super PAC, which was previously run by Kellyanne Conway and later David Bossie, before each joined the Trump campaign. The super PAC’s biggest donor was Robert Mercer.

FEC filings for June, August, September, and October from the Make America Number 1 super PAC (run by Rebekah Mercer and largely funded by Robert Mercer) show millions of dollars going to Cambridge Analytica (owned and invested in by the Mercers) for “survey research,” “data acquisition,” “media” and “campaign management consulting [services].” These filings also show Make America Number 1 made regular payments to Glittering Steel for “video production.”

Cambridge Analytica’s website lists U.S.-based addresses in Washington, D.C., and New York. A California business public records search returns no results for Cambridge Analytica, and a Delaware business public records search (that lists Cambridge Analytica’s registration) does not provide address registration. Yet, the FEC filings show the Mercer super PAC’s payments to Cambridge Analytica were all sent to the Bannon-centered 8383 Wilshire Boulevard address. It is unclear where or if Cambridge Analytica publicly lists this Beverly Hills address as its own.

According to The New York Times, Bannon sat on Cambridge Analytica’s board until last August, “when he joined the Trump campaign.” Bannon’s spokesperson told the Times that Bannon no longer has “‘financial involvement’” with the firm.

So, why were Mercer-approved payments for a Mercer-invested company sent to an address that’s affiliated with Bannon -- and has seemingly no public connections to Cambridge Analytica itself? Were the payments (especially the ones made after August) earmarked for Bannon, though his own spokesperson said he stepped away from Cambridge’s board in August? The shady web of connections among the Make America Number 1 super PAC, Cambridge Analytica, and Stephen Bannon prompted an FEC complaint that raises more questions than answers.

Campaign Legal Center Filed Complaint Alleging “Illegal Compensation To Stephen Bannon By Mercer-Backed Super PAC”

On October 6, the campaign finance watchdog Campaign Legal Center (CLC) filed a complaint with the FEC alleging that the Make America Number 1 super PAC violated FEC laws by making illegal “in-kind contributions to Donald J. Trump for President, Inc. in the form of compensation for personal services rendered to the campaign ... and ‘coordinated communications.’” The complaint also noted:

• The individuals who formed, fund and lead Make America Number 1 were
  responsible for Trump hiring as campaign manager Kellyanne Conway, previous
  president of the super PAC; hiring Stephen K. Bannon as campaign CEO, whose
  projects have long been funded by the individuals who formed, fund and lead
  Make America Number 1; and Make America Number 1 appears to have covered
  the salaries for both Conway and Bannon as they work for the Trump campaign.
• At the request of Make America Number 1’s founders and funders, the Trump
  campaign has begun contracting with a data firm owned by Make America
  Number 1’s founders and funders and whose board includes Bannon, running
  afoul of the “common vendor” rule designed to preserve the independence of
  campaigns and political committees.

Then, in December, the CLC “presented new evidence to the Federal Election Commission alleging that the super PAC Make America Number 1 illegally compensated Steve Bannon’s work as Donald Trump’s campaign CEO.” Specifically, the CLC’s new evidence claimed that the super PAC’s payments to Cambridge Analytica were meant as payment for Bannon, not the company at large.

“If a Mercer-backed super PAC subsidized Bannon’s work for the Trump campaign,” the complaint notes, “it violates federal campaign finance law.” 

Importantly, before the October CLC complaint was filed, Make America Number 1’s July monthly and August monthly FEC filings showed that payments to Cambridge Analytica were sent to the Wilshire Boulevard address. Then, after the CLC filed its initial complaint, the super PAC’s payments to Cambridge Analytica (and Glittering Steel) in its September monthly, October monthly, and pre-general election filings started going to new addresses in Virginia. But when the Make America Number 1 super PAC later amended those reports after the presidential election, it changed the Virginia addresses back to the Wilshire Boulevard address.

In line with the Campaign Legal Center’s FEC complaint, the Make America Number 1 payments to Cambridge Analytica increasingly look like (potentially illegal) payments to Bannon.

When considering that the FEC reports were amended (as recently as February 21, no less), more questions arise: Why did the super PAC start sending Cambridge Analytica payments to a Virginia address (after the CLC complaint), only to change them back later to Bannon's address? If those payments were earmarked for Bannon, as the CLC alleges, did they continue after he stepped down from the board, given that the amended FEC reports show payments to Cambridge Analytica (at the Wilshire Boulevard address) well past August? What business ties, if any, does Bannon still have with Mercer-backed companies, and if so, do conflict-of-interest laws apply, given that he is a senior White House official?

Though it’s been documented that Bannon has “lived as a virtual nomad … with no fixed address,” as described by The Washington Post, questions abound about what, if any, legal violations may be looming over the millions of dollars coming into his shady Beverly Hills address.