FEDERAL ELECTION COMMISSION In the mater of Republican Party of Minnesota Anthony G, Suton, individually and MUR No. _ in his capacity as Treasurer ‘COMPLAINT 1. Citizens for Responsibility and Ethis in Washington CREW") and Melanie Sloan bring this complaint before the Federal Election Commission ("FEC") seeking an immediate investigation and enforcement ation agains the Republican Party of Minnesota and Anthony G, Sutton, individually and as treasurer of the Republican Party of Minnesota, for direct and serious violations of the Federal Election Campaign Act (“FECA”). Complainants 2. Complainant CREW is a non-profit corporation, orgaized under section 501(¢X(3) of the Internal Revenve Code. CREW is committed to prtcting the right of cizens to be informed about the atvitis of govemment officials and to ensuring the integrity of government officials. CREW is dedicated to empowering citizens tohave an influential voce in ‘government decisions and inthe governmental decision-making process. CREW uses a combination of research tigation, and advocacy to advance its mission. 3, Infurteranee ofits nssion, CREW seeks to expose unethical and legal conduct of those involved in government. One way CREW does this is hy ecuating citizens regarding the integrity ofthe electra process and ou system of government. Toward this end, CREW ‘monitors the campaign finance activites of those who run for Federal oie and publcizes those ‘who violate federal campaign finance laws through its website, press releases and other methods‘of distibution. CREW also files complains withthe FEC when i discovers violations ofthe FECA. Publiicing eampaig finance violators and filing complaints with the FEC serves CREW's mission of keeping the public informed about individuals and enties tat violate campaign finance laws and detering future violations of campaign finance law. 4. Imorderto assess whether an individual, candidate, poical committee of ober regulated entity is complying with federal campaign finance law, CREW needs the information contained in receipts and disbursements repr that political committees must file pursuant to the FECA, 2USC. §434(a)2); 11 CER. § 104.1, CREW is hindered int programmatic tivity when an individual, candidat, politcal committer, or other epulated ent fis to Aiselose campaign finance information in repons of receipts and disbursements equted by the FECA, 5. CREW relies onthe FEC’s proper administration of the FECA’s reporting requirements because the FECA-mandated report of receipts and disbursements ae the only source of information CREW can use o determine if candidate, politcal commits or other ‘regulated entity is complying withthe FECA. ‘The proper administration of the FECA’s reportirg requirement inchudes mandating that all reports of receipts and disbursements required by the FECA are properly and timely filed with he FEC. CREW is hindered in ts programmatic tivity when the FEC fas o propery administer the FECA’s reporting requirement 5. Complainant Melanie Sloan isthe exceutive director of Citizens for Responsibility and Ethics in Washington, a citizen ofthe United States, and a reitered voter and resident ofthe District of Columbia. As registered voter, Ms, Sloan is ented to receive information contained in reports of receipts and disbursements required by the FECA, 2 US.C. § 434(a)@); 11 CAR. § 104.1, Ms, Sloan is harmed when a candidate politcal committee orother regulated entity fails to eport campaign finance activity as required by the FECA. See FEC, Akins, 524 US. 11, 19 (1998), quoting Buckley v. Valeo, 424 U.S. 1, 66-67 (1976) (political committees must disclose contributors and disbursements to help voters understand ‘who provides which candidates with financial support). Ms. Sloan is futher harmed when the FEC fails to properly administer the FECA’ reporting requirements, iting her ability to review campaign finance information Respondents 7. The Republican Pay of Minnesota is state committe within the meaning of2 USC. § 43105). 8 Anthony G. Suton was the teasurer ofthe Republican Party of Minnesota fom May 14, 2007 through July 10, 2009 and the chairman of the Republican Party of Minnesota ‘rom July 1,2009 through December 2, 2011 actual Allegations 9. On August 15, 2011, the FEC accepted a signed conciliation agreement with the ‘Republican Party of Minnesota in Matter Under Review 5926 (atached as Ext 1), Inthat conciliation agreement, dhe Republican Party of Minnesota acknowledged that it had filed to disclose atleast $994,319 in oustanding debs fo vendors during 2006 in violation of 2US.. § 434(6), Exhibit 1 at Section IV, 19. To resolve tis violation of 2 US.C. § 4346) the Republican Pary of Minnesota agreed to pay acivl penalty of $170,000. Exhibit | at Seton VL. The Republican Party of Minnesota alto expressly agreed to ease and desist fom farther violations of2 US, §434(6). Exhibit at Seetion VIL 1 10. OnDecember 20,2011, the Republican Panty of Minnesots edits December “Monthly Report with the FEC (attached as Exhibit 2), The December Monthly Report indicates