Representative George Santos has spent his campaign money in plenty of conspicuous ways, from lavish hotel stays in Las Vegas and Palm Beach, Fla., to an unusual slew of payments for exactly $199.99 — two cents below the threshold where receipts would be required.
But deep within Mr. Santos’s campaign filings, The New York Times found another eye-catching number: $365,399.08 in unexplained spending, with no record of where it went or for what purpose.
The mysterious expenditures, which list no recipient and offer no receipts, account for nearly 12 percent of the Santos campaign’s total reported expenses — many times exceeding what is typical for congressional candidates. Fellow New York House members, for example, failed to itemize between zero and 2 percent of their expenses this past cycle.
Without explanations for each expenditure in the reports filed with the Federal Election Commission, it’s impossible to determine if Mr. Santos spent campaign funds on legitimate election-related purposes.
Election law experts said that the $365,000 in unexplained expenses was not necessarily illegal but suggested a pattern of remarkable sloppiness, if not an attempt to cover up improper spending that violated campaign finance laws.
The unexplained spending is among a litany of irregularities found in nearly every aspect of how the Santos campaign handled its finances, The Times found.
Several donors said in interviews that the Santos campaign or associated groups misrepresented how much they gave. Campaign finance documents show discrepancies between what the Santos campaign reported having spent and what recipients, such as other Republican candidates, reported having been given.
When the campaign has amended its filings, as it has 36 times, some payments have gone up or simply disappeared. And though other New York candidates list $26,000 in donations from Mr. Santos, the contributions do not appear in his filings at all, The Times’s analysis showed.
Bill McGinley, a lawyer for one of the donors and a former general counsel to the National Republican Senatorial Committee, examined some of Mr. Santos’s contribution reports and said they were “all over the place and do not make any sense.”
“I’ve never seen anything like this,” he added.
The shifting costs of a sushi meal
Mr. Santos, a Republican elected in November, is facing several criminal and ethics inquiries after revelations that he lied about his upbringing, education and work history. His fabrications have led to numerous calls for his resignation and suspicion over how he raised and spent his campaign money.
The unexplained $365,000 in his campaign disclosures is a vivid example.
Mr. Santos launched his second bid for a New York House seat in early 2021, just months after he lost to Representative Thomas R. Suozzi.
From the beginning of his campaign, Mr. Santos spent extravagantly, traveling far outside his district to attend fund-raisers and other events, though he had no declared primary challenger. In the first three months of 2021, for example, he reported spending more than $5,000 on airfare and hotel stays in West Palm Beach and Washington, D.C.
By late 2021, as Mr. Santos built his campaign war chest, his spending continued to pick up. He spent nearly $90,000 in December, making trips to Kansas and Michigan, according to reports filed in January 2022.
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Those two trips were memorialized in several itemized expenditures dated to Dec. 19. The filings show that Mr. Santos spent $266.66 on five different Ubers and taxis, as well as $828.78 on stays at the Hyatt Regency in Wichita, Kan. He also itemized $140.54 he spent on food, including $60.54 at Tokyo Sushi and Grill in Auburn, Hills, Mich.
But by April 2022, Mr. Santos seemed to have adopted a new accounting strategy. He added more than $250,000 in more than 1,200 payments to “Anonymous,” nearly all for $199.99. Some of the payments, reported earlier by The Washington Post, were added to older spending reports; none had any description other than the dates.
Mr. Santos also used the April filings to change some of his previously recorded expenses, retroactively raising the cost of some of them to $199.99. The cost of the five Uber and taxi rides from Dec. 19 rose to $445.22, and the Tokyo Sushi and Grill bill had gone up to $199.99. There were also three new expenses on that date, each for $199.99, paid out to “Anonymous.”
In May, Mr. Santos changed his reports again. He wiped out all the individual line items paid to Anonymous, as well as the meal at Tokyo Sushi, but the filing still included the $250,000 in spending, with no further details, dates or explanation.
In the latter stages of the campaign, Mr. Santos itemized small sums spent for gas, lunch and office supplies. But he also continued to spend money without providing receipts or identifying the date or recipient, with the unitemized spending growing to $365,399.08.
Campaigns do not need to itemize or provide receipts for expenses of less than $200. But if they spend more than $200 with a single vendor — even spread over several transactions — they would be required to go back and itemize each expenditure.
If Mr. Santos were to suggest that the unexplained $365,000 was spent in increments of $200 or less, he would have had to do business with more than 1,800 separate entities — many times more than the roughly 270 he listed in itemized reports.
Experts said that would be implausible and called the spending concerning, particularly in concert with his other campaign finance issues.
Saurav Ghosh, a director with the Campaign Legal Center, a watchdog group, said that it “beggared belief” that each of the expenditures would have been made at different vendors and that none of them would have totaled more than $200, adding: “It again falls into the category of reporting that is so ludicrous that it’s completely wrong, and suggests that they’re covering up how they actually spent their money.”
Mr. Santos’s director of communications declined to comment. Joe Murray, his lawyer, said that it would be inappropriate to comment given ongoing investigations into Mr. Santos.
The degree to which Mr. Santos has seemingly stretched campaign finance rules underscores the challenge that the F.E.C. faces in its effort to monitor hundreds of federal campaigns and an exploding number of political committees across the country each election cycle.
While the agency flagged scores of issues in Mr. Santos’s campaign filings, such as excessive contributions and unexplained increases in the number of itemized disbursements, it does not appear to have looked into the $365,399.08 that Mr. Santos said he spent without any explanation. And even if it did, the spending would be difficult to parse.
“I don’t know how you even determine that it’s a lot of different expenditures,” said Kenneth Gross, the former head of the F.E.C. general counsel’s enforcement division. “You’re just stabbing around in the dark.”
The unreported $95,000
The Santos campaign’s accounting of the political donations it received is also littered with discrepancies. Some donors say the amounts reported by the campaign do not match what they gave.
Several donors interviewed by The Times received letters from the F.E.C. asking them to explain donations that appear to be above the legal threshold.
But the issues went beyond that. In one case, the campaign reported 24 separate transactions from one donor that totaled nearly $20,000, in excess of what is legally allowed. All are linked to the donor’s former address, but they use different versions of the donor’s name — making it appear as if the money is coming from two different people. Some of the contributions incorrectly refer to the donor’s having a spouse. The donor, who asked not to be identified, said his own records indicated that he gave around $13,000 to the campaign and an associated committee in six transactions through that period.
Another generous Santos donor, Andrew Intrater, said that his personal financial records show that he donated around $250,000 to the campaign and various Santos-connected political groups during the 2022 cycle. But not all the donations in the filings matched Mr. Intrater’s records, he said.
Mr. Intrater gave $175,000 to Rise NY PAC — a voter registration effort he later learned was run by Mr. Santos’s sister and Nancy Marks, his campaign treasurer — only to later discover that $95,000 of that was not reported by the group in the financial reports required by the state. (The PAC recently updated its filings to reflect the missing donations, which go back to 2021.)
Mr. Intrater also made another $25,000 donation to a Santos-affiliated political entity called RedStone Strategies. Mr. Intrater made the donation after a RedStone representative, at Mr. Santos’s prodding, told him and other donors that RedStone was raising $1.5 million for a hefty television ad buy on behalf of Mr. Santos.
But it turned out that these donations — in fact the entire entity — were never registered and disclosed with the F.E.C. as would be required for such activity. The Times has reported that there is no sign that this group, which used the same co-working space address as Mr. Santos’s campaign and business headquarters, actually spent any money on advertising or other political activity.
Mr. Intrater says he has provided information about the donations to the Department of Justice.
Scrutiny over donations
Another mystery revolves around fees that Mr. Santos paid to WinRed, the donation-processing digital platform used to collect mostly small-dollar contributions to candidates.
WinRed charges a standard fee (as of last year, 3.94 percent) on every donation, which is paid by the campaign or committee that receives the money. But Mr. Santos seemed to suggest a different arrangement that was reported earlier by NBC News.
Mr. Santos, who received $796,238.26 from WinRed, according to that company’s F.E.C. filings, should have paid roughly $33,000 in fees. Instead, his filings to regulators show payments adding up to more than $206,000 — an appropriate fee only if Mr. Santos had taken in roughly $5 million.
The overpayment leaves roughly $173,000 in fees unaccounted for.
In a statement, WinRed said it “proactively reached out to the campaign to ensure its agency fees were being reported accurately.”
Paul S. Ryan, an expert in campaign finance law, suggested that Mr. Santos may be “inflating the payments to WinRed and pocketing them for personal use,” something that he said the F.E.C. might not notice because WinRed expenses are so common among candidates.
“The best way to avoid scrutiny is to file reports that appear plausible on their face,” he added.
The accounting problems extend to Mr. Santos’s reported generosity to other candidates, records show. During the campaign, his primary campaign committee and leadership PAC gave more than $180,000 to other campaigns and committees. But the amounts and names listed on his filings did not always match what his recipients recorded, The Times’s analysis found.
Mr. Santos’s leadership fund, GADS PAC, reported sending two donations of $2,900 each in July of last year to Michelle Bond, a Long Island Republican who lost a primary challenge to Representative Nick LaLota. But Ms. Bond’s records show a single donation of $5,000 from the PAC in August, $800 less than what Mr. Santos had reported.
Mr. Santos also sent two separate $2,900 contributions from his leadership PAC to Blake Masters’s unsuccessful Senate bid in Arizona, according to filings from Mr. Santos and Mr. Masters.
Mr. Santos’s campaign reported making another donation, of $2,000, to Mr. Masters, but that amount does not show up in Mr. Masters’s filings. That contribution lists an address in the Florida Panhandle that does not appear to exist.
Mr. Masters’s campaign confirmed it had no records of such a payment.
The inconsistent bookkeeping extended to other contributions made by Mr. Santos.
New York State campaign finance records show that state and local candidates and committees reported nearly two dozen donations from Mr. Santos and his PACs between 2020 and 2022, totaling more than $26,000. But Mr. Santos’s own filings with the F.E.C. show no record of the donations.
Jay Root contributed reporting, and Susan C. Beachy contributed research.