Damning Ethics Report Solves the Big George Santos Question: Where the Money Came From

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The House Ethics Committee’s blistering report on Rep. George Santos lays out a number of violations so reckless and overt that they border on absurd. But the report also shows the congressman’s direct involvement in one of the biggest campaign finance grifts in U.S. history—and investigators may have finally answered one of the most tantalizing questions about Santos: Where did his money come from?

It turns out, the answer may have been tucked into a footnote and two appendixes listing Santos’ financial transactions.

To be clear, while the Ethics Committee saw serious potential legal problems with the source of hundreds of thousands of dollars that Santos loaned to his campaign, the report never closed the case. The committee cut off that investigation in deference to the Justice Department’s ongoing criminal probe, indicating additional charges may be on the way.

But The Daily Beast’s review of the committee report and its underlying evidence has found that House investigators actually did solve the mystery. In doing so, they uncovered what appears to be an illegal pass-through scheme involving hundreds of thousands of dollars in illicit contributions that Santos funneled to his campaign from business clients—perhaps without their knowledge.

Santos also appears to have taken the scheme a step further, personally reaping tens of thousands of dollars after he was elected to Congress.

The Daily Beast first reported the potential straw donor scheme last December, revealing the names of Santos business clients who were also major campaign donors. By Santos’ own admission at the time, the money he lent his campaign came from his company, the Devolder Organization, raising the specter that the “loans” were actually illegal pass-through donations, designed to skirt limits on individual contributions.

The Ethics Committee has now confirmed that reporting, along with the suspicions of campaign finance law experts who raised flags about the source of Santos’ “personal loans,” as well as the straw donor scheme. (The report also confirms The Daily Beast’s reporting last month that the fake $500,000 loan Santos made in March of last year was, eventually, real money—albeit from unknown sources.)

The committee said that its “unprecedented” investigation—roughly nine months in the making—turned up “substantial evidence” of wrongdoing by Santos. In an accompanying report, the investigative subcommittee detailed a staggering array of potential violations, including campaign finance infractions, ethical infringements, criminal fraud and theft. The probe’s scope, per committee rules, was limited to Santos’s activity in office and his candidacy, and did not examine every potential wrongdoing—including a referral to investigate his previously undisclosed marriage to a Brazilian woman, which The Daily Beast first reported last December.

“Representative Santos sought to fraudulently exploit every aspect of his House candidacy for his own personal financial profit,” the committee said in a statement. Still, the report stopped short of calling for Santos’ expulsion, leaving that option to the full House—a decision that the Ethics Committee Chairman suggested Thursday was made to expedite removal.

But The Daily Beast can now connect details in the House report to paint a more detailed picture of this scheme, involving nearly $800,000 in what the Ethics Committee lays out as illegal contributions, along with tens of thousands of dollars that Santos appears to have repaid himself through the campaign after his election last year.

Jordan Libowitz, communications director for watchdog Citizens for Responsibility and Ethics in Washington, said Santos “has proven himself to be a true icon of political grifting.”

“It’s now clear what we suspected for a long time—that the money was never Santos’s, and he was just passing it through to cover an illegal donation,” Libowitz told The Daily Beast. “But in a truly George Santos fashion, he added a new twist by using campaign donations to ‘repay’ himself for a loan he never made, adding a second grift so that he personally benefited, not just his campaign.”

Brendan Fischer, a campaign finance law specialist at watchdog Documented, said the report suggests that Santos may face still more criminal charges.

“This investigative report outlines astonishing levels of dishonesty, some of it criminal. The report also confirms what The Daily Beast has been reporting for several months now,” Fischer said. But the report “only hints at” the source of the six-figure loans, he said.

“Reading between the lines, it is apparent that DOJ is investigating potential straw donations to Santos’ campaign, and the House committee deferred to that probe,” Fischer said.

But the source of the campaign money is still in the report—you just have to know where to look.

According to the underlying documents in the appendixes, both Santos and his company, the Devolder Organization, had very little cash on hand throughout 2022—with totals of -$7.77 and -$10.82, respectively, in bank accounts at the start of September. Those accounts then suddenly saw hundreds of thousands of dollars flood in, followed almost immediately by hundreds of thousands of dollars transferred to the Santos campaign—hallmarks of pass-through contributions.

After Santos won his election, his campaign then transferred $20,000 to his private company. The transfer came when the company’s balance was in the negatives, the day after it bounced a $75 check.

But while bank statements show that the campaign transferred the money to the Devolder Organization, the campaign never disclosed that payment in its FEC statements, along with another $10,000 that same month, the ethics report said.

Santos prioritized those transfers to himself over his campaign’s other debts, which at the time included $22,000 in bonuses owed to staff, $30,000 owed to a consulting firm, and a $15,000 bonus for his campaign treasurer.

The underlying evidence, however, reveals the true source of the money—a Santos client The Daily Beast first named last December, tied to one of the wealthiest, most influential lawyers in Florida.

Footnote 65 in the investigative subcommittee (ISC) report says that the six-figure payments to Santos all came from an unnamed “Individual 4” and an entity owned by a family member of Individual 4 (only identified as “Company 2”). That seems ambiguous enough, but a bank statement included in an appendix points to “Company 2” being an entity called “A-RU Holdings.” That company belongs to a Florida man named Alex Ruiz, according to Florida business records. And his mother, Mayra Ruiz—a major Santos donor who previously told The Daily Beast that she was also a Santos client—additionally appears to be Individual 4.

Here’s what footnote 65 says:

“The transfers originated from Individual 4 and an entity owned by Individual 4’s family member, Company 2. The ISC found some evidence that Representative Santos provided some services to Individual 4 and Company 2; however, given the timing, amounts, and other circumstances of the payments, the ISC had serious questions regarding whether these payments were intended to benefit Representative Santos’ campaign and thus were unlawful excessive contributions. The ISC was unable to further pursue these questions due to DOJ’s specific deferral requests.”

An appendix to the report contains bank statements for the Devolder Organization at the time. Those statements show that the company carried a balance of less than $50 between June and October, with no financial activity. Then, on Oct. 3, the company received $250,000 from A-RU Holdings. (The company’s name, with the $250,000 transaction, is listed on page 7 in Appendix B, Part 2, of the ethics report.)

The same month as the $250,000 transaction, Santos drew from this payment to cut campaign contributions from his company account totaling $215,000—one for $90,000, and one for $125,000—while receiving no further payments from any source.

In other words, the only source for those contributions is the $250,000 from Ruiz’s company. And that rules out any other company being “Company 2.”

In an interview with The Daily Beast last December, Mayra Ruiz confirmed that she and related family entities were Devolder Organization clients. Only three Ruiz family members have donated to Santos: Mayra, and two of her children, Alex and Cristina. Federal Election Commission filings show that only Mayra is a “major donor,” as the report described Individual 4.

Alex Ruiz is the son of Mayra Ruiz and her ex-husband, John Ruiz, a Miami personal injury lawyer who parlayed his Medicare payer recovery business into a multibillion-dollar IPO that flopped a few months before Santos was elected. Shortly before his election, Santos brought Mayra Ruiz together with another business client The Daily Beast named, Raymond Tantillo, to broker a yacht sale, as The New York Times reported.

Neither Mayra Ruiz, nor Alex, nor Cristina responded to The Daily Beast’s comment requests.

While the ISC said it found some evidence that Santos had provided some legitimate business services, “the timing, amounts, and other circumstances of the payments” raised “serious questions” about whether these payments were actually political contributions.

Those circumstances, the report notes, include the fact that Santos did not identify the Ruizes or their companies as business clients on his financial disclosures. Crucially, the report adds—in footnote 209—that “Individual 4 provided information to the Committee indicating that she believed her funds were political donations to his campaign and other political committees.”

That information is connected to another company controlled by Santos: RedStone Strategies. RedStone, whose connection to Santos was first reported by The Daily Beast, appears in the Santos indictment as an entity that Santos falsely presented to donors as a political fundraising group. However, House investigators could not further that line of inquiry, saying—as they did in multiple footnotes related to these contributions—that they had deferred to specific requests from the Justice Department.

Despite the deferral, the report introduced a slew of evidence into the public domain, such as the $250,000 transfer for A-RU Holdings.

The bank statement shows that while some of the $250,000 went to a number of relatively petty personal costs that month, the vast majority—$215,000—went to the campaign. (The day of one $125,000 loan, the Devolder Organization also paid someone $2,900—the maximum amount of a campaign donation.) The bank statements show that Devolder received no other income that month, and none at all until November.

The $250,000 was ostensibly the up-front payment for a capital introduction contract between the Devolder Organization and A-RU Holdings. The contract, included in the report, stated that Devolder would help A-RU Holdings secure $255,000,000 in investments over the next 12 months, and would receive another $750,000 at “conclusion of project.”

But the Devolder bank statements in the report do not itemize any further payments from A-RU Holdings, and it’s unclear whether Santos provided any services or ever fulfilled the contract.

Then, on Oct. 4—the day after Alex Ruiz paid Santos that $250,000—Mayra Ruiz (identified in the report as Individual 4) transferred $100,000 to another Santos company, RedStone Strategies, the report says. However, this was part of an allegedly criminal fundraising scheme that prosecutors outlined in their first Santos indictment, in May.

Again, the ethics report indicates “Individual 4” was under the impression she was making a lawful political donation. The $100,000 payment came after she received an email regarding her “pledge for $100,000 to Redstone Action to help elect George Santos to Congress representing NY-03,” the report said. In reality, that super PAC did not exist.

But the report shows what prosecutors have so far kept close to the vest—this $100,000 actually ended up in the campaign’s bank account.

The day after Mayra Ruiz apparently paid $100,000 to RedStone Strategies, that same amount of money was transferred from RedStone’s bank account to Santos’ personal bank account, the report notes. Days later, Santos cut a $100,000 check to his campaign, effectively washing the money as a personal contribution. (Candidates are allowed to give unlimited amounts to their own campaigns.)

“While there is evidence that some funds solicited on behalf of RedStone were used to benefit Representative Santos, this appears to have been an excessive campaign contribution masked as a personal loan by Representative Santos,” the ethics report noted, adding that it could not pursue the question further “due to investigative concerns raised by DOJ.”

Fischer concurred that the report indicated Mayra Ruiz was “Individual 4,” adding that the Ethics Committee “effectively concluded that Santos had violated the straw donor ban,” but deferred to the ongoing DOJ probe.

“In short, there may be more criminal charges coming in this Santos saga,” Fischer said.

Ironically, some of the evidence of the pass-through scheme came from Santos’ own legal counsel—but it was presented as proof that Santos had contributed the money from his personal funds.

The ISC provided a letter that Santos’ counsel—Charlie Spies, of Dickinson Wright—sent to the FEC in March, in response to campaign finance complaints.

“Respondent’s loans to his Campaign were made from his personal funds,” Spies wrote in the letter. He noted that Santos had provided “consulting services for multiple clients,” calling them “bona fide” services for which he received more than $1 million. Spies argued that Santos had the right to directly contribute his company’s cash “as membership draw by a sole proprietor of the entity.”

But the bank statements that Spies provided to support the claims undercut the protestations of innocence.

Notably, all of Santos’ campaign loans came in September and October. And the “more than $1 million” in Santos’ 2022 revenue was not distributed evenly across the calendar year. Instead, the payments were almost entirely in close proximity to the election. In fact, all of the $667,960 that the Devolder Organization made in consulting fees during 2022 came after Oct. 3, according to financial statements included with the report. (Those statements curiously also list a $255,000 “referral fee” as a Devolder expense, not income.)

It’s a similar story with Santos’ personal funds. The September 2022 statement from his Wells Fargo checking account, which Spies provided, shows a negative balance of -$7.77 at the beginning of the month. Then, on Sept. 16, Santos clocked a $450,000 payment, which Spies attributed to “Individual 4.” Almost all of that ended up in the campaign. Four days later, Santos cut a $300,000 check to his campaign, with another $100,000 check going out two days after that. He had no other deposits after that payment, and ended the month with about $25,000 in the account.

Page 39 of the ISC’s report says that the $450,000 is related to “a partially executed promissory note” between the Devolder Organization and “Individual 4.” But the report adds that investigators had “serious questions regarding this payment,” specifically given its proximity with the loans.

Spies provided the FEC with another series of bank statements, these from the Devolder Organization. Those statements, however, were also included by the committee, showing that Spies heavily redacted them in key ways.

For instance, Spies redacted the campaign’s $20,000 transfer to the Devolder Organization, obscuring that transaction from the FEC. However, the transfer is visible to the public in the statement that the committee provided independently in its report, which the committee attributed to the campaign.

Spies, in fact, redacted almost everything. But he did include two payments to the company in December. One of the payments—$99,960—came from the Devolder Organization itself, and appears canceled out by two $100,000 payments the company made to a Santos donor and client that day. The Devolder Organization paid multiple five-figure checks to other entities soon after that.

Santos has blamed allegations of wrongdoing on his former treasurer, Nancy Marks, and his attorney, Spies, did the same in his letters to the FEC. Last month, Marks pleaded guilty to helping Santos orchestrate the fake $500,000 loan, and will be a key prosecution witness against him.

An attorney for Santos didn’t return The Daily Beast’s comment request.

But the ethics report suggests that this won’t just be Marks’ word against Santos’. The committee provided additional documentation that demonstrates Santos was actively engaged and aware of his campaign’s financial activity and statements. The documentation includes emails showing that Santos regularly reviewed the campaign’s internal accounting, asked Marks for financial statements, and received weekly financial reports.

The ethics report makes it increasingly likely that Santos will be expelled from Congress. And while he still refuses to resign, he too appears to have seen the writing on the wall. On Thursday, he announced that he would not seek re-election in 2024.

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