minimum and maximum penalties for conduit
convictions will apply and result in enhanced
fines. See Example 2 for an illustration of such
a computation.
(d) Example 4: Fundraiser possessing special skill
Factual Scenario: The defendant is a professional federal
fundraiser who has attended several training courses
sponsored by the Federal Election Commission and is
therefore intimately familiar with the requirements and
prohibitions of the Federal Election Campaign Act.
The fundraiser has been retained by a federal
candidate. He approaches a wealthy donor who he
knows has given the candidate the maximum amount
permitted by FECA, and suggests that the donor make a
further contribution by permitting the candidate and his
staffers to use the donor’s personal jet for campaign
purposes and without billing the campaign for its use.
The ensuing illegal “in-kind” contribution is valued at
$225,000, for which the fundraiser is liable as an aider
and abettor. The aggregate value of the offense is
$225,000, consisting of one felony violation of 52 U.S.C.
§ 30116(a)(1)(A),
charged
under
Section
30109(d)(1)(A)(i) and 18 U.S.C. § 2.
Total Offense Level: 20
Base Offense Level under § 2C1.8(a): 8
Enhancement for value between $150,000 and
$250,000 under § 2B1.1(b)(1)(F): 10
Enhancement for number of transactions under
§ 2C1.8(b)(4) (one § 30116 violation): 0
Enhancement for use of special skill under § 3B1.3:
2
190
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