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20 - ORGANIZATIONS/PRIVATE/Cambridge Analytica.md
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@ -108,7 +108,7 @@ relations:
start: 2017-05
end: 2020-10-02
role: "formal investigation into data analytics in political campaigns"
fn: 38
fn: 39
- type: subject_of
with: "[[Senate Select Committee on Intelligence]]"
end: 2020-08-18
@ -158,33 +158,35 @@ The Bolton PAC's payments to the company began on July 7, 2014 with $25,000 for
Kaiser told the Senate committee that discussion of a commercial offer to the Trump campaign began in May 2015, that she and Nix met Bannon in Washington in September 2015, that [[Donald Trump]] telephoned Bannon during the meeting and directed that Nix and Kaiser come to New York to meet [[Corey Lewandowski]], and that "eight or ten weeks" of contract negotiations followed without result.[^27] Bannon told the committee he had no recollection of the call.[^27] Kaiser also said that almost every client meeting she had with a political figure was preceded by an introduction from Bannon, Rebekah Mercer or [[Kellyanne Conway]], whom the committee described as an advisor to the Mercers at the time, and that Conway was closely involved in moving the company from the Cruz campaign to the Trump campaign.[^28]
The committee recorded that the Cruz campaign spent about $5.8 million on the company and the campaign of [[Ben Carson]] more than $430,000, citing a [[CNN]] report, and that within a week of Cruz leaving the race the employees working on his campaign began moving to the Trump campaign.[^27] [[Rick Gates]] told the [[Federal Bureau of Investigation]] that the campaign decided shortly after the Republican National Convention to use the company, that the [[Republican National Committee]] did not want to use it, that [[Brad Parscale]] was reluctant, that [[Jared Kushner]] wanted to use it and negotiated a package with payment at the end of the campaign.[^22] Kushner told the committee that the Mercers aggressively advocated use of the company and that the campaign engaged it to secure the Mercers' support.[^22] Parscale said he decided to hire the company in June 2016 after approval from [[Paul Manafort]] and Kushner, that he declined its offer of "psychographic profiling" services, and that he used Republican National Committee data rather than the company's data.[^22][^29]
[[Brad Parscale]] told the committee that the campaign's polling data was ingested into a visualization tool with the help of Cambridge Analytica developers, and that the tool was available on an iPad that Parscale carried.[^29]
The committee obtained a campaign data team presentation of August 22, 2016 with a slide depicting data flowing in both directions between the campaign and Cambridge Analytica, with the company's node titled "Digital Media Psychographic Analysis," and another slide showing arrows between its "Psychographic Analysis" and both the Republican National Committee's "GOP Data Center" and the campaign's San Antonio operation, which it called "Project Alamo."[^29] The committee wrote that documents it obtained suggested that the company's data may have been used in support of the campaign and that the campaign may have leveraged its psychographic analysis capabilities.[^29] Gates told the FBI that he later learned campaign data was transmitted to and analyzed in the [[United Kingdom]], which concerned him.[^29] Kaiser said that Project Alamo was "built completely from scratch" from the Republican National Committee's Data Trust database and purchased data sets.[^29]
The committee recorded that the Cruz campaign spent about $5.8 million on the company and the campaign of [[Ben Carson]] more than $430,000, citing a [[CNN]] report, and that within a week of Cruz leaving the race the employees working on his campaign began moving to the Trump campaign.[^27] [[Rick Gates]] told the [[Federal Bureau of Investigation]] that the campaign decided shortly after the Republican National Convention to use the company, that the [[Republican National Committee]] did not want to use it, that Brad Parscale was reluctant, that [[Jared Kushner]] wanted to use it and negotiated a package with payment at the end of the campaign.[^22] Kushner told the committee that the Mercers aggressively advocated use of the company and that the campaign engaged it to secure the Mercers' support.[^22] Parscale said he decided to hire the company in June 2016 after approval from [[Paul Manafort]] and Kushner, that he declined its offer of "psychographic profiling" services, and that he used Republican National Committee data rather than the company's data.[^22][^30]
The committee obtained a campaign data team presentation of August 22, 2016 with a slide depicting data flowing in both directions between the campaign and Cambridge Analytica, with the company's node titled "Digital Media Psychographic Analysis," and another slide showing arrows between its "Psychographic Analysis" and both the Republican National Committee's "GOP Data Center" and the campaign's San Antonio operation, which it called "Project Alamo."[^30] The committee wrote that documents it obtained suggested that the company's data may have been used in support of the campaign and that the campaign may have leveraged its psychographic analysis capabilities.[^30] Gates told the FBI that he later learned campaign data was transmitted to and analyzed in the [[United Kingdom]], which concerned him.[^30] Kaiser said that Project Alamo was "built completely from scratch" from the Republican National Committee's Data Trust database and purchased data sets.[^30]
### Russian and WikiLeaks contacts
Wylie said that from spring 2014 through 2015 Cambridge Analytica representatives met representatives of Lukoil, that Nix's presentations included discussion of rumor and disinformation campaigns, and that in May 2018 he told the [[Senate Judiciary Committee]] that Lukoil "has formal information sharing agreements with the Russian Federal Security Service."[^30][^31] His written statement said that after a request for information from Lukoil executives in the spring of 2014, Cambridge Analytica discussed with Lukoil its experience with "foreign disinformation, rumour campaigns, microtargeting and its American data assets."[^31] Kaiser told the committee the discussions concerned a customer loyalty application for Lukoil's stations in Turkey, said she was told the data could also be useful for political activities there, and furnished a February 2015 presentation prepared by SCL Commercial; neither she nor Wylie believed that a contract resulted, and the committee stated that it did not independently corroborate the allegation that Lukoil intended to use the company to affect elections.[^30] The committee noted that the [[Office of Foreign Assets Control]] had added Lukoil to its Sectoral Sanctions Identifications List on September 12, 2014.[^30]
Wylie said that from spring 2014 through 2015 Cambridge Analytica representatives met representatives of Lukoil, that Nix's presentations included discussion of rumor and disinformation campaigns, and that in May 2018 he told the [[Senate Judiciary Committee]] that Lukoil "has formal information sharing agreements with the Russian Federal Security Service."[^31][^32] His written statement said that after a request for information from Lukoil executives in the spring of 2014, Cambridge Analytica discussed with Lukoil its experience with "foreign disinformation, rumour campaigns, microtargeting and its American data assets."[^32] Kaiser told the committee the discussions concerned a customer loyalty application for Lukoil's stations in Turkey, said she was told the data could also be useful for political activities there, and furnished a February 2015 presentation prepared by SCL Commercial; neither she nor Wylie believed that a contract resulted, and the committee stated that it did not independently corroborate the allegation that Lukoil intended to use the company to affect elections.[^31] The committee noted that the [[Office of Foreign Assets Control]] had added Lukoil to its Sectoral Sanctions Identifications List on September 12, 2014.[^31]
Wylie also told the committee that in spring 2014 Bannon approved focus groups about [[Vladimir Putin]] and Russian expansionism preparatory to a predictive model, and that Bannon and [[Konstantin Kilimnik]] were two of three people likely responsible for the idea.[^32] [[Sam Patten]], a consultant who worked for the company in Nigeria, Mexico, Kosovo and the Czech Republic, told the committee there was "no connection" between Kilimnik and Cambridge Analytica; Kaiser said that on the Nigerian project the company may have assisted its client in retaining former Israeli intelligence officers working privately to conduct opposition research.[^32]
Wylie also told the committee that in spring 2014 Bannon approved focus groups about [[Vladimir Putin]] and Russian expansionism preparatory to a predictive model, and that Bannon and [[Konstantin Kilimnik]] were two of three people likely responsible for the idea.[^33] [[Sam Patten]], a consultant who worked for the company in Nigeria, Mexico, Kosovo and the Czech Republic, told the committee there was "no connection" between Kilimnik and Cambridge Analytica; Kaiser said that on the Nigerian project the company may have assisted its client in retaining former Israeli intelligence officers working privately to conduct opposition research.[^33]
The committee reported open-source accounts that during the 2016 campaign Nix emailed [[Julian Assange]] about the possible release of [[Hillary Clinton]]'s deleted emails, and that Assange said in October 2017 that [[WikiLeaks]] had rejected an approach by Cambridge Analytica. The committee obtained no additional information, and Bannon and others close to the campaign said they had no prior awareness of the contact.[^33] The committee also recorded that it was unable to obtain the company's corporate communications, which were in the hands of United Kingdom authorities, and that Nix "generally disregarded the Committee's requests for an appearance."[^34] It found "no convincing evidence that Russia's government or intelligence services worked with or through" Cambridge Analytica, Psy Group or Colt Ventures in furtherance of the 2016 interference.[^34] Cambridge Analytica, LLC is named among the respondents in matters under review 7207, 7268, 7274 and 7623 before the Federal Election Commission, in which Commissioners Shana Broussard and Ellen Weintraub issued a statement of reasons citing Volume 5 after a certification dated April 22, 2021; the text of the statement concerns the Russian Federation, the Internet Research Agency and the Trump committee and does not mention Cambridge Analytica outside the caption.[^35]
The committee reported open-source accounts that during the 2016 campaign Nix emailed [[Julian Assange]] about the possible release of [[Hillary Clinton]]'s deleted emails, and that Assange said in October 2017 that [[WikiLeaks]] had rejected an approach by Cambridge Analytica. The committee obtained no additional information, and Bannon and others close to the campaign said they had no prior awareness of the contact.[^34] The committee also recorded that it was unable to obtain the company's corporate communications, which were in the hands of United Kingdom authorities, and that Nix "generally disregarded the Committee's requests for an appearance."[^35] It found "no convincing evidence that Russia's government or intelligence services worked with or through" Cambridge Analytica, Psy Group or Colt Ventures in furtherance of the 2016 interference.[^35] Cambridge Analytica, LLC is named among the respondents in matters under review 7207, 7268, 7274 and 7623 before the Federal Election Commission, in which Commissioners Shana Broussard and Ellen Weintraub issued a statement of reasons citing Volume 5 after a certification dated April 22, 2021; the text of the statement concerns the Russian Federation, the Internet Research Agency and the Trump committee and does not mention Cambridge Analytica outside the caption.[^36]
### Regulatory and criminal proceedings in the United Kingdom
The Information Commissioner's Office issued a monetary penalty notice of £500,000 to Facebook on October 25, 2018, the highest fine permitted under the Data Protection Act 1998, citing lack of transparency and security failures relating to the harvesting of data.[^36] The office also executed a warrant at the company's premises at 8 p.m. on March 23, 2018, seized servers and other material, and reported that Cambridge Analytica and SCL Elections entered administration on May 3, 2018, that an enforcement notice of May 4, 2018 required it to answer a subject access request from the American academic [[David Carroll]] that had been made in January 2017, and that the deadline of June 3, 2018 passed without compliance.[^18] The office reported that Nix and Kogan had declined invitations to voluntary interviews under caution and that it would have issued a substantial fine had the company not been in administration.[^18] SCL Elections pleaded guilty at [[Hendon Magistrates' Court]] on January 9, 2019, the day set for trial, to failing to comply with the enforcement notice; press reports gave the penalty as a fine of £15,000 with £6,000 in costs and a victim surcharge of £170.[^37] The Information Commissioner's 2020 letter to Parliament gives the fine as £18,000.[^38]
The Information Commissioner's Office issued a monetary penalty notice of £500,000 to Facebook on October 25, 2018, the highest fine permitted under the Data Protection Act 1998, citing lack of transparency and security failures relating to the harvesting of data.[^37] The office also executed a warrant at the company's premises at 8 p.m. on March 23, 2018, seized servers and other material, and reported that Cambridge Analytica and SCL Elections entered administration on May 3, 2018, that an enforcement notice of May 4, 2018 required it to answer a subject access request from the American academic [[David Carroll]] that had been made in January 2017, and that the deadline of June 3, 2018 passed without compliance.[^18] The office reported that Nix and Kogan had declined invitations to voluntary interviews under caution and that it would have issued a substantial fine had the company not been in administration.[^18] SCL Elections pleaded guilty at [[Hendon Magistrates' Court]] on January 9, 2019, the day set for trial, to failing to comply with the enforcement notice; press reports gave the penalty as a fine of £15,000 with £6,000 in costs and a victim surcharge of £170.[^38] The Information Commissioner's 2020 letter to Parliament gives the fine as £18,000.[^39]
On October 2, 2020 the Information Commissioner, [[Elizabeth Denham]], wrote to the chair of the Digital, Culture, Media and Sport Committee that the office had concluded its investigation, that the company had purchased commercially available data amounting at one estimate to more than 130 billion data points, mostly about United States voters, to combine with Facebook-derived data from Kogan, that its models were mostly built from "off the shelf" tools, that the office found no further evidence to change its view that the company was not involved in the European Union referendum campaign beyond early inquiries about UK Independence Party data, and that it found no additional evidence of Russian involvement in the servers it obtained.[^38] The letter also reported evidence that in its last stages the company was drawing up plans to move its data offshore to avoid regulatory scrutiny, which it did not carry out before it ceased trading.[^38]
On October 2, 2020 the Information Commissioner, [[Elizabeth Denham]], wrote to the chair of the Digital, Culture, Media and Sport Committee that the office had concluded its investigation, that the company had purchased commercially available data amounting at one estimate to more than 130 billion data points, mostly about United States voters, to combine with Facebook-derived data from Kogan, that its models were mostly built from "off the shelf" tools, that the office found no further evidence to change its view that the company was not involved in the European Union referendum campaign beyond early inquiries about UK Independence Party data, and that it found no additional evidence of Russian involvement in the servers it obtained.[^39] The letter also reported evidence that in its last stages the company was drawing up plans to move its data offshore to avoid regulatory scrutiny, which it did not carry out before it ceased trading.[^39]
The Insolvency Service announced in September 2020 that Nix had given an undertaking disqualifying him from acting as a company director for seven years from October 5, 2020, having, in the service's words, caused or permitted SCL Elections or associated companies to act with a lack of commercial probity by marketing services including "bribery or honey trap stings, voter disengagement campaigns, obtaining information to discredit political opponents and spreading information anonymously in political campaigns." The service did not say whether any such services were performed, and Nix told Reuters he had made no admission of wrongdoing.[^39] The Digital, Culture, Media and Sport Committee had recorded in February 2019 that the Insolvency Service was investigating the directors of SCL Elections, SCL Group, SCL Analytics, SCL Commercial, SCL Social and Cambridge Analytica (UK) under the [[Company Directors Disqualification Act 1986]].[^40]
The Insolvency Service announced in September 2020 that Nix had given an undertaking disqualifying him from acting as a company director for seven years from October 5, 2020, having, in the service's words, caused or permitted SCL Elections or associated companies to act with a lack of commercial probity by marketing services including "bribery or honey trap stings, voter disengagement campaigns, obtaining information to discredit political opponents and spreading information anonymously in political campaigns." The service did not say whether any such services were performed, and Nix told Reuters he had made no admission of wrongdoing.[^40] The Digital, Culture, Media and Sport Committee had recorded in February 2019 that the Insolvency Service was investigating the directors of SCL Elections, SCL Group, SCL Analytics, SCL Commercial, SCL Social and Cambridge Analytica (UK) under the [[Company Directors Disqualification Act 1986]].[^41]
### Emerdata and the end of the group
Emerdata Limited (Companies House number 10911848) was incorporated on August 11, 2017 with Wheatland as a director, and its persons with significant control from incorporation were Wheatland and Dr Alexander Bruce Tayler, each holding more than 25 percent and up to 50 percent until January 23, 2018.[^41] From January 23, 2018 the register shows Cambridge Analytica Holdings LLC, with an address on Orange Street in Wilmington, Delaware, as holder of more than 50 percent and less than 75 percent of shares and votes until August 9, 2022; since that date the register carries a statement that there is no registrable person.[^41] The register records the officers appointed on January 23, 2018 as Nix (resigned March 28, 2018), Johnson Chun Shun Ko (resigned May 9, 2018), Cheng Peng (resigned May 8, 2018) and Ahmad Al Khatib (resigned May 7, 2018); Tayler was a director again from March 28 to April 18, 2018, Gary Ka Chun Tiu from June 12, 2018 to December 3, 2024, and Wheatland until May 22, 2019.[^41] Rebekah and Jennifer Mercer were appointed directors on March 16, 2018 and remained in office as of the register consulted on October 1, 2026, with [[Jacquelyn James-Varga]] (appointed May 22, 2019) and Bradley David Golub (appointed December 3, 2024).[^41]
Emerdata Limited (Companies House number 10911848) was incorporated on August 11, 2017 with Wheatland as a director, and its persons with significant control from incorporation were Wheatland and Dr Alexander Bruce Tayler, each holding more than 25 percent and up to 50 percent until January 23, 2018.[^42] From January 23, 2018 the register shows Cambridge Analytica Holdings LLC, with an address on Orange Street in Wilmington, Delaware, as holder of more than 50 percent and less than 75 percent of shares and votes until August 9, 2022; since that date the register carries a statement that there is no registrable person.[^42] The register records the officers appointed on January 23, 2018 as Nix (resigned March 28, 2018), Johnson Chun Shun Ko (resigned May 9, 2018), Cheng Peng (resigned May 8, 2018) and Ahmad Al Khatib (resigned May 7, 2018); Tayler was a director again from March 28 to April 18, 2018, Gary Ka Chun Tiu from June 12, 2018 to December 3, 2024, and Wheatland until May 22, 2019.[^42] Rebekah and Jennifer Mercer were appointed directors on March 16, 2018 and remained in office as of the register consulted on October 1, 2026, with [[Jacquelyn James-Varga]] (appointed May 22, 2019) and Bradley David Golub (appointed December 3, 2024).[^42]
The Digital, Culture, Media and Sport Committee reported in February 2019 that Emerdata had not gone into administration, was the largest creditor of SCL Elections and was paying the administration costs, and listed shareholders as of August 10, 2018 that included Cambridge Analytica Holdings LLC, Tayler, Wheatland, trusts for the benefit of Rebekah, Jennifer and Heather Mercer, Alexander and Catherine Nix, five members of the Marland family, Henry and Roger Gabb, Nigel and Alexander Oakes, and Reza Saddlou-Bundy.[^40] The committee recommended that the [[National Crime Agency]] investigate the connections between SCL Elections and Emerdata.[^40] The committee also reported that SCL Insight Limited, owned by Nigel Oakes, had been spun off in the 2017 reorganization.[^40]
The Digital, Culture, Media and Sport Committee reported in February 2019 that Emerdata had not gone into administration, was the largest creditor of SCL Elections and was paying the administration costs, and listed shareholders as of August 10, 2018 that included Cambridge Analytica Holdings LLC, Tayler, Wheatland, trusts for the benefit of Rebekah, Jennifer and Heather Mercer, Alexander and Catherine Nix, five members of the Marland family, Henry and Roger Gabb, Nigel and Alexander Oakes, and Reza Saddlou-Bundy.[^41] The committee recommended that the [[National Crime Agency]] investigate the connections between SCL Elections and Emerdata.[^41] The committee also reported that SCL Insight Limited, owned by Nigel Oakes, had been spun off in the 2017 reorganization.[^41]
Emerdata entered administration on December 9, 2024, the register names Benjamin Stanyon and Nedim Patrick Ailyan as practitioners, records a cessation to act on April 8, 2026, and gives the registered office as care of Opus Restructuring LLP, Milton Keynes.[^41] SCL Group Limited, SCL Elections Limited and Cambridge Analytica (UK) Limited were in administration from May 3, 2018 to April 17, 2019, then in compulsory liquidation on a petition of August 13, 2018, which concluded on September 1, 2025; the first two were dissolved on January 31, 2026 and the third on January 30, 2026.[^42]
Emerdata entered administration on December 9, 2024, the register names Benjamin Stanyon and Nedim Patrick Ailyan as practitioners, records a cessation to act on April 8, 2026, and gives the registered office as care of Opus Restructuring LLP, Milton Keynes.[^42] SCL Group Limited, SCL Elections Limited and Cambridge Analytica (UK) Limited were in administration from May 3, 2018 to April 17, 2019, then in compulsory liquidation on a petition of August 13, 2018, which concluded on September 1, 2025; the first two were dissolved on January 31, 2026 and the third on January 30, 2026.[^43]
### Footnotes
@ -216,17 +218,18 @@ Emerdata entered administration on December 9, 2024, the register names Benjamin
[^26]: Mercer Family Foundation, Form 990-PF for 2011, Part XV (grant to OISM, P.O. Box 1279, Cave Junction, Oregon, $965,000) (https://990s.foundationcenter.org/990pf_pdf_archive/201/201982204/201982204_201112_990PF.pdf); Form 990-PF for 2021, Part XV (Oregon Institute of Science and Medicine, 2251 Dick George Road, Cave Junction, Oregon, $250,000), ProPublica Nonprofit Explorer full text (https://projects.propublica.org/nonprofits/organizations/201982204/202213199349104431/IRS990PF).
[^27]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 673 to 674 and notes 4352 to 4357 (Kaiser transcript, pp. 144 to 156; Bannon transcript, p. 268; Maegan Vazquez and Paul Murphy, "Trump isn't the only Republican who gave Cambridge Analytica big bucks," CNN, March 21, 2018). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^28]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, p. 672 and note 4348 (Kaiser transcript, pp. 40 to 43). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^29]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 675 to 678 and notes 4367 to 4379 (Parscale transcript, pp. 53 to 60; Trump Data Team Presentation, August 22, 2016, FLYNN_SSCI_00011770 and 00011773; FBI FD-302 of Rick Gates, October 29, 2018; Kaiser transcript, pp. 161 to 164). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^30]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 670 to 671 and notes 4334 to 4341 (Wylie proffer; Wylie written statement to the Senate Judiciary Committee, May 16, 2018; Kaiser transcript, pp. 66 to 67 and 121 to 123; SCL Commercial presentation for Lukoil, February 18, 2015; OFAC listing of September 12, 2014). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^31]: Christopher Wylie, written statement, "In the Matter of Cambridge Analytica and Other Related Issues," Senate Committee on the Judiciary, May 16, 2018, paragraphs 32 and 33. https://www.judiciary.senate.gov/download/06/03/2026/05-16-18-wylie-testimony
[^32]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, p. 668 and notes 4318 to 4325 (Wylie proffer; Patten transcript, pp. 29 to 38; Kaiser transcript, pp. 67 to 68; Bannon transcript, pp. 253 to 256). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^33]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 678 to 679 and notes 4380 to 4383 (Betsy Swan, "Trump Data Guru Alexander Nix: I Tried To Team Up With Julian Assange," *The Daily Beast*, October 25, 2017; Kara Scannell, Dana Bash and Marshall Cohen, CNN, October 25, 2017). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^34]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 663 to 664 (section introduction, "Committee did not examine the effectiveness of the work these companies may have conducted"; limitations including Nix's non-appearance and the seizure of the company's corporate communications by U.K. authorities). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^35]: Federal Election Commission, Statement of Reasons of Commissioners Shana M. Broussard and Ellen L. Weintraub, MURs 7207, 7268, 7274 and 7623 (Russian Federation; Donald J. Trump for President, Inc.; Donald J. Trump; H. Russell Taub; Cambridge Analytica, LLC; Internet Research Agency; Paul Manafort), note 2 (certification dated April 22, 2021). https://www.fec.gov/files/legal/murs/7207/7207_47.pdf
[^36]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns: A report to Parliament*, November 6, 2018, section 3.2.4 (p. 38). https://www.statewatch.org/media/documents/news/2018/nov/uk-ico-report-investigation-into-use-of-data-political-campaigns-6-11-18.pdf
[^37]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns*, November 6, 2018, section 3.2.3 (trial set for January 9, 2019 at Hendon Magistrates' Court); "Cambridge Analytica Pleads Guilty In UK Data Access Case," *MediaPost*, January 9, 2019 (fine of £15,000, costs of £6,000, victim surcharge of £170, citing the ICO announcement) https://www.mediapost.com/publications/article/330338/ ; Ellen Tannam, "Cambridge Analytica owner hit with £15,000 fine for disobeying UK ICO," *Silicon Republic*, January 2019 (District Judge Kenneth Grant: "wilful disregard of the enforcement notice") https://www.siliconrepublic.com/enterprise/cambridge-analytica-scl-fine
[^38]: Elizabeth Denham, Information Commissioner, letter to Julian Knight MP, Chair, Digital, Culture, Media and Sport Committee, reference ICO/O/ED/L/RTL/0181, October 2, 2020, paragraphs 3 to 15. https://cy.ico.org.uk/media2/migrated/2618383/20201002_ico-o-ed-l-rtl-0181_to-julian-knight-mp.pdf
[^39]: "Ex-Cambridge Analytica head banned from running firms in UK," Reuters, published by Al Jazeera, September 25, 2020 (statement of the Insolvency Service of September 24, 2020; Mark Bruce, chief investigator; disqualification from October 5, 2020). https://www.aljazeera.com/economy/2020/9/25/uk-bans-ex-cambridge-analytica-boss-for-unethical-services
[^40]: House of Commons Digital, Culture, Media and Sport Committee, *Disinformation and "fake news": Final Report*, HC 1791, February 18, 2019, paragraphs 285 to 290, 296 and notes 327 to 329 and 338. https://publications.parliament.uk/pa/cm201719/cmselect/cmcumeds/1791/1791.pdf
[^41]: Companies House, EMERDATA LIMITED (company number 10911848), overview, officers, persons with significant control and insolvency pages, viewed October 1, 2026; personal appointments pages for Jennifer Lynne Mercer, Rebekah Anne Mercer, Jacquelyn James-Varga and Bradley David Golub. https://find-and-update.company-information.service.gov.uk/company/10911848
[^42]: Companies House, insolvency pages for SCL GROUP LIMITED (05514098), SCL ELECTIONS LIMITED (08256225) and CAMBRIDGE ANALYTICA(UK) LIMITED (09375920), viewed October 1, 2026 (administration May 3, 2018 to April 17, 2019; compulsory liquidation, petition August 13, 2018, winding up commenced April 17, 2019 and concluded September 1, 2025; dissolved January 31, 2026, January 31, 2026 and January 30, 2026). https://find-and-update.company-information.service.gov.uk/company/05514098/insolvency
[^29]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, notes 447 and 448 (Parscale transcript, p. 64). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^30]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 675 to 678 and notes 4367 to 4379 (Parscale transcript, pp. 53 to 60; Trump Data Team Presentation, August 22, 2016, FLYNN_SSCI_00011770 and 00011773; FBI FD-302 of Rick Gates, October 29, 2018; Kaiser transcript, pp. 161 to 164). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^31]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 670 to 671 and notes 4334 to 4341 (Wylie proffer; Wylie written statement to the Senate Judiciary Committee, May 16, 2018; Kaiser transcript, pp. 66 to 67 and 121 to 123; SCL Commercial presentation for Lukoil, February 18, 2015; OFAC listing of September 12, 2014). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^32]: Christopher Wylie, written statement, "In the Matter of Cambridge Analytica and Other Related Issues," Senate Committee on the Judiciary, May 16, 2018, paragraphs 32 and 33. https://www.judiciary.senate.gov/download/06/03/2026/05-16-18-wylie-testimony
[^33]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, p. 668 and notes 4318 to 4325 (Wylie proffer; Patten transcript, pp. 29 to 38; Kaiser transcript, pp. 67 to 68; Bannon transcript, pp. 253 to 256). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^34]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 678 to 679 and notes 4380 to 4383 (Betsy Swan, "Trump Data Guru Alexander Nix: I Tried To Team Up With Julian Assange," *The Daily Beast*, October 25, 2017; Kara Scannell, Dana Bash and Marshall Cohen, CNN, October 25, 2017). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^35]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 663 to 664 (section introduction, "Committee did not examine the effectiveness of the work these companies may have conducted"; limitations including Nix's non-appearance and the seizure of the company's corporate communications by U.K. authorities). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^36]: Federal Election Commission, Statement of Reasons of Commissioners Shana M. Broussard and Ellen L. Weintraub, MURs 7207, 7268, 7274 and 7623 (Russian Federation; Donald J. Trump for President, Inc.; Donald J. Trump; H. Russell Taub; Cambridge Analytica, LLC; Internet Research Agency; Paul Manafort), note 2 (certification dated April 22, 2021). https://www.fec.gov/files/legal/murs/7207/7207_47.pdf
[^37]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns: A report to Parliament*, November 6, 2018, section 3.2.4 (p. 38). https://www.statewatch.org/media/documents/news/2018/nov/uk-ico-report-investigation-into-use-of-data-political-campaigns-6-11-18.pdf
[^38]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns*, November 6, 2018, section 3.2.3 (trial set for January 9, 2019 at Hendon Magistrates' Court); "Cambridge Analytica Pleads Guilty In UK Data Access Case," *MediaPost*, January 9, 2019 (fine of £15,000, costs of £6,000, victim surcharge of £170, citing the ICO announcement) https://www.mediapost.com/publications/article/330338/ ; Ellen Tannam, "Cambridge Analytica owner hit with £15,000 fine for disobeying UK ICO," *Silicon Republic*, January 2019 (District Judge Kenneth Grant: "wilful disregard of the enforcement notice") https://www.siliconrepublic.com/enterprise/cambridge-analytica-scl-fine
[^39]: Elizabeth Denham, Information Commissioner, letter to Julian Knight MP, Chair, Digital, Culture, Media and Sport Committee, reference ICO/O/ED/L/RTL/0181, October 2, 2020, paragraphs 3 to 15. https://cy.ico.org.uk/media2/migrated/2618383/20201002_ico-o-ed-l-rtl-0181_to-julian-knight-mp.pdf
[^40]: "Ex-Cambridge Analytica head banned from running firms in UK," Reuters, published by Al Jazeera, September 25, 2020 (statement of the Insolvency Service of September 24, 2020; Mark Bruce, chief investigator; disqualification from October 5, 2020). https://www.aljazeera.com/economy/2020/9/25/uk-bans-ex-cambridge-analytica-boss-for-unethical-services
[^41]: House of Commons Digital, Culture, Media and Sport Committee, *Disinformation and "fake news": Final Report*, HC 1791, February 18, 2019, paragraphs 285 to 290, 296 and notes 327 to 329 and 338. https://publications.parliament.uk/pa/cm201719/cmselect/cmcumeds/1791/1791.pdf
[^42]: Companies House, EMERDATA LIMITED (company number 10911848), overview, officers, persons with significant control and insolvency pages, viewed October 1, 2026; personal appointments pages for Jennifer Lynne Mercer, Rebekah Anne Mercer, Jacquelyn James-Varga and Bradley David Golub. https://find-and-update.company-information.service.gov.uk/company/10911848
[^43]: Companies House, insolvency pages for SCL GROUP LIMITED (05514098), SCL ELECTIONS LIMITED (08256225) and CAMBRIDGE ANALYTICA(UK) LIMITED (09375920), viewed October 1, 2026 (administration May 3, 2018 to April 17, 2019; compulsory liquidation, petition August 13, 2018, winding up commenced April 17, 2019 and concluded September 1, 2025; dissolved January 31, 2026, January 31, 2026 and January 30, 2026). https://find-and-update.company-information.service.gov.uk/company/05514098/insolvency