The complaint to the Federal Election Commission (FEC), along with exhibits, is available at this link. It alleges that Hung Cao engaged in “mail fraud and wire fraud” by raising funds for the “Unleash America PAC” (FEC ID #C00831248) by soliciting donations on the premise that funds would be used to support local candidates in state races for the Virginia House of Delegates and the Virginia Senate. According to the complaint, the Unleash America PAC “did not donate a single dollar or expend any money in support of any Virginia candidate committees in 2023.” Instead, some of the money has now been directed to compensate several people working on Hung Cao’s current US Senate campaign. Funds that were originally raised on the promise of supporting Virginia state candidates are now being used, “for [Senate] campaign expenditures, among them for mail lists and political consultants aiding his U.S. Senate campaign,” the complaint alleges, citing media sources.
The Unleash America PAC raised $148,489.02 in 2023, according to the complaint.
While we don't automatically trust left-leaning news sources like USA Today (which is why we have independently verified this information, see below), USA Today has been covering the story and attempted to solicit answers on some earlier funding questions, writing in a May 9th, 2024 story by Elizabeth Beyer:
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USA Today had repeatedly emailed, called, and texted Cao's Senate campaign and had emailed the treasurer listed on Unleash America FEC filings since early February to get answers regarding the PAC's expenditures. Aside from a memo sent to USA Today from Cao's campaign through an intermediary, no response was provided.
In a email response to USA Today author Elizabeth Beyer, general counsel for Hung Cao for Virginia, Steve Roberts, wrote the following (February 14, 2024):
Unleash America PAC is a federally-registered Super PAC, and as such cannot make contributions to any campaign whatsoever. No campaign could possibly have received a contribution from Unleash America PAC, nor could Hung have pledged to make such a contribution.
USA Today also writes:
When Cao launched Unleash America in February 2023, the super PAC had one stated goal: To get Republicans elected during Virginia's 2023 statehouse contests to support Gov. Glenn Youngkin's agenda, as reported by the Staunton News Leader and USA Today.
... After Republicans lost the House of Delegates in Virginia and failed to flip the Senate, analysis of Unleash America's expenditures showed no support of any kind, in-kind or otherwise, for Virginia's Republican candidates.
The story goes on to state that $37,514 from the super PAC was paid to John Ryan O’Rourke, who is Cao’s 2024 Senate campaign manager. He was also previously Cao’s campaign manager for his congressional run. USA Today also adds, “Another $22,867 of Unleash America's money went to K2 & Co., a communications firm Cao had employed during his 2022 Congressional campaign and also during his 2024 Senate campaign.”
Strangely, OpenSecrets.org shows zero spending by the Unleash America PAC in 2024 as well as having no data available at all for 2023.
Cao resigned from the Unleash America PAC, then announces his US Senate run, but donated funds were still in question
According to his campaign’s general counsel, Cao resigned from Unleash America PAC on June 15th, 2023. About three weeks later, he filed candidacy paperwork to run for the US Senate (on July 6th, 2023).
Elizabeth Beyer of the Staunton News Leader, which is associated with USA Today, spoke with a donor who says he was were misled by Cao's fundraising promises. Reporting on April 15th of this year in an article entitled, "Unleash America was supposed to be about supporting Va. candidates. But the money didn't go there," she writes:
Robert Landrum thought he was supporting Republicans in Virginia’s statehouse elections that year, when he donated $500 to a federal super PAC in April 2023. The super PAC, Unleash America, had one stated goal: To get Republicans elected during Virginia’s 2023 statehouse contests to support Gov. Glenn Youngkin’s agenda. “That’s how he represented the PAC. That’s what he said,” Landrum said in a phone interview with USA Today.
... [Cao] announced his PAC on a local radio talk show in February 2023. He pledged that Unleash America would support Republicans in 2023 in "a lot of the races that people wrote off."
On radio shows and in news articles in early 2023 Cao repeated his motivation for championing the PAC: To support Virginia Republicans seeking local and state-level office. His stated goal was to help to deliver a Republican General Assembly majority in November to support Republican Gov. Glenn Youngkin’s legislative efforts. He made that pledge on The Wilkow Majority and Richmond’s Morning News with John Reid on February 2, 2023. And again, in an article that ran in The Dispatch on February 4, 2023. And again, in another article that ran in the Washington Examiner on February 7, 2023. And people listened.
Natural News was able to independently confirm what Elizabeth Beyer reported (see below). Mr. Cao has called the USA Today reporting a "hit job" by "the left," but Natural News is no leftist publisher, and I personally voted for Trump twice (and will likely do so again, despite my aggravation at several of his policies).
This article from TheDispatch.com also appears to confirm that Hung Cao raised funds for the Unleash America PAC by promising to spend money on local Virginia races in the Senate and House. From that article:
For now, Cao is serving as honorary chairman of a new political action committee called Unleash America, which plans to announce its fundraising team in a few weeks and aims to invest heavily this cycle in Republican candidates for state Senate and House of Delegates.
Hung Cao is on video, audio promising to user the Unleash America PAC to fund Virginia state candidates
On February 2, 2023, Hung Cao joined the live broadcast of “Richmond’s Morning News with John Reid.” That interview is available at this link.
On the show, within the first four minutes, Cao says the following:
Cao: What we need to do right now, is we need to get leaders in the Virginia House of Delegates and the State Senate that believe in our values... and that’s why I’m launching Unleash America PAC, because I was one of the top fundraisers in the country this past year. I was 14th out of 435 people. I had people giving from all 50 states, and I wanted to use that in order to help the people running this year, and especially getting the vote out...
Host: Will your PAC start to address some of those issues?... Where are you going to put the money?
Cao: Obviously a lot of the races that people wrote off saying this is not going to happen... So we need to look at these candidates who have a fighting chance, and we’ve got to get them across, because without a good House of Delegates and without a State Senate, the governor’s not going to be able to get half the things that he wants to get across.
In a video clip acquired by Natural News, Hung Cao is seen stating that the Unleash America PAC would be providing support for local state candidates. In one video (see screen shot below), he says:
We stood up a super PAC called Unleash America that's both a federal and state so that we can take the money and invest into the [state] elections for this year. I'm not trying to brag, I was the 14th largest fundraiser in the entire NRCC last year... So what's the best way to do that? That's why I'm working very hard this year in order to figure out a way to get the vote out to state elections.
Congressional candidate Mike Van Meter has witnessed promises made but not kept
Mike Van Meter is running for the U.S. House of Representatives, 11th Congressional District, in 2024. His website is VanMeterForVirginia.com
I reached out to Mr. Van Meter for a comment on this story and provided him with details of what we already knew. He told me that Hung Cao's idea for the Unleash America PAC was born out of another well-known PAC in Virginia called the Spirit of Virginia PAC. This PAC is a fundraising powerhouse, having raised over $33 million since 2021, according to VPAP.org.
Gov. Youngkin is the founder of the Spirit of Virginia PAC, and according to the interviews I conducted for this story, Youngkin is the primary decision maker of where this money goes. "The Governor raised this money but he targeted only few races across Virginia, and everybody was frustrated because we thought we were all going to get supported, but the money only went to certain people," Van Meter told me. "The governor did support candidates, but he didn't support everyone."
Following the footsteps of the Spirit of Virginia PAC, the Unleash America PAC spearheaded by Hung Cao promised to do things differently, raising money from all 50 states and distributing those funds to local candidates in Virginia's House and Senate races. Mr. Cao made these promises publicly, in numerous interviews and videos we have reviewed.
Mike Van Meter was there at the very beginning of the PAC. After Van Meter appeared on the Larry O'Connor show one morning, around October of 2023, and was very vocal about Gov. Youngkin's lack of financial support for local candidates across the state, especially those in Northern Virginia. "I must have said something out of frustration," Van Meter told me, adding, "I said I really wish people who not write off northern Virginia. I'm getting tired of the party raising money in northern Virginia to help other candidates. When I finish the show, Hung Cao calls me, this was around 6:30 in the morning, and he said I think it's wrong, and I'm working on this PAC, and I want to make sure what the governor did doesn't happen again. We need to raise money to help each other, particularly races that need the money like yours."
"After Republicans lost the House of Delegates in Virginia and failed to flip the Senate, analysis of Unleash America’s expenditures showed no support of any kind, in-kind or otherwise, for Virginia’s Republican candidates," writes NewsLeader.com. Natural News has confirmed the same with multiple people directly involved in Virginia candidacy campaigns.
In political circles across Virginia, by the way, Hung Cao is well known for being absent from local political events in Virginia, according to numerous people with whom I spoke. Although he promised to help local candidates with his Unleash America PAC, none of the candidates we spoke with ever received any funds. As Van Meter told me:
[Cao] mentioned to me that he was working with a PAC and he did tell me the purpose was to financially help the Republican candidates, and he wasn't going to run it the way the governor did. He told us it was not right, the way the governor distributed funds. Cao said I'm going to be the new guy in town and I'm going to make sure everybody gets base money support. And that's the last I heard of it.
Van Meter reiterated to me that Cao never directly promised specific funds to him, but that such a promise was strongly inferred from the conversation. "It was clear from the conversation, I got the impression that was the intent of the PAC," Van Meter said.
Hung Cao's political opponent Jonathan Emord calls for Unleash America PAC donations to be reimbursed to donors
As part of this investigation, we also reached out to Jonathan Emord, Hung Cao's opponent for the GOP nomination, and whom I have interviewed several times in the past. In the interests of full transparency, I donated to Mr. Emord's campaign in 2023. We emailed Emord's public press contact with the details of the allegations against Mr. Cao, along with links to some of the audio recordings confirming Cao's promises to fund local Virginia candidates. Emord responded to our inquiry with the following statement:
The facts reveal a breach of the public trust that is disqualifying. Cao deceived Virginians and people across the country into believing the funds he solicited for his Unleash America PAC would be spent on state candidates. Instead, he took the money for himself and his U.S. Senate campaign. He should reimburse all donors to that sham PAC.
Nhan Huynh reveals more details about the lack of financial support for conservative candidates in Virginia
Emord isn't the only one calling for significant repercussions related to Hung Cao's use of donation funds. As part of the investigation for this article, I also spoke with Nhan Huynh, who ran for Virginia's 9th District in 2023. His website is HuynhForVirginia.com
Huynh, a military veteran who literally grew up under communism and fled to the United States to find freedom, is also ethnically Vietnamese, as is Hung Cao. They both attended the same high school, in fact. Huynh told me he strongly supported Cao during his congressional run, and served as a ballot counter for his campaign (election oversight / election integrity tasks). "I supported him wholeheartedly but when it comes time for him to support us, he turns his back on us," Huynh said. "He promised all this to support local candidates, he used his name, our name to fund raise, and more importantly, as a fellow Vietnamese, to attract minority voters which are pretty important in our area. We need minority support, we believe that minorities in principle are conservatives, and we can’t give lip service that we want to attract minorities and not do anything... we have to engage them. Hung Cao did not do that."
He added, "It is devastating to not have support because we need these minorities to turn out who share our principles and support anti-communist [ideals], and what democrats represent are communist principles."
Huynh, who expressed truly moving levels of passion about escaping communism and protecting the founding principles of our constitutional republic, believes that Cao's top-down campaign style is a losing strategy that fails to connect with the grassroots public where it matters.
Huynh explained to me that Hung Cao avoids grassroots campaigning and runs a "top-down" campaign, getting endorsements (from Donald J. Trump, in this case), paying for media ad splits and not engaging very much at the local level. Cao is essentially a no-show at local events, multiple sources told me, including Huynh.
About the allegations of Hung Cao's alleged misuse of PAC funds, Huynh told me, "I think he should own up to it. Ultimately, I think he should withdraw [from the race] because I think Democrats are gonna pound on it if he wins the nomination. It hurts us in the long run. We need true passionate conservatives who believe in the grassroots movement. You can say you are anti-communist but if you don’t engage at the grassroots level, it won’t work."
Again and again, as I spoke to other candidates running to represent various districts in Northern Virginia, the same theme was repeated: Cao made promises to help fund local races, but never delivered on those promises. Even more frustratingly, he doesn't participate much in bottom-up, local politics and is barely visible to the people who he expects to vote for him. "We can’t have fake people, people that give lip service and not truly galvanize the masses," Huynh added.
Maxwell Fisher laments the lack of financial support for northern Virginia candidates
As part of this investigation, I also spoke with Maxwell Fisher ("Max"), whose campaign site is MaxFisherForVirginia.com
"The majority of our candidates in Fairfax County, when they run, when not successful, they tend to not come back and run again," Fisher told me. "A lot has to do with the lack of support. We had 41 candidates running in northern Virginia. It was an absolute panic to try to get money and attention. So I didn’t even find out until after the election that the PAC that Hung Cao started was in existence. I had no idea."
Fisher also confirmed that the well-funded Spirit of Virginia PAC, largely controlled by Gov. Youngkin, was abundantly funded thanks to generous donor support, but none of that money went to the candidates fighting for survival in areas like Fairfax County. Fisher told me:
We had Spirit of Virginia [PAC], they had their own funding, and a lot of people donated to Spirit of Virginia, but they supported a hand-selected group of campaigns. Democrats tend to spend a ton of money in Fairfax, around $40 - $50K per candidate, plus blue PACs they have out here. [But] we’ve always felt like the Republican party has been non-existent out in this area.
Fisher also confirms the notable absence of Hung Cao at local events, saying, "I have met and spent a lot of time with all five of our senate candidates, and I’m friendly with all of them," Fisher said, "The one person always absent was Hung Cao, and not to say he wasn’t as engaged, he just hasn’t been around. All these other candidates are putting in time, showing up at events, a lot more grassroots efforts."
The lack of financial support for Fairfax County races is also a priority concern for Fisher, and this speaks directly to the Hung Cao PAC promises that ended up being empty promises. "Any candidate that ran last year could tell you the same thing... We didn’t see any of the PAC money. It was basically five campaigns targeted across the Commonwealth, and none of them won," Fisher said.
"We have a really good opportunity this year to leverage and win these House and Senate seats," Fisher added. "No matter what happens on June 18th, we have to be able to help each other out. If he’s not successful, if he has a ton of money still around, he needs to start helping out other candidates."
My Analysis / Opinion
As an investigative journalist, I do not automatically believe USA Today writers, even when they attempt to be fair. I took it upon myself to investigate this story, to call Virginia congressional candidates, review the documents and seek out relevant audio recordings.
Lest anyone accuse me of having an anti-Asian bias of some sort, know that this author is married to a Taiwanese immigrant, that I previously lived in Taiwan and that I speak a fair amount of Mandarin Chinese. I am pro- legal immigration, I voted for Trump twice, and will likely vote for him a third time this November. Last year, I donated to the campaign of Jonathan Emord, who is Hung Cao's opponent in the upcoming primary on June 18th. I will likely donate again as allowed by law. I am a resident of Texas, so I have no vote in Virginia, but I do have national and international reach, and I believe the very fate of our Constitutional Republic is at stake in this coming election, and the party composition of the US Senate is critical for determining whether America survives or falls. Thus, every candidate in a race for US Senate needs to be the strongest candidate possible.
I personally hope Tim Kaine is resoundingly defeated in November and that Virginia turns solid red once again, given how much damage to Virginia and America has been achieved by Democrats during the Biden administration. This is where I'm coming from in my analysis, meaning I would be thrilled if either Hung Cao or Jonathan Emord defeated Tim Kaine. Mr. Cao's pro-America, pro-freedom philosophies are well aligned with my own, and I have no issue with Mr. Cao's stern defense of the First and Second Amendments, or other natural freedoms enumerated in the Bill of Rights, for example. However, I do personally believe that attorney Jonathan Emord has a far more in-depth understanding of the dangers of the bureaucratic state and would fight tooth and nail to dismantle it, ultimately proving to be more effective than Cao as a senator.
My primary concern in all this is that Hung Cao's fundraising for the Unleash America PAC -- and the unfulfilled promises he made to use that money to fund local candidates across Virginia -- will be seized upon by the Democrat party to undermine and possibly destroy the Hung Cao campaign. Combined with the enormous funding for Tim Kaine coming from across all 50 states, questions about Hung Cao's broken promises and Unleash America PAC funds being used to compensate some of the same people working on his current Senate campaign, could be campaign-ending vulnerabilities.
Then there's the question of legality. It's clear that Hung Cao made numerous, documented promises to raise money through the Unleash America PAC and to use those funds to help financially support local candidates, but according to his own General Counsel, such a role of the PAC is not allowed by federal law. As his attorney stated in the email screen shot shown above:
Unleash America PAC is a federally-registered Super PAC, and as such cannot make contributions to any campaign whatsoever. No campaign could possibly have received a contribution from Unleash America PAC, nor could Hung have pledged to make such a contribution.
Indeed, it seems clear that the Unleash America PAC did not make contributions to any campaign, but it's also clear that Mr. Cao both implied that such funds would be diverted, at least in part, to local candidate campaigns, and it's also clear that Mr. Cao engaged in fundraising activities by promising the public that his PAC would fund local campaigns, even though local campaigns were not, in the end, funded at all.
This brings up the obvious question that USA Today is essentially asking: Did Hung Cao deceive donors to raise money for his PAC, then divert some or all of those funds to his own Senate campaign? Are there potential legal ramifications for these actions?
The message I'm getting from other candidates in Virginia is that they feel Hung Cao diverted money to his own US Senate campaign by depriving those funds to other candidates who desperately needed them, resulting in many losses at the state level in the elections last year (Virginia has elections every year for various positions) which could have otherwise been competitive. This appears to be why other candidates are publicly speaking out against Mr. Cao's behavior, and why Mr. Emord and Mr. Huynh are calling for Mr. Cao to either reimburse all donated funds or withdraw his US Senate campaign entirely.
We have reached out to the press contact of the Hung Cao campaign to ask for comment. So far, we have not received a reply, but we are happy to update this article with the reply once we receive it. We have also reached out to attorney Brittany Schneider Williams but have so far received no response.
If you believe any facts or statements in this article to be in error, please reach out to us at the "Submit a News Tip" link on this site. We are committed to accurate reporting and will correct any errors if necessary, as well as adding statements from relevant parties if they choose to provide us with those statements.
God bless Virginia. And God bless America. May this great republic be saved from tyranny and restored to its well deserved glory.
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