Is this shadowy network of PACs ripping off pro-life voters around the country?

The telemarketer on the phone told Sharon Toborg that she could help end abortion—for a small, one-time donation of $75.

But Toborg, the treasurer of a pro-life group in Vermont who’s been involved in the anti-abortion movement for 30 years, had never heard of the organization she was being asked to donate to, called “National Campaign.” And as she started researching the group, she didn’t like what she found.

National Campaign is one of four different political action committees, all with unusually vague names, registered by the same person. This shadowy network of PACs claim to be supporting pro-life candidates and mobilizing voters against Hillary Clinton. But they’ve also funneled millions of dollars to two shell companies that seem to exist mostly on paper, according to Federal Election Commission records.

It’s not clear who is benefiting at the companies or PACs, or whether the arrangement has broken any laws or FEC rules. But the PAC network may be taking advantage of passionate, older pro-life donors making small contributions.

National Campaign PAC was registered in May 2014 by a woman named Ann Mattson, who is listed as the group’s treasurer. Its address is listed as a co-working space in Wilmington, Delaware. A website for the PAC—calling itself “The Pro-Life Committee”—says it is “a federal political action campaign committed to the sanctity of human life.”

Since 2014, National Campaign has reported raising more than $5.75 million from donors, FEC records show. While it has contributed only $12,500 to pro-life political candidates, it has also reported spending more than $4.4 million on phone banks, direct mail, and website design at two companies: “RFP Services, LLC” and “Political Issue Advocacy, LLC.”

Those two companies were incorporated within two days of one another, less than two months before the PAC started soliciting donations. RFP was registered in Delaware on March 24, 2014, and Political Issue Advocacy was registered in South Dakota on March 26, 2014. The true owners of both companies are not identified in the incorporation papers, which instead name a registered agent who accepts legal documents for them. (The same system was used in the shell companies unveiled by the Panama Papers leak.) Both companies are listed with the same registered agent.

It’s difficult to determine what, if anything, these companies actually do. RFP Services doesn’t seem to have a website, a phone number, or a physical office, other than its registered agent. There is no online record of it employing anyone or conducting any services. It’s a similar story with Political Issue Advocacy. While it does have a website, it’s very generic, with stock photos of smiling telemarketers and jars of pennies. There’s no listing of an address, a phone number, any employees’ names, or any past clients. There is an email address listed on the site, but no one responded to a message I sent.

And there’s no record of any federal political candidates or PACs—other than those run by Mattson—paying a single dollar to RFP Services or Political Issue Advocacy for any phone banking or direct mail services.

Since she started National Campaign, Mattson has also launched three more PACs, each with similarly vague names. In 2015, she started “Voter Education,” which has raised $798,604 and also spent most of that funding on Political Issue Advocacy, LLC and RFP Services, LLC. Last week, another Mattson PAC popped up: “Coalition.” (Yes, that’s its full name.) On Wednesday, she registered a fourth PAC, “National Security.” Neither of the two latest PACs have any record of contributions or expenditures so far.

It’s not only the spending of these PACs that raises eyebrows—the donor records are also opaque. Federal election committees must report each individual donor who gives more than $200 in an election cycle. Smaller donations can be incorporated as a bulk sum of “unitemized” contributions.

Since National Campaign launched, FEC filings show that 98.4% of the total funds it has raised are listed as unitemized contributions—$5,667,419 in all. (Voter Education PAC has an even higher rate.) There’s nothing technically wrong with this, if all of the money came from contributions below $200. But even Bernie Sanders’ presidential campaign, famed for its tsunami of small dollar donations, only listed 57.1% of its total contributions as unitemized.

Brendan Fischer, a lawyer at the Campaign Legal Center, a good government group, said he couldn’t remember ever seeing a PAC raise such a high percentage of money from unitemized contributions. “For a group that has no apparent public presence and appears to be operating out of a co-working space, it’s highly questionable how they can get that level of money,” Fischer said. “It certainly raises all sorts of red flags.”

Robert Kelner, a prominent election lawyer at the D.C. firm Covington & Burling LLP, agreed. “This would have to be an exceptionally successful small dollar fundraising effort,” he said. “Without knowing more, it’s impossible to say for sure whether it’s fraudulent, but it definitely looks peculiar.”

Mattson, the treasurer of all four PACs, is the only person listed in connection with any of them on FEC forms. Multiple attempts to contact her proved unsuccessful: I called her and left messages at the five different phone numbers listed on the FEC forms, and emailed the six different email addresses listed for her. I also left a message for her at the co-working space in Delaware where National Campaign lists its address. When I called one phone number associated with Mattson on a domain name registration, a server at a McDonald’s in Atlanta picked up the phone.

I also reached out to the two LLC’s through their registered agent, and neither responded. Corporate documents for Political Issue Advocacy are signed by someone named Kathleen Johnson, but it’s not clear whether she’s an owner or associated with the registered agent. I was unable to find any contact information for Johnson.

In recent weeks, National Campaign has reported spending $230,000 for phone banks opposing Hillary Clinton, again spending the money at Political Issue Advocacy, LLC. Since 2014, it has also donated a total of $12,500 directly to the campaigns of several dozen Republican congressional candidates.

The network of PACs has been an annoyance to more prominent pro-life groups. Toborg, the treasurer of the Vermont Right to Life committee PAC, said she was “shocked” by the amount of money the PACs had raised in just two years of operation.

“It certainly seems suspicious to me that these two companies are formed and all of a sudden there’s a political committee formed that’s doing millions of dollars of business with each of them,” Toborg said. “They are pulling millions of dollars in, supposedly to promote pro-life causes, and it appears to me that they’re mostly paying some businesses.” Toborg said she’s warned her members not to donate to the PACs.

But it’s unlikely that the FEC would be able to take action against the PAC network. Current law essentially lets PAC treasurers do what they want with the money they raise. Ann Ravel, the former FEC chair, has said her agency is mostly toothless against PACs that raise money by misleading donors, and urged Congress to allow the commission to sanction fraudulent fundraising. “The law doesn’t give the FEC the tools or the authority needed to address scam PAC activity,” she wrote in a Roll Call op-ed last year.

The identity of the people behind the PACs and the two LLCs is a mystery.

For the record, the National Campaign PAC is not associated the National Campaign to Prevent Teen and Unplanned Pregnancy, a charity with a similar name. “We have absolutely zero, zero affiliation with them,” said Bill Albert, a spokesperson for the unplanned pregnancy group, which advocates for contraception and does not take a stance on abortion. As a 501(c)(3) nonprofit, it would be against IRS rules for the group to get involved with political advocacy.

And while we’re debunking red herrings, it’s worth mentioning that there’s another, legitimate marketing company in Colorado called RFP Services. Joe Bullard, their Vice President, told me he’s never heard of National Campaign or Ann Mattson and his company has never worked with any political campaigns.

In collecting donations, the PACs seem to be taking advantage of the most passionate pro-lifers, who don’t ask too many questions about where their money’s going. Many of the itemized donations listed come from older donors and retirees.

Raymond Fink, 85, who lives in Michigan, gave National Campaign a total of $1,000 in almost a dozen small donations over the last year. “Anytime anybody is against the butchering of babies in the womb, I’ll probably give to them,” he told me. “I don’t usually stop to check out what they are.”

Elaine Grant, a retiree in upstate New York, said telemarketers for the PAC who convinced her to donate $400 told her the money would be used for “lobbying lawmakers and stuff like that.” But no money from National Campaign has ever been earmarked for lobbying expenses, and searches in the House and Senate lobbying disclosure databases turn up zero records for National Campaign or any of the organizations involved. “I’m mad,” she said when I told her about how the money was going to the two companies.

Dominick Tenuto, 69, of Staten Island, gave $500 to National Campaign after getting a letter from them requesting donations to help the Republican Party. “It seemed legit,” he said. “It makes you feel like you’ve been victimized. I guess this is the world we live in.”

“It’s sad because pro-life people are really very generous to the cause,” Toborg said. “You think you’re giving money to a cause you believe in—and it’s not quite what it seems.”