The FEC’s ruling was detailed in a letter last week to director Kendra Arnold of the Foundation for Accountability and Civic Trust, a watchdog group that demanded an investigation into Americans for Progressive Action USA in May 2020. That super PAC, Arnold argued in a complaint at the time, violated the Federal Election Campaign Act with fabrications on its financial disclosures.

“On behalf of the American public, I am pleased this case has been fully adjudicated and the truth revealed,” Arnold said in a statement.

“Unfortunately, it took the commission over four years to issue its ruling in a case where the law was clear, which cannot fill the public with confidence that those who violate federal law will be held accountable in a timely manner,” Arnold said. “Cases before the FEC are often time sensitive and they must act more swiftly to discourage would-be violators from this kind of unlawful behavior.”

The discrepancies included a mysterious $4.8 million sum that the PAC received and a $2.5 million sum that it claimed to spend on advertising with businesses that never heard of the PAC — despite advertising platforms having no record of the activity.

Moreover, the PAC’s reported telephone number for its treasurer was disconnected, while its reported bank was said to be located in a city not matching the zip code.

“Respondents knowingly and willfully violated 52 U.S.C. § 30104(b) by filing a false Statement of Organization, false disclosure reports, and false 48-Hour Independent Expenditure Reports with the Commission,” FEC officials wrote in the September letter, which also named the PAC’s official, Christopher Richardson.

Richardson, who is from Pennsylvania, pleaded guilty earlier this year to two charges stemming from the super PAC’s fabricated transactions, according to a Justice Department press release. The FEC’s new ruling demanded Richardson and the PAC “cease and desist” from violating federal law and asked the PAC to file accurate reports with the FEC.

But no civil penalty will be due, according to the FEC. Richardson used the false name Evan Jones to file documents with the FEC.

“Respondent Christopher Richardson, through the submission of financial documentation to the commission and additional representations, has indicated that financial hardship prevents him from paying any civil penalty to the commission,” FEC officials said. “Richardson is currently in the process of paying restitution in the amount of $352,000 and has limited assets. The commission regards these submissions and representations as material representations.”

The chain of events comes after a Politico report in 2020 on the “phantom” super PAC’s shady activities. The fabricated financial disclosures baffled campaign finance experts, who expressed confusion over why someone would make up fake FEC spending reports.

“I’ve seen cases when candidates reported all these fake donors and all these fake expenses … so they can come out and say they raised all this money,” Nancy Watkins, a veteran GOP treasurer for political committees, told the outlet in 2020. “There’s very wealthy people who are easily fooled.”