"The allegations made in AJ Delgado’s declaration paint a deeply troubling picture of potentially illegal activity carried out by Donald Trump’s campaign," CREW president Noah Bookbinder said. "The FEC must conduct an investigation to determine the validity of these claims and establish the degree to which any wrongdoing occurred."

According to Delgado, Trump's campaign made several large payments to the Kasowitz Benson Torres law firm following the 2020 election totaling more than $4 million, that she says were explicitly done to circumvent federal campaign finance law. Millions of dollars were also paid to the firm's compliance firm, Red Curve Solutions, which the Beast reported does not conduct any legal services.

Delgado claimed in her declaration that during settlement negotiations in 2017 that ultimately fell apart, Trump campaign attorney Marc Kasowitz said that "Trump and the Campaign would need to keep this confidential," and stressed that Trump was "known for ‘not settling.'"

"My attorneys expressed this would not be possible because disbursements by a Campaign are public record," Delgado recalled. She said Kasowitz then "dismissed the concerns easily," saying her concerns about campaign finance disclosure laws was "not a problem at all." He allegedly then told her "what we would do is the campaign pays me and then I cut a check to you guys."

A spokesperson for the firm dismissed Delgado's concerns, telling the Beast that "Ms. Delgado’s accusations that there were FEC violations or that the firm acted as a ‘middleman’ to ‘hid[e] settlement payments to women’ from the Campaign are pure fantasy and false."

According to FEC records, Trump's Make America Great Again PAC and his primary campaign organization, Donald J. Trump for President, Inc., paid the firm roughly $4.5 million between 2016 and 2021. The Beast reported that Trump using PACs and law firms as pass-through entities for payouts is a common practice. An FEC record from February of this year, for example, shows a payment to attorney Alina Habba in the amount of $392,638.69 for "legal consulting," which was the exact dollar amount the ex-president was required to pay the New York Times for defamation.

The 45th president of the United States is in the midst of a criminal trial, in which he faces 34 felony counts of falsifying business records relating to hush money payments to women claiming to have had extramarital affairs with him. In a manner similar to what Delgado described, Trump is accused of disguising reimbursements to his former attorney Michael Cohen — who will testify against him next week — by classifying them as legal fees. Cohen is expected to say on the witness stand that there was no such legal retainer and that the payments were reimbursement for him personally covering the hush money payments.