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Paul S. Ryan, Common Cause’s vice president for policy and litigation, hailed the news as “a win for democracy.” But he argued that the FEC’s “failure to hold former-President Trump and his campaign accountable for this violation lays bare the dysfunction at the FEC.” He noted that the decision comes on the heels of a similar decision by the agency to drop an inquiry into whether Trump violated campaign finance laws when Cohen paid adult-film actress Stormy Daniels $130,000 in the days leading up to the 2016 election. “The agency has again shown itself incapable of fully enforcing the campaign finance laws passed by Congress,” Ryan said in a statement.

Paul S. Ryan, Common Cause’s vice president of policy and litigation, said he had mixed feelings about the outcome. While he felt “vindicated” by the fine, he said, he was frustrated that Mr. Trump, whom he called “the mastermind of the illegal scheme,” had not been held accountable.  Mr. Cohen, who has served time in prison in part for his involvement in the payments, said during his trial that the transaction had been part of an effort to cover up Mr. Trump’s “dirty deeds.” Mr. Pecker had agreed to an immunity deal with federal prosecutors to provide information related to the payments as part of Mr. Cohen’s trial. “He’s the only one not to be held accountable,” Mr. Ryan said of Mr. Trump. The F.E.C. has not yet formally announced the results in this case or revealed all of its internal findings; as the person who filed the original complaint, Mr. Ryan was notified on Tuesday of its outcome.

The FEC investigation of American Media stemmed from a 2018 complaint filed by Common Cause, a Washington, D.C.-based watchdog group. The complaint also alleged violations by Mr. Trump and his campaign, but the FEC has taken no action against the former president. Paul S. Ryan, vice president of policy and litigation at Common Cause, expressed frustration that Mr. Trump has faced no repercussions for the hush money paid on his behalf. “The mastermind of this illegal operation has not been punished, has not been held accountable,” he said.

Bell’s super-PAC reached more than 42,000 people with its fundraising emails—as many as 1,000 donated—and his “e-mail marketing contained material misrepresentations including promising ‘5X’ matching of any donation,” prosecutors noted. While that is a far cry from prosecuting anyone for using the tactic, according to Paul S. Ryan, vice president of policy and litigation at watchdog group Common Cause, it still raises the stakes for any campaign thinking about offering matches they can’t actually make. “Would the DOJ go after a PAC making legitimate political expenditures and contributions, but that falsely used ‘match’ language in its solicitation of contributions? I don’t know and won’t venture a guess,” Ryan says. “But candidates and PACs should now be on notice that the DOJ considers such false ‘match’ language to be a material misrepresentation to donors. All candidates and PACs should steer clear from using material misrepresentations when soliciting contributions.”

The FEC first launched its inquiry in 2018 after the nonprofit government watchdog group Common Cause filed a complaint against the Trump campaign. On Thursday, Paul S. Ryan, Common Cause’s vice president for policy and litigation, said the decision to drop the case showcased how the federal agency is “broken.” “The FEC’s nonpartisan career staff attorneys recommended that the Commission find reason to believe that Trump, his campaign committee, and the Trump Organization committed the violations alleged in Common Cause’s complaints,” Ryan said in a statement. “Today’s announcement that the FEC will not be holding Trump accountable for his campaign finance violations is just the latest display of dysfunction at the FEC.” Ryan also encouraged the Justice Department to pursue an investigation of Trump’s role in the scheme before the statute of limitations expires in October.

”Continued pursuit of the matter required at least four votes,” said Paul S. Ryan, vice president for policy and litigation at Common Cause, which filed one of the complaints against Trump and his campaign. “Republican Commissioners Cooksey and Trainor overrode the career attorneys and Democratic commissioners and killed the investigation.”