The 37 ways money buys policy in Nevada — in plain English.
Our sister site Nevada Political Establishment runs a public-records auditor against NV campaign-finance, lobbyist-disclosure, business-registry, and federal-spending data, producing flags grouped into five "detector tiers." Each detector identifies one specific way money can be moved between donors and policy-makers without crossing a single criminal line. The full taxonomy:
Tier A — Chained / triangulated patterns (the strongest signals)
Multi-source correlations where each leg is independently filed in public records, but only the combination is meaningful.
- D1 — Quid-pro-quo chain. A→B→C linkage between contribution, lobbyist contact, and recorded vote on a single matter.
- D2 — Recusal failure. Legislator voted on a matter affecting a financial interest already disclosed in NRS 281A filings.
- D3 — Adverse-interest representation. Lobbyist or attorney represents both sides of the same regulatory question.
- D4 — Cleanup-of-evidence pattern. Records change, are sealed, or are made unavailable after public-records request.
- D5 — Contribution-to-access ratio. Disproportionate ratio of campaign dollars to public-dollar value of the relationship.
- D6 — Triangulation-on-action. Three independently-filed data points (donor, lobbyist, vote) align on one specific matter.
- Donor-as-state-contractor. Campaign donor is also a vendor on a contract the recipient legislator oversees.
- Lobbyist as own-client NVSOS officer. Registered lobbyist is also the corporate officer of the client they represent.
- Multi-PAC operator. Single individual is the disclosed operator of multiple PACs simultaneously.
- National-money penetration ratio. Percentage of out-of-state money in a state-level race.
- Politician-paid-lobbyist. Legislator or campaign committee paid a registered Carson City lobbyist.
- Quid-pro-quo chain (Indirect). Same as D1 but indirect inference required.
- Sleeper PAC. Registered, $0 disbursed across reporting cycles.
- Spousal-donation bundling pattern. Donor and donor's spouse give to the same recipients, time-aligned.
- Vendor-PAC overlap. State vendor's officers also operate a separately-registered PAC.
Tier B — Temporal correlation ("shadow work")
Time-bounded co-occurrence. Each in isolation is innocent; the temporal-bundled correlation is the signal.
- Arabella ecosystem pass-through (Schedule I). Grant flows through Sixteen Thirty / Hopewell / New Venture funds.
- Contribution change-point on bill activity. Donor's contribution pattern shifts around a specific bill's life cycle.
- Fiscal-sponsorship invisibility (Schedule O). Real recipient hidden behind a fiscal sponsor on Form 990 Schedule O.
- Lobbyist registration vs bill-drop timing. Lobbyist registered immediately before, during, or after a specific bill drop.
- Section 527 PAC transfer. Money moves from 501(c)(4) parent to 527 PAC inside a single window.
- Shell-entity formation timing. NV business entity formed just before a contribution, contract, or lobbying engagement.
Tier C — Relationship anomalies
- Officer/director across multiple tax-exempt organizations with overlapping purposes.
- Same-household pairs giving to the same recipients.
- Lobbyist disclosure gap (NRS 218H reports vs detected money flow).
- Voted on a matter affecting a known financial supporter (less strict than D2).
- State vendors who also contribute politically (the volume signal).
- Registered lobbyists and candidates drawing a state PERS pension.
Tier D — Disclosed-vs-actual divergence
POGO / Government Accountability Institute methodology — what was filed vs. what actually happened.
- Year-over-year budget growth on a specific line.
- Largest absolute spending lines compared to enabling-statute scope.
- Politicians and committees that paid registered lobbyists (reverse-direction money flow).
- Lobbyist-employer disclosure missing or contradictory.
Tier E — Statistical anomalies
- Donor → recipient pairs dominated by in-kind contributions.
- Largest year-over-year underspend (budgeted > $500K, expended < 20%).
- Contribution-and-bill temporal clusters.
Found-in-court research leads
Patterns surfaced by court filings, deposition transcripts, and discovery records.
How tiers are assigned
Detectors are ranked by "evidence tier default" — the level of evidence needed for the pattern to count as a flag worth investigation. Tier A patterns require three independent data points; Tier E patterns can flag on a single statistical outlier. Full methodology at NPE's detectors page.
What the auditor cannot detect
- Verbal agreements. The auditor sees only what is filed.
- Off-shore money flows not captured by FEC, IRS, or NV SOS filings.
- Foreign-actor contributions hidden behind a US-based pass-through.
- Cash bribery. If it happened, the auditor will see only the downstream policy outcome.
Reproducibility
Every detector is open-methodology and runnable against the public records. The NPE detector implementations are committed to the project repository. Anyone can re-run the analysis against the same public-record datasets and reach the same flags.