Campaign finance watchdog groups filed a complaint Wednesday with the Federal Election Commission alleging that Rick Santorum's presidential campaign illegally directed a donation to a super PAC.

The complaint is based on a Sunlight Foundation report in which Louisiana mega donor Bill Doré recounted how he was instructed to donate $1 million to the Red, White and Blue Fund, the super PAC supporting Santorum's 2012 run for the presidency. It comes days after Santorum triggered speculation about an encore presidential run with a visit to Iowa, the state that will kick off the 2016 campaign with its much-watched caucuses. 

“Mr. Doré’s account of his interaction with Mr. Santorum and his staff, if true, reveals a clear violation of federal campaign finance law,” said Paul S. Ryan, Campaign Legal Center senior counsel in a statement.

That's because federal law bars candidates and their staff from directing to a super PAC any more than the amount of money they can legally raise themselves. The FEC has set that amount at $5,000 per year.

Santorum's spokesperson denies any wrongdoing.

"We have not received a copy of the complaint and when we do, we will refer it to our attorney. We are confident that neither Sen. Santorum nor any campaign staff member solicited funds in excess of the federal limits or from sources prohibited under federal law," Santorum spokesperson Virginia Davis wrote in an email.

The complaint does not allege that the Santorum campaign solicited funds, but rather directed them.

Under federal law directing campaign money means to "guide…a person who has expressed an intent to make a contribution…by identifying a candidate, political committee or organization, for the receipt of such funds," the complaint notes.

Doré, a savvy oilman who built a $2 billion company, told the Sunlight Foundation that he did not know of the Red, White and Blue Fund's existence before flying to Florida in early January 2012 to meet Santorum, whom he liked after seeing him on television, and decided he wanted to contribute $1 million to his campaign. They enjoyed a private dinner and then Doré met his campaign staff.

Doré initially told a Sunlight Foundation reporter that Santorum, at the dinner, told him about the existence of the super PAC and that Doré could donate to it.

In a subsequent phone call with a reporter who had expressed surprise over that account, Doré said he misremembered the evening and that it was Santorum's staff, rather than the ex-senator, who told him about the super PAC. He said that female staffer told him he could give his $1 million to the Red, White and Blue Fund and provided him with the address.

Such details are irrelevant, according to the Campaign Legal Center and Democracy 21, the two groups filing the complaint. They contend that directing the money is a violation of campaign finance law whether it was Santorum or his campaign workers giving the instructions.

When it receives complaints, FEC legal staff typically follow a routine process before asking the commissioners whether to start an investigation. 

Within five days of receiving a complaint, the FEC's staff sends a copy to the accused parties. The FEC would give Santorum 15 days to refute the claims. Then the legal staff evaluates the complaint and response before giving a recommendation to commissioners about whether there is "reason to believe" a violation has occurred. If commissioners think there is, the FEC would conduct a formal investigation.

One potential complicating factor: The FEC's legal staff is under heavy scrutiny from Republican commissioners. GOP Commissioner Donald McGahn is campaigning to adopt a new enforcement manual to prevent the staff from using publicly available reports and contacting other agencies before the commissioners sign off on an official investigation. Even Congress has entered the enforcement fight.

(Photo credit: Gage Skidmore via Flickr)