Democratic Majority for Israel has become one of the major players in Democratic primaries, spending millions in competitive races to ensure that the most outspoken critics of the Israeli government never make it to Congress.

But some of the money that the group’s super PAC is spending on behalf of Eileen Filler-Corn ― a former speaker of the Virginia House of Delegates running for Virginia’s 10th Congressional District ― is a little different. It originated not in the pockets of wealthy Israel supporters, but with Filler-Corn herself.

Thanks to the quirks of the federal campaign finance system, some of the money DMFI PAC is likely to spend on Filler-Corn’s behalf is money she raised during her career in Virginia state politics. Filler-Corn’s state political action committee, Energized for Change, which supported Democratic candidates for the state legislature over many years, contributed $110,000 to DMFI PAC the day after DMFI PAC endorsed her.

Filler-Corn’s actions ― and a somewhat different step taken by Del. Dan Helmer, a rival Democrat ― illustrate the extent to which federal campaign finance law is riddled with loopholes that candidates are finding ever more creative ways to exploit.

“This represents an aggressive effort to launder big money from a state account into a super PAC,” said Brendan Fischer, a campaign finance attorney who now runs the corruption-focused investigative journalism project Documented.

Unlike federal campaigns, state-level candidates and PACs are not subject to any contribution limits.

So Connor Farrell, a left-wing fundraising consultant, argued in a complaint to the Federal Election Commission in late March that Filler-Corn, who remains in charge of Energized for Change, violated a provision of federal campaign finance law that bars federal candidates from spending or transferring money not subject to federal candidate contribution limits ― also known as “soft money” ― to an entity involved in a federal election.

The law states that a candidate for federal office “shall not solicit, receive, direct, transfer, or spend funds in connection with an election for Federal office... unless the funds are subject to the limitations, prohibitions, and reporting requirements of this Act.”

Farrell also questioned whether Filler-Corn had an arrangement with DMFI PAC where she secured the group’s endorsement with the promise of a donation, which would violate rules barring candidates and campaigns from coordinating with super PACs.

It is very likely that the FEC will take more than a year to even decide whether to initiate an official investigation into the complaint. Virginia’s Democratic primaries are on June 18.

In the meantime, DMFI PAC denied any coordination between the two parties.

“In this and every instance DMFI PAC is scrupulous in its compliance with the letter and spirit of the law,” Rachel Rosen, a spokesperson for DMFI PAC, said in a statement. “Frivolous suggestions to the contrary by political opponents should be dismissed.”

Filler-Corn’s campaign likewise maintains that she devised a complex method for complying with the law’s requirement that any contributions she directed be subject to federal limits.

Even though she transferred $110,000 from her state PAC to DMFI PAC in a lump sum, her campaign can account for it in increments of $6,600, the election-cycle contribution limit for individuals giving to federal candidates.

In other words, if a single, individual donor gave Energized for Change more than $50,000 ― as at least five individuals did ― Filler-Corn would take $6,600 from each and count it toward the $110,000 total.

Filler-Corn’s campaign did not include contributions from corporations, unions or trade groups in its accounting for the money it transferred to DMFI PAC, the campaign said. And Energized for Change stopped raising money once Filler-Corn announced her federal bid in October, ensuring that she would not be guilty of raising “soft money” as a federal candidate.

“The Speaker earned the endorsement of DMFI PAC as well as dozens of others from Democratic leaders and organizations because of her values and track record fighting for Virginia families,” Reed Elman, Filler-Corn’s campaign manager, said in a statement. “We are confident the FEC will dismiss this frivolous complaint.”

Filler-Corn, who was Virginia’s first Jewish and first female speaker, has framed her campaign, in part, as a response to the Palestinian group Hamas’ Oct. 7 terror attack against Israel.

“As a Jewish American, I have deeply felt the tragedies of the past few weeks,” she said in her Oct. 18 announcement. “Congress has been left rudderless at a time of global uncertainty. The American people and our allies abroad deserve better than this.”

Other top contenders are sounding similar notes of support for Israel’s right to defend itself, including Helmer, who is the grandson of Holocaust survivors. The field does have at least one dovish candidate who is in serious contention: state Sen. Jennifer Boysko, who endorsed a cease-fire in the Israel-Hamas war in late October.

Helmer has also leveraged money raised as a state lawmaker for his advantage in a federal race. While his actions have not yet elicited an FEC complaint, they too raise questions about the elasticity of rules regulating super PACs.

Until early November, Helmer ran a federal super PAC, Secure Progress, with the goal of helping Democrats take back Virginia’s House of Delegates and hold the state Senate.

On Nov. 7, the day that Democrats retook the Virginia House, Helmer contributed $100,000 left in Secure Progress’ account to VoteVets, a super PAC that supports Democratic candidates who have served in the U.S. military.

Helmer, an Iraq and Afghanistan war veteran, announced his campaign for Congress on Nov. 15. Two days later, VoteVets PAC, an arm of VoteVets, endorsed Helmer.

The legal basis for what Helmer did with Secure Progress is, on its face, solid. Unlike Filler-Corn, he was not yet a federal candidate when he made the transfer to a super PAC (though he had already commissioned a poll about his candidacy in October). And Helmer’s candidacy for Congress would have required him to shutter his federal super PAC, while Filler-Corn could have, in theory, kept her state PAC open while running for federal office.

At the same time, the timing of Secure Progress’ donation to VoteVets enabled Helmer to transfer the money without even having to account for it in the $6,600 increments that Filler-Corn claims to have detailed. And legality aside, the contribution creates the appearance that Helmer’s donation could have influenced VoteVets’ decision to endorse him.

“Dan closed Secure Progress before deciding to run for Congress, and transferred all money in line with federal law,” Brendon Mills, Helmer’s campaign manager, said in a statement. “He is grateful to partners like VoteVets, which has previously endorsed Dan in every one of his races dating to 2018, for their work” helping elect other Democratic veterans to the Virginia House.

The outside backing of either DMFI PAC or VoteVets could prove decisive in a crowded Democratic primary. In addition to Filler-Corn, Helmer and Boysko, former Virginia Education Secretary Atif Qarni and Dels. Suhas Subramanyam and David Reid have mounted serious bids.

The winner of the primary would have to defend a suburban and exurban Washington, D.C.-area seat where President Joe Biden won by 18 percentage points in 2020, but where Rep. Jennifer Wexton (D) prevailed by less than 7 points in 2022. Wexton, who flipped the GOP-held seat in 2018, announced plans to retire in September following her diagnosis with a fast-progressing, terminal neurological condition.

But there are political risks in Filler-Corn’s campaign-cash three-card monte. For one thing, pro-Israel groups’ big spending in Democratic primaries is already controversial. Democratic voters have been telling pollsters they want to see Biden take a firmer line with the Jewish state, whose invasion of Gaza has killed more than 33,000 people, the majority of them women and children, and brought the region’s population to the brink of famine.

Prior to Filler-Corn, the best-known recent cases of federal candidates testing the limits of the law with transfers from their state PACs involved prominent Republicans. Florida Gov. Ron DeSantis (R) and Rep. Byron Donalds (R-Fla.) both elicited FEC complaints from the nonpartisan Campaign Legal Center for allegedly directing state PAC funds not subject to federal contribution limits into super PACs supportive of their bids for federal office.

Four FEC commissioners must sign off to proceed with an investigation into a complaint, and no such consensus materialized in Donalds’ case. In a May 2022 statement, the FEC’s three Republican commissioners said there was “no reason to believe” he violated the law, because Donalds resigned as chair of the state PAC prior to the transfer of money. DeSantis, likewise, resigned from the state PAC he’d been affiliated with.

Filler-Corn, who remains at the helm of her state PAC, is offering a different defense from Donalds’. But at least one campaign finance lawyer, who spoke to HuffPost on condition of anonymity, believes it is likely to hold up under FEC scrutiny.

Still, the nature of the FEC’s consideration of the complaint against Donalds speaks to just how porous and poorly enforced the United States’ already limited campaign finance regulations are.

It took nearly two years for the enforcement body to conclude it did not want to investigate Donalds ― well after Donalds might have suffered the political consequences of a deeper probe. And the structure of the six-person commission, which by statute can have no more than three people from a single party, has rendered it virtually toothless in an era when Republican policymakers believe, almost universally, that campaign donations are protected political speech that should be as lightly regulated as possible.

“In the best of times, they were never really an aggressive agency,” said Larry Noble, a former general counsel at the FEC who teaches campaign finance law at American University Washington College of Law. “And now they seem deadlocked.”

Noble, who was also a general counsel at the Campaign Legal Center, added: “We don’t really have a campaign finance enforcement system anymore.”