Donald Trump’s pick for CIA director, 59-year-old John Ratcliffe, doesn’t have anywhere close to his boss’s wealth. But in a Trumpian move, he figured out how to shift campaign funds to his own pocket.

Ratcliffe’s congressional campaign was sitting on $403,000 shortly after he stepped down from Congress. Thanks to a variety of maneuvers, most of that money ended up back with Ratcliffe, according to a Forbes analysis of filings with the Federal Election Commission.

First, he paid his wife. In 2021, after five years in Congress and one in Trump’s administration, John Ratcliffe appointed his spouse, Michele, an attorney, to serve as the treasurer of his old congressional campaign. She didn’t have much work to do–the campaign was making an average of nine transactions a month–but she nonetheless collected $44,000 for her services.

Michele Ratcliffe denies any wrongdoing. “Retention of a paid treasurer of a campaign committee is required under FEC rules,” she told Forbes. “Uncompensated financial compliance services would be improper as an ‘in kind’ contribution in excess of campaign donation limits.”

That’s not true, as Michelle Ratcliffe herself should know. Seven years before she started charging her husband’s campaign, Michelle Ratcliffe did the same job for free. “Treasurers, particularly in House races, can and often do serve as unpaid volunteers,” explained Brett Kappel, an attorney specializing in campaign finance. “There is even a special exception that allows legal and accounting firms to provide their services for free to a campaign committee to ensure it is complying with FEC requirements, and those free services aren’t considered a contribution.”

In addition, John Ratcliffe apparently used campaign funds to promote his consulting business. Federal regulations explicitly prohibit candidates from using campaign money for personal expenses. But in mid-2021, Ratcliffe’s campaign paid Telegraph Creative, an Alabama-based firm, $11,500 for “website design.” The funds appear to have funded a personal website, rather than a campaign one. Metadata from a site for Ratcliffe’s private consulting business indicates that Telegraph created that web page. Dates in the URLs of john-ratcliffe.com, suggest that work on Ratcliffe’s business site began around the time of those payments. At one point, the website was even hosted on the same server as Telegraph Creative’s own website. Additionally, blog entries on the news section of Ratcliffe’s site list “Telegraph” as the author. Telegraph Creative did not respond to inquiries. “All campaign account fees and expenditures were reasonable, necessary and charged at or below market rates,” said Michelle Ratcliffe, when asked if campaign funds were used on her husband’s personal website.

John Ratcliffe also figured out a third way to route campaign money to himself. Two years after he left Congress, the Supreme Court ruled in FEC v. Ted Cruz for Senate that restrictions on candidates using donations received after an election to repay loans they made to their campaigns were unconstitutional. That allowed Ratcliffe to come back to his still-open, barely functioning congressional campaign and legally cut himself a $225,000 loan-repayment check, zeroing out the remaining balance of a total of $460,000 in loans he had made to his campaign years earlier.

He still had a little bit of spare change leftover. The $122,000 of campaign funds that were not directed to the Ratcliffes primarily went to other political committees (including Rep. Lee Zeldin’s gubernatorial campaign in New York), a previous treasurer, compliance services, travel expenses and the Tunnel to Towers Foundation.

None of the transactions ever led to consequences, as Michelle Ratcliffe pointed out in a statement. “To reiterate, the FEC has accepted all original and amended reports and reflects that there are no outstanding issues,” she said.