Cambridge Analytica

Cambridge Analytica, formally Cambridge Analytica LLC, was a Delaware limited liability company formed in December 2013 with its principal office at 597 Fifth Avenue in New York City, and part of the family of companies of the British firm SCL Group.¹ Robert Mercer capitalized the company, Steve Bannon served on its board, and its chief executive officer was Alexander Nix.² The company filed for Chapter 7 bankruptcy protection in the United States Bankruptcy Court for the Southern District of New York on May 17, 2018 (In re Cambridge Analytica LLC, Case No. 18-11500-shl).³

SCL Group and its predecessors

Companies House records Strategic Communication Laboratories Limited as incorporated on July 20, 2005, and renamed SCL Group Limited on August 19, 2015.⁴ The officers recorded for that company include Nigel Oakes (director from October 3, 2005 to June 5, 2018), Alexander Waddington Oakes (director from July 20, 2005 to January 28, 2016, and secretary from March 31, 2014 to January 28, 2016), Alexander James Ashburner Nix (director from July 20, 2005 to December 7, 2012, and again from January 28, 2016 to April 30, 2018), Julian Wheatland (director from November 10, 2005 to January 12, 2007, and from December 20, 2007 to June 26, 2020), Roger Michael Gabb (director from November 10, 2005 to March 28, 2018) and Geoffrey Edwin Pattie (director from November 10, 2005 to December 1, 2008).⁴ An earlier company, Behavioural Dynamics Holdings Limited, was incorporated on February 8, 1991 with Nigel Oakes as director and was dissolved on April 26, 2011.⁵

Christopher Wylie, who worked for SCL from June 2013 to November 2014, told the Senate Select Committee on Intelligence in a proffer on May 17, 2018 that SCL had evolved from a single company with Defense, Commercial, Elections and Social divisions into a holding company with subsidiaries, that Oakes was chief executive of the holding company, and that the defense division produced 80 percent of SCL Group's revenue.⁶ Nix, who the committee reported joined SCL in 2003, was described by Wylie as responsible for the non-defense divisions.⁶ Companies House lists Nix as director of SCL Elections Limited from October 17, 2012, SCL Social Limited from February 19, 2013, SCL Commercial Limited from January 10, 2014, and SCL Analytics Limited from October 23, 2015, all to April 30, 2018.⁷ Cambridge Analytica (UK) Limited was incorporated on January 6, 2015 as SCL USA Limited and took its later name on April 14, 2016.⁸

The Digital, Culture, Media and Sport Committee of the House of Commons wrote in its 2019 final report, repeating its 2018 interim report, that SCL had carried out work "for the British Government, the US Government and other allied Governments," that the Ministry of Defence had issued an approbation of SCL after it provided psychological operations training to ministry staff, and that Nix had told the committee that SCL "is a company that operates in the government and defence space, it acts as a company that has secret clearance."⁹ In evidence to the committee, Brittany Kaiser said that before 2015 the "target audience analysis" methodology was considered "weapons grade communications tactics" and that the British government had to be told if it was to be deployed in another country.⁹ Emma Briant of the University of Essex told the committee that SCL Group had delivered counter-Russian propaganda training for NATO at about the time Cambridge Analytica pitched to the Russian oil company Lukoil.¹⁰

USAspending.gov records a contract, SAQMMA17C0115, between the State Department and SCL Group Limited of 1 to 6 Yarmouth Place, Mayfair, London, signed on February 17, 2017, for "target audience research including designing communication and messaging strategy and monitoring its implementation." Performance ran from February 20, 2017 to February 19, 2018, the amount obligated was $456,500, the ceiling with all options was $496,232, and the extent-competed field reads "not competed."¹¹

Formation and ownership

According to Wylie, Steve Bannon introduced Nix to Robert Mercer and Rebekah Mercer as potential investors in SCL Group, and Mercer's lawyer advised that an investment should go through a United States entity rather than SCL itself. Wylie said the company was established with an initial $15 million investment by Mercer, who held 90 percent, with the remaining 10 percent held by SCL Elections in exchange for assignment of its intellectual property, and that Robert Mercer was president, Bannon vice president, Jennifer Mercer treasurer and Nix a board member.² The committee wrote that Wylie suggested Bannon engaged SCL Group and became vice president of Cambridge Analytica in order to "build an arsenal of informational weapons [that] he could deploy on the American population."¹² Wylie added that under this arrangement Cambridge Analytica had no employees of its own and that its clients were to be served by SCL Elections.²

Bannon told the committee that he had met Nix between mid-2013 and 2014 while conducting investment due diligence for Mercer, that he described his role as that of a "typical investment banker," and that Cambridge Analytica was "totally independent" of SCL Group with its own workforce, the appearance of a shared workforce being a product of Nix and some data scientists doing work for both companies.²¹³ Kaiser, who opened the first United States office of the company in Alexandria, Virginia in October 2015, told the committee that at least initially the two companies "were one and the same company," and said the company at its largest had 130 employees, with about 40 in New York and 20 in Washington.¹⁴

The statement of financial affairs filed in the bankruptcy lists Nix as a member of the board of managers and chief executive officer, Rebekah Mercer as a member of the board of managers and vice president, and Jennifer Mercer as a member of the board of managers, each from March 6, 2014 through January 23, 2018.² Rebekah and Jennifer Mercer signed the written consent authorizing the May 2018 petition as the board members.²

Facebook data and Global Science Research

The Information Commissioner's Office reported in November 2018 that the company had sought to use Facebook friend data that was available to application developers under version 1 of the Facebook platform interface, that a collaboration with David Stillwell of the University of Cambridge Psychometrics Centre failed when he refused for data protection reasons, and that in May 2014 Aleksandr Kogan, another academic with links to Cambridge, offered to do the work with his own application.¹⁵ The office reported evidence that Cambridge Analytica staff, including Wylie, helped Kogan set up his company Global Science Research, that the application collected data from about 320,000 users who took a personality test, and that Facebook estimated the total number of users and friends whose data was accessed at about 87 million.¹⁵ Cambridge Analytica commissioned the survey company Qualtrics to pay members of the public less than a dollar to use the application.¹⁵

The Federal Trade Commission found, on the allegations in its complaint to which Cambridge Analytica filed no answer, that the application obtained profile data from approximately 250,000 to 270,000 users and from 50 to 65 million of their friends, at least 30 million of them identifiable United States consumers, and that users were told the application did not collect personally identifiable information.¹⁶ The commission issued its opinion on November 25, 2019 (Docket No. 9383) after Cambridge Analytica filed neither an answer nor an opposition to the motion for summary decision; its bankruptcy trustee did not object to the motion. The commission had accepted consent settlements with Nix and Kogan on July 24, 2019 requiring them to destroy the data and algorithms derived from it.¹⁶

The Senate committee wrote that, according to Kogan, the application ultimately collected approximately 30 million personality profiles "which were transferred to SCL Group," and noted in a footnote that his written testimony to a Senate subcommittee on June 19, 2018 states that the data was not transferred to SCL.¹⁷ The Information Commissioner's Office reported contrary evidence that Cambridge Analytica staff controlled "the manner and frequency" with which the data was harvested and that the harvested data was transferred to a "drop-zone" from which Cambridge Analytica extracted modeled data.¹⁸ Wylie told the committee that the Russian government sponsored some of Kogan's research and that Kogan traveled to Russia to present it; the committee quoted a March 15, 2014 email from an SCL employee to Nix, Wylie and a colleague referring to "the interesting work Alex Kogan has been doing for the Russians."¹⁷ Kogan denied awareness of any evidence the Trump campaign used the data.¹⁷

Clients and payments recorded by the Federal Election Commission

Itemized disbursements to Cambridge Analytica in Federal Election Commission Schedule B records total $16,111,196.81 across 19 committees between June 2014 and March 2018, a figure that includes one entry marked "VOIDED: TO BE REFUNDED" ($10,027) and one memo-coded entry ($20,000); without them the total is $16,081,169.81.¹⁹ The largest recipients of payment by committee were Donald J. Trump for President, Inc. ($5,912,500 in five payments between July 29 and December 12, 2016), Cruz for President ($5,805,552 in 19 payments from July 2015 to June 2016), Make America Number 1 ($1,476,484 in 13 payments from December 2015 to December 2016), the John Bolton Super PAC ($1,152,300 in 13 payments from July 2014 to September 2016), Keep the Promise II ($570,000 in December 2015 and January 2016) and Carson America ($438,065 from May 2015 to January 2016).¹⁹ The North Carolina Republican Party paid $215,000 between July 2014 and June 2015, the Thom Tillis committee $130,000 between October 2014 and December 2015, and the Jobs Growth and Freedom Fund $133,333.33 in October 2014.¹⁹ Two committees named Restoring American Leadership PAC and Restore American Leadership are recorded at $117,100 and $38,625 between May and December 2016, and the committees of Tom Cotton ($20,000, October 2014), Monica Wehby ($20,000, August and October 2014) and Patrick McHenry ($15,000, October 2014) also appear.¹⁹ Art Robinson for Congress, a committee whose registered address is 2251 Dick George Road, Cave Junction, Oregon, paid $20,000 in three payments between June 10 and November 5, 2014, and the committee Bob Huff for Congress reported the voided $10,027 entry on March 9, 2018.¹⁹²⁰

The Trump campaign payments were reported as "data management" and "data management services." The campaign's reports for July, August, September and October 1 to 19, 2016 and the year-end report that carry them are amendments filed on November 19, 2018, December 20, 2018, March 13, 2019, April 5, 2019 and June 28, 2019, each the last in a chain of four or five filings that began with an original report filed between August 2016 and January 2017.²¹ The single payment of $5,000,000 is dated September 1, 2016.²¹ The Senate committee recorded that the first disbursement was on July 29, 2016 and that the payments continued through December 12, 2016.²²

The Bolton PAC's payments to the company began on July 7, 2014 with $25,000 for "research" and continued as "survey research" through September 29, 2016; over the same period the committee's receipts include ten contributions of $500,000 each from Robert Mercer, dated between April 28, 2014 and December 28, 2017.²³ Make America Number 1, whose statement of organization of April 6, 2015 was submitted under a cover letter headed "Keep The Promise I" and whose amended statement signed on June 22, 2016 gives the name Make America Number 1, received $11,000,000 from Mercer on April 10, 2015, and $4,500,000 more in 2016.²⁴²⁵ The committee's disbursements in the same period include payments to Cambridge Analytica, $109,341.25 to Breitbart News Network LLC on November 25, 2015 for "list purchase expense," and $280,641 to Glittering Steel LLC for video production.²⁵ The Mercer Family Foundation return for 2021 lists the Oregon Institute of Science and Medicine at 2251 Dick George Road, Cave Junction, Oregon, and earlier returns list grants to an organization of that name at Cave Junction, including $965,000 in tax year 2011.²⁶ The foundation and the family's other filings are described at Mercer family.

Contacts with the Trump campaign

Kaiser told the Senate committee that discussion of a commercial offer to the Trump campaign began in May 2015, that she and Nix met Bannon in Washington in September 2015, that Donald Trump telephoned Bannon during the meeting and directed that Nix and Kaiser come to New York to meet Corey Lewandowski, and that "eight or ten weeks" of contract negotiations followed without result.²⁷ Bannon told the committee he had no recollection of the call.²⁷ Kaiser also said that almost every client meeting she had with a political figure was preceded by an introduction from Bannon, Rebekah Mercer or Kellyanne Conway, whom the committee described as an advisor to the Mercers at the time, and that Conway was closely involved in moving the company from the Cruz campaign to the Trump campaign.²⁸

The committee recorded that the Cruz campaign spent about $5.8 million on the company and the campaign of Ben Carson more than $430,000, citing a CNN report, and that within a week of Cruz leaving the race the employees working on his campaign began moving to the Trump campaign.²⁷ Rick Gates told the Federal Bureau of Investigation that the campaign decided shortly after the Republican National Convention to use the company, that the Republican National Committee did not want to use it, that Brad Parscale was reluctant, that Jared Kushner wanted to use it and negotiated a package with payment at the end of the campaign.²² Kushner told the committee that the Mercers aggressively advocated use of the company and that the campaign engaged it to secure the Mercers' support.²² Parscale said he decided to hire the company in June 2016 after approval from Paul Manafort and Kushner, that he declined its offer of "psychographic profiling" services, and that he used Republican National Committee data rather than the company's data.²²²⁹

The committee obtained a campaign data team presentation of August 22, 2016 with a slide depicting data flowing in both directions between the campaign and Cambridge Analytica, with the company's node titled "Digital Media Psychographic Analysis," and another slide showing arrows between its "Psychographic Analysis" and both the Republican National Committee's "GOP Data Center" and the campaign's San Antonio operation, which it called "Project Alamo."²⁹ The committee wrote that documents it obtained suggested that the company's data may have been used in support of the campaign and that the campaign may have leveraged its psychographic analysis capabilities.²⁹ Gates told the FBI that he later learned campaign data was transmitted to and analyzed in the United Kingdom, which concerned him.²⁹ Kaiser said that Project Alamo was "built completely from scratch" from the Republican National Committee's Data Trust database and purchased data sets.²⁹

Russian and WikiLeaks contacts

Wylie said that from spring 2014 through 2015 Cambridge Analytica representatives met representatives of Lukoil, that Nix's presentations included discussion of rumor and disinformation campaigns, and that in May 2018 he told the Senate Judiciary Committee that Lukoil "has formal information sharing agreements with the Russian Federal Security Service."³⁰ Kaiser told the committee the discussions concerned a customer loyalty application for Lukoil's stations in Turkey, said she was told the data could also be useful for political activities there, and furnished a February 2015 presentation prepared by SCL Commercial; neither she nor Wylie believed that a contract resulted, and the committee stated that it did not independently corroborate the allegation that Lukoil intended to use the company to affect elections.³⁰ The committee noted that the Office of Foreign Assets Control had added Lukoil to its Sectoral Sanctions Identifications List on September 12, 2014.³⁰

Wylie also told the committee that in spring 2014 Bannon approved focus groups about Vladimir Putin and Russian expansionism preparatory to a predictive model, and that Bannon and Konstantin Kilimnik were two of three people likely responsible for the idea.³¹ Sam Patten, a consultant who worked for the company in Nigeria, Mexico, Kosovo and the Czech Republic, told the committee there was "no connection" between Kilimnik and Cambridge Analytica; Kaiser said that on the Nigerian project the company may have assisted its client in retaining former Israeli intelligence officers working privately to conduct opposition research.³¹

The committee reported open-source accounts that during the 2016 campaign Nix emailed Julian Assange about the possible release of Hillary Clinton's deleted emails, and that Assange said in October 2017 that WikiLeaks had rejected an approach by Cambridge Analytica. The committee obtained no additional information, and Bannon and others close to the campaign said they had no prior awareness of the contact.³² The committee also recorded that it was unable to obtain the company's corporate communications, which were in the hands of United Kingdom authorities, and that Nix "generally disregarded the Committee's requests for an appearance."³³ It found "no convincing evidence that Russia's government or intelligence services worked with or through" Cambridge Analytica, Psy Group or Colt Ventures in furtherance of the 2016 interference.³³ Cambridge Analytica, LLC is named among the respondents in matters under review 7207, 7268, 7274 and 7623 before the Federal Election Commission, in which Commissioners Shana Broussard and Ellen Weintraub issued a statement of reasons citing Volume 5 after a certification dated April 22, 2021; the text of the statement concerns the Russian Federation, the Internet Research Agency and the Trump committee and does not mention Cambridge Analytica outside the caption.³⁴

Regulatory and criminal proceedings in the United Kingdom

The Information Commissioner's Office issued a monetary penalty notice of £500,000 to Facebook on October 25, 2018, the highest fine permitted under the Data Protection Act 1998, citing lack of transparency and security failures relating to the harvesting of data.³⁵ The office also executed a warrant at the company's premises at 8 p.m. on March 23, 2018, seized servers and other material, and reported that Cambridge Analytica and SCL Elections entered administration on May 3, 2018, that an enforcement notice of May 4, 2018 required it to answer a subject access request from the American academic David Carroll that had been made in January 2017, and that the deadline of June 3, 2018 passed without compliance.¹⁸ The office reported that Nix and Kogan had declined invitations to voluntary interviews under caution and that it would have issued a substantial fine had the company not been in administration.¹⁸ SCL Elections pleaded guilty at Hendon Magistrates' Court on January 9, 2019, the day set for trial, to failing to comply with the enforcement notice; press reports gave the penalty as a fine of £15,000 with £6,000 in costs and a victim surcharge of £170.³⁶ The Information Commissioner's 2020 letter to Parliament gives the fine as £18,000.³⁷

On October 2, 2020 the Information Commissioner, Elizabeth Denham, wrote to the chair of the Digital, Culture, Media and Sport Committee that the office had concluded its investigation, that the company had purchased commercially available data amounting at one estimate to more than 130 billion data points, mostly about United States voters, to combine with Facebook-derived data from Kogan, that its models were mostly built from "off the shelf" tools, that the office found no further evidence to change its view that the company was not involved in the European Union referendum campaign beyond early inquiries about UK Independence Party data, and that it found no additional evidence of Russian involvement in the servers it obtained.³⁷ The letter also reported evidence that in its last stages the company was drawing up plans to move its data offshore to avoid regulatory scrutiny, which it did not carry out before it ceased trading.³⁷

The Insolvency Service announced in September 2020 that Nix had given an undertaking disqualifying him from acting as a company director for seven years from October 5, 2020, having, in the service's words, caused or permitted SCL Elections or associated companies to act with a lack of commercial probity by marketing services including "bribery or honey trap stings, voter disengagement campaigns, obtaining information to discredit political opponents and spreading information anonymously in political campaigns." The service did not say whether any such services were performed, and Nix told Reuters he had made no admission of wrongdoing.³⁸ The Digital, Culture, Media and Sport Committee had recorded in February 2019 that the Insolvency Service was investigating the directors of SCL Elections, SCL Group, SCL Analytics, SCL Commercial, SCL Social and Cambridge Analytica (UK) under the Company Directors Disqualification Act 1986.³⁹

Emerdata and the end of the group

Emerdata Limited (Companies House number 10911848) was incorporated on August 11, 2017 with Wheatland as a director, and its persons with significant control from incorporation were Wheatland and Dr Alexander Bruce Tayler, each holding more than 25 percent and up to 50 percent until January 23, 2018.⁴⁰ From January 23, 2018 the register shows Cambridge Analytica Holdings LLC, with an address on Orange Street in Wilmington, Delaware, as holder of more than 50 percent and less than 75 percent of shares and votes until August 9, 2022; since that date the register carries a statement that there is no registrable person.⁴⁰ The register records the officers appointed on January 23, 2018 as Nix (resigned March 28, 2018), Johnson Chun Shun Ko (resigned May 9, 2018), Cheng Peng (resigned May 8, 2018) and Ahmad Al Khatib (resigned May 7, 2018); Tayler was a director again from March 28 to April 18, 2018, Gary Ka Chun Tiu from June 12, 2018 to December 3, 2024, and Wheatland until May 22, 2019.⁴⁰ Rebekah and Jennifer Mercer were appointed directors on March 16, 2018 and remained in office as of the register consulted on October 1, 2026, with Jacquelyn James-Varga (appointed May 22, 2019) and Bradley David Golub (appointed December 3, 2024).⁴⁰

The Digital, Culture, Media and Sport Committee reported in February 2019 that Emerdata had not gone into administration, was the largest creditor of SCL Elections and was paying the administration costs, and listed shareholders as of August 10, 2018 that included Cambridge Analytica Holdings LLC, Tayler, Wheatland, trusts for the benefit of Rebekah, Jennifer and Heather Mercer, Alexander and Catherine Nix, five members of the Marland family, Henry and Roger Gabb, Nigel and Alexander Oakes, and Reza Saddlou-Bundy.³⁹ The committee recommended that the National Crime Agency investigate the connections between SCL Elections and Emerdata.³⁹ The committee also reported that SCL Insight Limited, owned by Nigel Oakes, had been spun off in the 2017 reorganization.³⁹

Emerdata entered administration on December 9, 2024, the register names Benjamin Stanyon and Nedim Patrick Ailyan as practitioners, records a cessation to act on April 8, 2026, and gives the registered office as care of Opus Restructuring LLP, Milton Keynes.⁴⁰ SCL Group Limited, SCL Elections Limited and Cambridge Analytica (UK) Limited were in administration from May 3, 2018 to April 17, 2019, then in compulsory liquidation on a petition of August 13, 2018, which concluded on September 1, 2025; the first two were dissolved on January 31, 2026 and the third on January 30, 2026.⁴¹