From the FEC web site regarding the matter: Keyes is ultimatley responsible but the majority of the day to day work should have fallen on his staff and especially the Accountant or Legal Eagles providing the oversight and compilation of the data for the FEC.

Case Summary

Summary

Case #	5442
Case Name	KEYES 2000, INC.
Case Type	MUR
Total Respondents	3
Election Cycle	2000

Penalty Amount	Disposition	Respondent
$23,000.00	Conciliation-PPC	Constantine, William Leo
$23,000.00	Conciliation-PPC	Keyes 2000, Inc.
	RTB/NFA	True, Paul

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Other Parties	Relationship	Respondent
Audit Division	Complainant
Braden, E. Mark, Esq.	Respondent's Counsel	Constantine, William Leo
Braden, E. Mark, Esq.	Respondent's Counsel	Keyes 2000, Inc.
Constantine, William Leo	Treasurer	Keyes 2000, Inc.

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Disgorgement Amount	Name
$95,302.00	Constantine, William Leo Keyes 2000, Inc.

4.	MUR 5442

	RESPONDENTS:	(a) Keyes 2000, Inc., William L. Constantine, treasurer (b) Paul True
	COMPLAINANT:	FEC Initiated (Audit)
	SUBJECT:	Excessive contributions; excessive contributions in the form of stale-dated checks; failure to dispose of cash contributions over $50; excessive cash disbursements
	DISPOSITION:	(a) Conciliation Agreement: $23,000 civil penalty* Respondents will remit $95,302 to the United States Treasury. (b) Reason to believe, but took no further action* [re: excessive contribution] Sent admonishment letter.The Commission audited the Committee for the period from January 1, 1999 through December 31, 2000 . The audit report found that Respondents violated FECA by accepting excessive contributions; had excessive contributions related to stale-dated checks; failed to dispose of a total of anonymous cash contributions that exceeded $50; failed to adhere to an appropriate accounting method for contributions under $50; and made cash disbursements in excess $100.
	DOCUMENTS ON PUBLIC RECORD:	Documents from this matter are available from the Commission's web site at http://eqs.sdrdc.com/eqs/searcheqs by entering 5442 under case number. The audit report is also available at the Commission's web site at http://www.fec.gov/audits/p00-01-08.pdf These documents are also available in the FECs Public Records Office at 999 E St. NW in Washington .