Perhaps no other single residence has been as lucrative for Janet Nguyen’s campaign coffers in recent years as 530 Dickinson Circle in Placentia.

Since 2012, nearly $34,000 in contributions to Nguyen’s supervisor and state Senate campaigns have come from five unrelated individuals who claim the upscale home as their primary residence, according to a Voice of OC analysis of Nguyen’s campaign finance records.

Records show the five individuals donated a total of $11,400 to the Friends of Supervisor Janet Nguyen 2012 committee within a two-day period in May of that year; and three of them gave $22,553 to Nguyen’s Senate campaign in 2013 and 2014. Some of the donations came from Lee’s Sandwiches franchises that are owned by one or more of the home’s residents, according to the records.

Such large amounts flowing to campaigns from one residence raise suspicion and could be illegal, say campaign finance experts. However, the available public records do not reveal enough to make a determination, the experts say.

Still, the donations from the Placentia home add another layer of intrigue to an ongoing investigation by the state Fair Political Practices Commission (FPPC) into potential political money laundering on behalf of Nguyen, who won the 34th District state Senate seat in the Nov. 4 election.

In October, Voice of OC reported that the FPPC had subpoenaed the phone and bank records of 11 donors to Nguyen’s 2012 campaign for supervisor. The FPPC has claimed in court documents that eight donors to the committee were illegally reimbursed for campaign contributions.

Those same court documents cite evidence showing patterns of contributions from individuals with the same home address and employer, misreported addresses, occupation and employer information; and individuals listed as “umemployed” or “student” giving significant amounts of money.

The documents also point to common red flags that investigators look for in campaign records that are consistent with money laundering schemes, such as multiple donors living at the same address, multiple large contributions with check dates within a seven day period, and multiple large contributions from employees of the same employer.

Although the Placentia house donors are not among the 11 donors seeking to block the subpoenas, their contributions are likely being scrutinized by FPPC investigators.

Here is a breakdown, based on public disclosures from the committees, of the donations from residents of the Placentia home:

  • On May 29, 2012, Alexander Pham, Nathan Long Dang, Huong Thi Nguyen and Quang Nguyen all contributed the maximum allowable amount of $1,600 to Nguyen’s supervisor campaign. Nguyen Vu donated $1,800 that day. At the time of his contribution Vu listed a residential address in Garden Grove, although he is currently registered to vote at the same Placentia home.
  • On May 30, 2012, Nguyen’s supervisor campaign received a $1,600 contribution from Trish Café Inc., which listed the Placentia address in business and campaign documents and owned a Lee’s Sandwiches restaurant in West Covina until it filed for bankruptcy in 2013. A separate Lee’s Sandwiches in Las Vegas, Nevada also donated $1,600 that day.
  • Since 2008, Huong Thi Nguyen, Quang Nguyen, Dang and Pham have all at one time or another been listed on business documents for Trish Café Inc. filed with the Secretary of State’s office. Court documents show Vu as the sole owner at the time of bankruptcy.’
  • The Lee’s Sandwiches in Las Vegas is owned by Goldland Capital Inc., which listed Huong Thi Nguyen as the owner and Pham as a financial officer, according to 2014 business license documents filed in Clark County Nevada.
  • In 2013 and 2014, Nguyen’s Senate campaign received contributions from Huong Thi Nguyen, $253; Pham, $7,500; Dang, $8,200; and the Las Vegas Lee’s Sandwiches $6,600. The statewide cap is higher than the local cap at $4,100 per person, per election cycle.

None of the donors returned phone calls and messages at their homes requesting comment for this article.

TINCUP Violation?

Local campaign finance watchdog Shirley Grindle says the intertwined business relationships are problematic. Depending on what stake each person has in the businesses; the donations could be in violation of the county’s local campaign finance ordinance, Grindle said.

The ordinance, called “Time is Now, Clean Up Politics” or TINCUP, limits individual contributions to local candidates at $1,600. Contributors who have a controlling interest in a company must disclose that relationship so that total contributions remain within the individual limit.

A person has a controlling interest if they hold at least a 50 percent stake or if they are responsible for decisions about the company’s political contributions.

“If five people all made contributions on their personal checking account, there’s nothing wrong with that,” Grindle said. “But if I make a contribution under my name, and six months later I send a contribution from Lee’s Sandwiches, and I am a 50 percent or more owner, I’m supposed to notify the candidate’s committee, [so] that those contributions get aggregated.”

Candidates and their committees are also obligated to do due diligence to identify those connections, Grindle said.

Tough to Prove

The FPPC declined Wednesday to comment on whether the Placentia house donors have been subpoenaed or if they are part of the money laundering probe, citing a policy not to discuss ongoing investigations.

Unlike many of the subpoenaed donors who listed their employment status as unemployed, the Placentia house donors appear to be independently wealthy, driving Mercedes Benz cars, having multiple real estate investments in Las Vegas and owning businesses in and out of the state.

Pham, Vu and Quang Nguyen own a company and registered trademark called NexBeauty which is involved in the production of the Mr. and Ms. Vietnam Continents beauty pageants in Westminster and Las Vegas.

The presence of one or more of these factors might raise eyebrows, but it doesn’t necessarily prove a potential money laundering scheme, according to Jim Wedick, a former FBI special agent who retired in 2004 who now consults on public corruption and fraud, among other crimes.

“There can be five people in a business that want to contribute the $1,600. Authorities might suspect some kind of scheme, but that’s not a scheme, that’s five people, they like the guy, they donate, that’s it,” Wedick said.

Correction: A previous version of this article indicated that eight of the 11 contributors to Janet Nguyen’s campaign committee under investigation by the FPPC admitted to being reimbursed. While FPPC documents reveal that eight contributors were reimbursed, it is unclear whether they are among the 11 seeking to block subpoenas seeking financial records.

Contact Thy Vo at thyanhvo@gmail.com.

Join the conversation: In lieu of comments, we encourage readers to engage with us across a variety of mediums. Join our Facebook discussion. Message us via our website or staff page. Send us a secure tip. Share your thoughts in a community opinion piece.