Virginia Republican gubernatorial nominee Winsome Earle- Sears built her political brand on transparency and accountability. But a closer look at her public filings reveals a pattern of omissions and inconsistencies in her financial disclosures — including a $12,000 “gift” far above the state’s legal limit and multiple undisclosed trips funded by outside organizations. 

The Mercury reviewed several Statements of Economic Interests (SOEI), campaign finance reports and related documents obtained through the Virginia Conflict of Interest and Ethics Advisory Council. 

The records show that Earle-Sears, who has served as lieutenant governor since 2022, repeatedly failed to disclose gifts and travel benefits as required under state law and, in several instances, amended her filings only after watchdogs or reporters raised questions. 

“These aren’t minor oversights,” said Alex Keena, an associate professor of political science at Virginia Commonwealth University who studies political ethics and campaign finance. “To me, this raises serious concerns about her ability to govern lawfully and ethically and highlights obvious conflicts of interest.” 

The Mercury sent Earle-Sears’ campaign a detailed list of questions regarding her financial disclosures, including specific inquiries about her reporting of gifts, travel and amendments. The campaign did not respond to several emails before publication. 

$12,000 ‘gift’ defied state’s limits 

One of the most striking irregularities in Earle-Sears’ filings dates to June 2021, when she reported receiving a $12,000 “gift” from Black Americans to Reelect the President — a pro-Trump organization for which she served as national chair. The disclosure appears in her 2021 SOEI filing, but she did not check any box to claim an exemption from Virginia’s $100 gift cap. 

According to state law, public officials may accept gifts exceeding $100 only if they fall into narrow categories, such as attendance at a “widely attended event,” a gift from a personal friend, or a token of appreciation from a foreign dignitary. The law explicitly defines these exceptions under the code. 

The $12,000 payment to Earle-Sears does not appear to meet any of those criteria, and no exemption was indicated on her form filed with the Virginia Conflict of Interest and Ethics Advisory Council. 

At the same time, federal election filings show that the same group paid Earle-Sears $7,966.12 for “event organizing,” “copy editing” and travel between April and December 2019. The payments, disclosed to the Federal Election Commission, included airfare, lodging, meals and consulting services. 

The dual reporting — as both a “gift” and as payments for work — blurs the line between compensation and gratuity. If the $12,000 was payment for her services, it should have been declared as income. If it was indeed a gift, it far exceeded the state’s allowable threshold. 

The 2021 disclosure, though publicly available, had not been widely reported until now. 

Undisclosed ALEC travel 

Between 2021 and 2023, Earle-Sears attended and spoke at multiple events hosted by the American Legislative Exchange Council (ALEC), a conservative nonprofit organization known for promoting model legislation on behalf of corporate members and Republican state lawmakers. 

In December 2021, one month after being elected lieutenant governor, she was a keynote speaker at ALEC’s States and Nation Policy Summit in Washington, D.C., alongside then-South Dakota Gov. Kristi Noem. 

In November 2022, she delivered another keynote at ALEC’s annual summit, which also featured former Vice President Mike Pence, according to an ALEC news release. 

And in October 2023, she appeared as a featured guest at ALEC’s 50th Anniversary Gala in Washington, where she was billed alongside Republican Sen. Pete Ricketts of Nebraska and conservative commentator Hugh Hewitt. 

Despite these high-profile appearances, none of the events — nor any related travel or lodging — appear on her state financial disclosures. 

Her 2022, 2023 and 2024 SOEIs each include a section requiring the filer to list “any lodging, transportation, money, or other thing of value” exceeding $100 received in their official capacity. Each year, Earle-Sears either checked “No” or reported nothing in that section. 

That omission matters, because ALEC routinely covers travel and lodging expenses for elected officials. The group’s funding structure has long drawn criticism for creating an opaque pipeline between corporate donors and state legislators. 

“Earle-Sears’ participation in multiple ALEC conferences without reporting any travel support is significant,” Keena said. “These are not inexpensive junkets. It reinforces the perception that there are special interests underwriting her access and agenda — and the public doesn’t see who’s paying.” 

The Mercury found no record of Earle- Sears seeking reimbursement for any of the ALEC-related travel from her office, nor any campaign expenditure filings corresponding to those events. 

Pattern of late or missing disclosures

The $12,000 gift and the unreported ALEC travel fit a larger pattern of incomplete or revised disclosures during Earle-Sears’ time as lieutenant governor. 

In February 2025, Earle-Sears filed her annual Statement of Economic Interests and certified that she had received no gifts or travel exceeding $100 in the previous year. 

But three months later, following a FOIA request by Democratic activist Josh Stanfield that revealed her participation in a 2024 trip to Israel funded by the Combat Antisemitism Movement, Earle-Sears filed an amended report. 

In the revised May 22 filing, she acknowledged seven previously undisclosed trips paid for by outside organizations, totaling $15,784.66, including the $6,000 Israel trip. 

Two other Virginia officials on the same delegation — Sen. Bryce Reeves, R-Spotsylvania, and Del. A.C. Cordoza, R-Hampton — each valued the trip at $10,000, Virginia Scope reported in late July. 

Earle-Sears’ office did not explain the discrepancy or why the trips had not been reported in her initial February filing. 

Private flights and unanswered questions 

Earle-Sears’ disclosure history has drawn additional scrutiny since the Richmond Times-Dispatch reported this summer that her April 2023 travel between Winchester and Abingdon matched the flight path of a private plane owned by Gary Duncan, a car dealer and campaign donor whose business is regulated by the state. 

Flight data reviewed by the newspaper showed Duncan’s Pilatus PC-12 aircraft made stops in Winchester and Abingdon that same day, aligning with Earle-Sears’ appearances in both cities. Her campaign finance reports and ethics filings contain no record of that flight or any payment for private air travel. 

Asked about the flight more than two years later, Earle-Sears’ communications director told the newspaper, “We’re still trying to figure it out.” 

Under Virginia law, a public official who knowingly files a false or incomplete Statement of Economic Interests is guilty of a Class 5 felony. The statute requires filers to sign an affirmation certifying their report is “full, true, and correct to the best of [their] knowledge.” 

So far, neither Earle-Sears nor her campaign has addressed whether she reimbursed the donor, received the flight as a gift, or plans to amend her filings. 

An ethics system built on self-policing

Virginia’s conflict-of-interest laws rely heavily on self-reporting and public disclosure, with limited enforcement power. The state’s Conflict of Interest and Ethics Advisory Council can provide guidance and review forms but lacks the authority to investigate or penalize violations. 

Enforcement typically falls to local prosecutors or the attorney general, who seldom pursue such cases unless prompted by outside complaints. 

“Sadly, hers is not a unique case,” Keena said. “President Donald Trump has exposed fundamental weaknesses in the enforcement of campaign finance law at the federal level, as the FEC has repeatedly chosen not to enforce obvious violations of federal law. At the state level, given Virginia’s lax treatment of campaign money, there seem to be little to no consequences for skirting the rules for a powerful elected official like Earle-Sears.” 

Indeed, past scandals involving Virginia officials — from former Gov. Bob McDonnell’s conviction on corruption charges that were later overturned to lesser-known disclosure lapses by members of both parties — have led to only incremental reforms. While the General Assembly tightened some reporting thresholds after 2014 and passed legislation this year that bars candidates from using campaign contributions for personal benefit, it stopped short of imposing strict oversight or independent audits. 

A broader pattern of opacity

Earle-Sears’ ethics issues extend beyond the headline-grabbing flights and trips. 

Between 2011 and 2021, she owned Shenandoah Appliance, Plumbing and Electric, a Winchester-based business she purchased from its founder, Dave Brown. 

Earle-Sears disclosed the business on her 2012, 2013 and 2014 financial statements but failed to list it as a principal business activity in 2015, even though she continued to own it. She later told reporters during her 2021 lieutenant governor campaign that she had shut down the company because she “couldn’t hire workers,” according to the Richmond Times-Dispatch. 

That inconsistency — coupled with her unexplained $12,000 payment, undisclosed ALEC trips and amended filings — suggests a recurring pattern of incomplete or misleading financial transparency. 

So far, no state agency has announced any review of Earle-Sears’ filings. If complaints are filed, they could trigger an investigation by the attorney general’s office or the State Board of Elections, though both have historically deferred to self-correction. 

This story originally appeared on VirginiaMercury.com.