Santos reported 40 of them.

In fact, his campaign accounted for roughly half of all expenses by all campaigns that cost exactly $199.99 — a statistical improbability.

The rarity of campaign expenses falling so close to the legal limit for retaining receipts has raised concerns that the Santos campaign’s disbursements were “deliberately falsified,” a complaint from the Campaign Legal Center alleges. Major questions about Santos’ campaign financing remain unanswered, including the source of $700,000 that the New York congressman ostensibly loaned to his campaign despite questions about his personal finances.

“This was a multi-hundred-thousand dollar operation,” said Adav Noti, a former FEC attorney and senior vice president at the nonprofit Campaign Legal Center, which filed a complaint against Santos. “We don’t know where the money came from, we don’t know where the money went to.”

Santos’ lawyer, Joe Murray, declined to comment, citing ongoing investigations. The congressman has previously admitted to exaggerating components of his biography but denied breaking any laws. Both local and federal prosecutors are investigating whether he may have broken the law, but has not been charged with a crime and has bucked calls to resign from fellow GOP members of the state’s congressional delegation.

Most of the Santos campaign’s $199.99 transactions — including the eight Italian restaurant charges — date back to 2021, according to FEC reports. But like the fabricated aspects of the now-congressman’s biography, they went largely unnoticed until after the election.

Under FEC regulations, campaigns are required to report all disbursements and maintain receipts or invoices for those valued at $200 or more. The sheer number of expenses reported as being just under the threshold for retaining receipts was among the subjects of the CLC’s complaint against the Santos campaign. The complaint also cited the $700,000 that Santos reported as a personal loan to his campaign despite questions about his finances.

Of the more than 4,300 House and Senate campaigns that filed any FEC reports during the 2022 election cycle, fewer than 9 percent reported one or more expenditures costing between $199 and $199.99.

Not all campaign expenditures in that narrow range raise questions. A relatively common expense this election cycle: subscriptions to the web-conferencing platform Zoom, which has a business plan priced at $199.90 per month.

But only 25 campaign committees reported any single expense costing exactly $199.99, POLITICO’s analysis found. No campaign other than Santos’ spent that specific amount more than four times. And Santos’ campaign spent that exact figure 37 times, according to his campaign finance reports, totalling just shy of $7,400. In addition to the Italian restaurant and Miami hotel, he reported spending exactly $199.99 on 10 distinct Uber rides, four Delta Airlines flights and two Amtrak trains, among other expenses.

These reported expenses are still a relatively small share of the more than $2.6 million that Santos’s campaign spent last cycle. But CLC’s complaint alleges that they raise questions about the accuracy of his reported disbursements.

The FEC, which is tasked with enforcing campaign finance laws, sent more than 20 letters to Santos’ campaign asking about mathematical errors and other inconsistencies throughout the 2022 election cycle. While such letters are fairly commonplace, that number is atypical, said Noti of the Campaign Legal Center.

The agency is not equipped to flag transactions that are suspicious based on the amounts and vendors.

Santos’ campaign has repeatedly amended its filings both before and after the election in response to FEC letters. That included filing several updated forms on Tuesday to denote previous large contributions that should have been reported in November, as well as amendments to several quarterly reports. The amendments did not touch on the $199.99 disbursements.