The referendum campaign's led by Lisa Scott, sister of Shawn Scott, who organized the referendum that led to Hollywood Slots in Bangor.
But the ethics commission staff says the money didn't come from them; instead it came from loans from Tokyo and Las Vegas-based entities.
Shawn Scott pocketed tens of millions of dollars when he sold out rights to a Bangor casino to Penn National Gaming after facing hurdles to obtaining a state license. He was accused of failing to cooperate with a state investigation.