necessarily even a crime. and it has been proven by many times that this is a civil action. >> giuliani said that today, but it is not necessarily a civil action. i mean, if it is found -- we're talking about hundreds of thousands of dollars two weeks ahead of an election. he's directing what michael cohen said were specifically dirty deeds. >> we've also seen in the past that campaign finance violations have been handed civilly. president obama took millions of dollars in misreported donations. he was fined $375,000. bernie sanders had illegal foreign assistance during his campaign in 2016. he was fined $14,500. >> i would just point out none of that was deliberate. it was discovered. >> but what we also know, and this was brought up in a very good piece this week on the hill is that to knowingly and willfully violate the law, you actually have to know that it's against the law. you have the fec commissioners and many campaign finance