SALEM — Former Oregon “first lady” Cylvia Hayes faces up to $110,000 in fines after the Oregon Ethics Commission decision on Friday that the fiancee of ex-Gov. John Kitzhaber violated state law 22 times by lobbying while holding an official state position.

Each violation carries a maximum penalty of $5,000. Hayes could also be liable to pay up to twice the amount of any profits related to her activities. The commission said Hayes received more than $200,000 to advocate for alternative energy and economic development.

The findings are preliminary and will be finalized during the commission’s next meeting on Feb 16.

Kitzhaber resigned as governor in February 2015, just three months after he was re-elected governor. At the time, he was under investigation for his knowledge of, or involvement in, alleged lobbying and conflicts-of-interest involving Hayes.

The U.S. attorney for Oregon and the Oregon attorney general closed their investigations last year without filing any charges against Kitzhaber or Hayes.

The ethics commission announced in July 2017 that it would resume the investigation it put on hold during the criminal investigations.

Neither Hayes nor her attorneys attended the ethics hearing. Hayes has steadfastly maintained she was not a public official and therefore the commission has no jurisdiction over her actions.

Commissioners said it was unfortunate Hayes chose not to have representation at the hearing, but said it would not cause them to delay action.

Hayes, who owns a home in Bend, did not respond to several media attempts to contact her as of late Friday.

The commission earlier rejected a settlement its staff negotiated with Kitzhaber that would have had the former state chief executive pay only $1,000 in fines. The commission is expected to take up Kitzhaber’s case at its next meeting.

In comments about the Hayes investigation, commissioners said Kitzhaber had enabled the violations by granting Hayes unique status as an official but unpaid adviser.

“Much of what happened here, since they share a household, is applicable to the governor,” said commission chair Alison R. Kean.

Kitzhaber referred to Hayes as the “first lady” of Oregon, and allocated office space and official state resources for her use.

The commission’s case against Hayes was laid out in a report issued Wednesday. It detailed emails investigators say showed Hayes knew she was acting in questionable ways.

The violations included using her public position to influence government officials in both the executive and legislative branches; advocate policy decisions that advanced the interests of her company, 3EStrategies; use public-paid travel to advance her business interests; accept gifts beyond state limits; and hold official meetings where she advocated for policies that favored her clients.

In one instance, investigators said Hayes leveraged her position to receive compensation from an airline beyond what would normally be accorded the average customer.

The report said that after Hayes complained to United Airlines about their service, the airline granted Hayes and Kitzhaber Premier Platinum status in its MileagePlus frequent-flyer program, a perk usually only available to the airline’s highest-spending and frequent-traveling customers.

According to United’s website, Premier Platinum status usually requires a customer to fly 75,000 qualifying miles in a year. It provides holders with unlimited complimentary seating upgrades (sometimes including up to eight total passengers), access to private airport lounges, up to three free checked bags, waivers on itinerary change charges and even access to officially “sold out” flights.

— The Associated Press contributed to this story Reporter: 541-525-5280, .