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The scrutiny of how Representative Lori Trahan financed her razor-thin victory in 2018 has not only hovered for months, it’s apparently giving oxygen to a potential primary challenge.

Dan Koh, the former Boston City Hall aide who fell to Trahan by 145 votes in last year’s Third Congressional District primary, is weighing a rematch, largely because of the questions about Trahan’s campaign spending, according to people close to the Andover Democrat.

Koh confirmed to the Globe he’s mulling a bid to represent the district that skirts the New Hampshire border, from Winchendon to Haverhill and down to Marlborough.

Trahan, of Westford, has faced a series of complaints targeting $371,000 she loaned her campaign amid the chaotic 10-Democrat primary, including hundreds of thousands of dollars in the weeks before the September vote.

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Trahan did not disclose a key source of the money — a joint bank account with her husband — until after she won election in November, prompting calls from watchdog groups for federal officials to investigate. Trahan aides have said the freshman lawmaker did nothing wrong.

Any potential response from regulators, however, has been slow coming, including from the Federal Election Commission, which currently doesn’t have enough commissioners to mete out decisions on everything from regulations to finance law enforcement.

But for Koh, it’s left questions of whether he lost fairly, and in his mind, a potential avenue to build a challenge. “In the Trump era, it’s got to matter you do things ethically,” said one person familiar with Koh’s thinking.

Koh, who won election to the Andover Board of Selectmen in March, has remained in public view since 2018, criticizing Trahan on social media over the summer for not calling for President Trump’s impeachment. He then followed with an op-ed in The Lowell Sun, again calling on her to back it. Trahan ultimately did — after Special Counsel Robert Mueller’s testified before Congress — and dismissed the idea that Koh was the reason.

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Days later, Trahan sent out a fundraising pitch, suggesting that “one former primary opponent” (read: Koh) had made it “pretty clear last week that he is running against me.” Speculation around a potential rematch has only continued to build.

Koh, the former top aide to Mayor Martin J. Walsh, confirmed he’s considering a campaign. “I’m thinking about it,” he said, “but I haven’t decided yet.”

In a statement, Trahan’s campaign touted her place among the record number of women elected to Congress last year, and accused Koh of “playing politics for months because he thinks he’s entitled to serve in Congress. We are happy to take our case to the voters.”

Should Koh run, it would open a landscape far different from 2018, when he, Trahan, and a gaggle of other candidates jostled among the largest congressional primary field in 20 years. Trahan ultimately won the primary with less than 22 percent of the vote and five candidates had cornered at least 15 percent. (Trahan easily topped Rick Green, a Republican, and independent candidate Michael P. Mullen in the November general election.)

To be sure, any potential challenge of Trahan in 2020 would face immediate and significant hurdles, namely that she’d enjoy the benefit of incumbency. Koh would likely have to convince voters that his repeat bid wasn’t being fueled by sour grapes from his narrow loss. And should it remain an issue, he’d have to persaude the electorate that the questions surrounding Trahan’s campaign spending are serious enough for them to consider a change.

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Matt Stout can be reached at matt.stout@globe.com. Follow him on Twitter @mattpstout.