Established Fact The Michigan Bureau of Elections used its official government email infrastructure — the Bureau’s statewide News Update system, which automatically delivered communications to every municipal clerk and deputy clerk in the state — to relay CTCL grant application information directly to local election officials in September 2020. The Bureau’s News Update of September
Established Fact Despite CTCL grants being publicly marketed as “COVID-19 Response Grants,” Fulton, Cobb, and DeKalb counties — the three largest recipients in Georgia — spent only approximately 1.3 percent of their CTCL grants on personal protective equipment. The remaining funds were applied to operational expenditures including administrative salaries, laptop computers, vehicle rentals, attorney fees,
Misappropriation of COVID Safety Grant Funds for Partisan Operational Enhancement (GA) Read More »
Established Fact The Yuma County Sheriff’s Office and Yuma County Recorder’s Office jointly confirmed sixteen open criminal investigations as of March 2022 into a pattern of election-related fraud spanning the 2020 General Election and continuing into the 2022 primary cycle. Categories of fraud documented in the Sheriff’s Office press release included impersonation fraud, false voter
Reasonable Inference The financial relationship between SVCF and Michigan Secretary of State Jocelyn Benson warrants scrutiny as a structural conflict of interest facilitated through multiple layers of nonprofit intermediaries. SVCF, as the donor-advised fund custodian for the Chan Zuckerberg Initiative, disbursed $69.5 million to the Center for Election Innovation and Research (CEIR). CEIR in turn
Reasonable Inference Suspicious Activity Reports (SARs) filed by financial institutions with FinCEN in connection with ActBlue transactions may corroborate fraud patterns already identified through FEC data analysis. In September 2024, House Oversight Chairman James Comer and Republican colleagues formally requested from Treasury Secretary Yellen all SARs related to ActBlue, citing concerns about potential money laundering,
FinCEN SAR Records — Potential Evidentiary Gap Requiring Database Query (US) Read More »
Reasonable Inference If two or more persons coordinated to submit fraudulent contributions through ActBlue — whether through straw donor schemes, identity misappropriation, or foreign contribution routing — each is subject to conspiracy liability under 18 U.S.C. § 371, independent of whether the underlying offense was completed or whether each participant personally committed every element of
Conspiracy Exposure — 18 U.S.C. § 371 (Up to 5 Years) (US) Read More »
Reasonable Inference Where perpetrators used real individuals’ personal identifying information (name, address, card number) to make contributions without authorization, each instance constitutes potential identity fraud under 18 U.S.C. § 1028, carrying up to 15 years imprisonment. Citations 18 U.S.C. § 1028(a)(7), (b)(1)(D), “Whoever, in a circumstance described in subsection (c) of this section— (7) knowingly
Identity Fraud Exposure — 18 U.S.C. § 1028 (Up to 15 Years) (US) Read More »
Reasonable Inference Where criminally derived funds (proceeds of straw donor violations or identity fraud) are transmitted through ActBlue to candidate accounts, laundering charges under 18 U.S.C. § 1956 are available. FECA violations are listed as specified unlawful activity under § 1956(c)(7)(D), enabling this theory. Citations Presidential Memorandum, “Investigation into Unlawful ‘Straw Donor’ and Foreign Contributions
Money Laundering Exposure — 18 U.S.C. §§ 1956–1957 (US) Read More »
Reasonable Inference Where fraudulent contributions are submitted via ActBlue’s internet platform, each electronic transmission constitutes a potential wire fraud predicate under 18 U.S.C. § 1343, which broadly covers any scheme to obtain money or property by false pretenses transmitted “by means of wire . . . communication in interstate or foreign commerce.” Wire fraud carries
Wire Fraud Exposure — 18 U.S.C. § 1343 (Up to 20 Years Per Count) (US) Read More »
Established Fact Foreign-connected campaign finance violations have resulted in federal criminal charges. In United States v. Michel, No. 1:19-cr-00148 (D.D.C.), prosecutors charged that fugitive Malaysian financier Jho Low’s funds were funneled through straw donors into federal campaign committees supporting a presidential candidate, in violation of FECA’s prohibition on foreign national contributions and the straw-donor ban.
DOJ Prosecution of Foreign-Connected Campaign Finance Violations (US) Read More »
