Established Fact

Extortive Clawback Clauses Dictating Election Operations as Condition of $10 Million Private Grant (PA)

Established Fact “Philadelphia accepted a $10,016,074 CTCL grant that contractually required the city to ‘work to secure 800 or more in-person polling places on Election Day’ and to pay election judges and poll workers using private grant funds — $851,500 in hazard pay for 8,515 poll workers was budgeted directly within the grant agreement. The

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Bureau of Elections Promoted Private CTCL Grants via Official State Communications Infrastructure (MI)

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

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Misappropriation of COVID Safety Grant Funds for Partisan Operational Enhancement (GA)

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,

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Third-Party NGO Voter Registration Operations Connected to National Private Funding Networks (AZ)

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

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DOJ Prosecution of Foreign-Connected Campaign Finance Violations (US)

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.

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Employer-Reimbursed Contribution Scheme Conviction (US)

Established Fact The Ninth Circuit affirmed conviction under § 30122 for orchestrating a scheme where an employer reimbursed employees for political contributions made in the employees’ names — directly analogous to third-party actors making contributions in victims’ names without authorization. Citations United States v. Whittemore, No. 13-10515 (9th Cir. Jan. 26, 2015) , “Whittemore distributed

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Knowing Acceptance / Willful Blindness Standard — United States v. Danielczyk (VA)

Established Fact The Eastern District of Virginia affirmed that the straw donor prohibition under § 30122 requires knowing acceptance by the receiving committee for criminal liability on the committee’s part, but that ‘knowing’ may be inferred from willful blindness — the Global-Tech standard. Citations United States v. Danielczyk, 788 F. Supp. 2d 472, 479–481 (E.D.

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Straw Donor Liability of Recipient Committees — FEC v. Weinsten (US)

Established Fact The Southern District of New York held that contributions made through straw donors violate § 30122 regardless of whether the ultimate recipient campaign was aware of the straw arrangement, establishing strict-liability principles for receiving committees. Citations FEC v. Weinsten, 462 F. Supp. 243, 250 (S.D.N.Y. 1978) (denying motion to dismiss FEC complaint alleging

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Chargeback and Dispute Records — Recoverable Evidence of Unauthorized Transactions (US)

Established Fact Where named donors disputed unauthorized charges through their financial institutions, chargeback records held by card networks (Visa, Mastercard) and issuing banks constitute recoverable evidence of confirmed unauthorized use — directly corroborating victim complaints. Citations Visa Operating Regulations § 11.2 (chargeback rights) Mastercard Rules § 13.1 records held by issuing banks and acquirers subpoena

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No Completed FEC Audit of ActBlue for 2020 Cycle Published (US)

Established Fact The FEC Audit Division’s public records show no completed audit of ActBlue for the 2020 election cycle as of March 2026. The FEC has statutory authority to compel such an audit under 52 U.S.C. § 30111(b) but has not done so for this period. Citations FEC, Audit Division — Completed Audits, https://www.fec.gov/legal-resources/enforcement/audit-case-documents/

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