Established Fact

Established Fact ActBlue files regular itemized contribution schedules (FEC Form 3X) with donor name, address, employer, occupation, date, and amount for all contributions ≥$200. These public records constitute the primary evidentiary base for pattern analysis and victim identification. Citations FEC.gov, Bulk Data Download — Contributions by Individuals, https://www.fec.gov/data/browse-data/?tab=bulk-data

Established Fact No declassified U.S. intelligence community assessment reviewed for this report specifically identifies ActBlue as a vehicle for foreign national contribution fraud during the 2020 cycle. This represents a significant evidentiary absence requiring ODNI/FBI inquiry. Citations Review of publicly available ODNI and FBI declassified assessments re: 2020 election foreign interference (no ActBlue-specific finding identified

Established Fact Instances appear in public FEC records in which the same physical address is associated with multiple donor names making near-simultaneous contributions to the same recipients — a pattern consistent with identity fabrication or credential harvesting at a single address. Citations “ActBlue wrote to Sift specifically about its failure to detect a fraud campaign

Established Fact Analysis of public FEC filings identified statistically anomalous frequencies of contributions in exact round-dollar amounts ($1, $5, $10, $15) attributed to single named donors over compressed time periods — a pattern inconsistent with typical individual donor behavior. Citations Analysis of FEC bulk data (Schedule A filings), FEC.gov, https://www.fec.gov/data/browse-data/?tab=bulk-data Election Research Institute, Anomalous Contribution

Established Fact Members of the House Administration and Judiciary Committees transmitted formal letters to the DOJ and FEC requesting investigation of ActBlue’s donor verification practices, citing constituent complaints and FEC data anomalies. Citations Formal letter from House Administration Chairman Bryan Steil, Judiciary Chairman Jim Jordan, and Oversight Chairman James Comer to U.S. Attorney General Pam

Established Fact Investigative reporting identified dozens of individuals whose names appear in FEC records as making large volumes of small, repeated contributions via ActBlue whom, when contacted, stated they had made no such contributions and did not recognize the transactions. Citations John Solomon & Steven Richards, ‘Hundreds of ActBlue donors say they never made contributions

Established Fact As of the compilation of this report, ActBlue has not published an independent third-party audit of its fraud detection performance for the 2020 election cycle, nor has it produced complete responsive records to all congressional inquiries. Citations Letter from Rep. Bryan Steil to ActBlue, Oct. 31, 2023 (on file, House Committee on Administration),

Established Fact Federal law does not require campaigns to itemize contributions below $200 aggregate per donor per cycle. This threshold creates a structural incentive to keep individual fraudulent transactions sub-threshold, rendering them invisible to public FEC disclosure. Citations 11 C.F.R. § 104.3(a)(4)(i) (specifying that authorized committees must report itemized individual contributions in Schedule A, Line

Established Fact ActBlue reported 15.3 million unique donors and over 165 million individual transactions in the 2020 cycle. This volume makes individual-transaction fraud detection and post-hoc audit exceptionally difficult without automated forensic tooling. Citations ActBlue, 2020 Year-End Report (Jan. 2021), https://actblue.com/updates/posts/2020-year-end-report

Established Fact During the 2020 federal election cycle ActBlue processed approximately $3.8 billion in total contributions — more than double its 2018 cycle total — creating an audit environment of exceptional complexity for regulators and recipient committees. Citations ActBlue, 2020 Year-End Report (Jan. 2021), https://actblue.com/updates/posts/2020-year-end-report OpenSecrets.org, ActBlue 2020 Cycle Summary, https://www.opensecrets.org/pacs/lookup2.php?strID=C00401224