Reasonable Inference

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,

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

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

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

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

Reasonable Inference Security researchers contend ActBlue’s relaxed CVV and Address Verification System (AVS) configuration would have reduced technical barriers to foreign-based actors using prepaid cards or VPNs to submit contributions without triggering identity mismatch rejections. Citations Logan Washburn, ‘Amid Chaos At ActBlue, House Republicans Seek Answers About ‘Potentially Fraudulent And Illicit Financial Activity,’ The Federalist,

Reasonable Inference ActBlue security negligence enables illegal foreign national contributions. 52 U.S.C. § 30121 law prohibits foreign nationals from making any direct or indirect contribution in connection with any U.S. election. Receiving committees are also prohibited from soliciting, accepting, or receiving such contributions. Felony threshold: >$25,000/year. Citations John Solomon, ‘Questions mount about ActBlue’s security,’ Just

Reasonable Inference Where a coordinating actor directs multiple nominal donors to make contributions earmarked for a common recipient, those contributions are attributed to the original source — not the nominal donor — and aggregate against that source’s individual contribution limits. The conduit or intermediary is required to report the original source and intended recipient to