United States

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.

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

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

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

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/

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