United States

Unauthorized ActBlue Donation Complaints (NC)

Campaign Finance, Disputed Fact, Financial Influence, North Carolina, United States /

Disputed Fact Reports indicate the North Carolina State Board of Elections received complaints from residents whose identities appear to have been used in unauthorized ActBlue transactions, and that the matter was referred for further review. Official confirmation of formal referral is limited. Citations Patrick Gannon, ‘North Carolina elections board fields complaints about ActBlue donations,’ NC

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Suspicious Elderly Donations (US)

Campaign Finance, Disputed Fact, Financial Influence, United States /

Disputed Fact Reporting identified elderly individuals — some reportedly in their 80s and 90s, including those hospitalized or deceased — whose names appeared in FEC records as making hundreds of small rapid-fire contributions via ActBlue without apparent authorization. Citations Caden Pearson, “ActBlue Donor Fraud Allegations Mount,” The Epoch Times, Oct. 4, 2023 (not independently verified by

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Donor Complaints — Just the News / Solomon Investigation (US)

Campaign Finance, Established Fact, Financial Influence, United States /

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

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No Independent Third-Party Fraud Audit Published for 2020 Cycle (US)

Campaign Finance, Established Fact, Financial Influence, United States /

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),

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ActBlue Disputes Adequacy-of-Fraud-Controls Characterizations (US)

Campaign Finance, Disputed Fact, Financial Influence, United States /

Disputed Fact ActBlue has publicly stated it employs machine-learning fraud detection, velocity checks, and proprietary controls. It disputes characterizations of its fraud controls as inadequate. No independent third-party audit of 2020-cycle fraud performance has been publicly released. Citations ActBlue, Statement on Fraud Prevention Practices (Sept. 2023), https://support.actblue.com/campaigns/faq/fraud-prevention/

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ActBlue Did Not Consistently Require CVV for Card Donations (US)

Campaign Finance, Disputed Fact, Financial Influence, United States /

Disputed Fact Unlike WinRed and most major e-commerce platforms, ActBlue reportedly did not consistently require Card Verification Value (CVV) entry for credit/debit donations during the 2020 cycle, removing a standard fraud-prevention control for card-not-present transactions.  Citations John Solomon, ‘Questions mount about ActBlue’s security,’ Just the News, Aug. 14, 2023, https://justthenews.com/politics-policy/elections/questions-mount-about-actblues-security-after-complaints-unauthorized ActBlue confirmed to Congress in

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Sub-$200 Non-Itemization Threshold Creates Structural Audit Gap (US)

Campaign Finance, Established Fact, Financial Influence, United States /

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

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Scale — 15.3 Million Unique Donors; 165 Million Transactions (US)

Campaign Finance, Established Fact, Financial Influence, United States /

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

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2020 Cycle Transaction Volume — ~$3.8 Billion Processed (US)

Campaign Finance, Established Fact, Financial Influence, United States /

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

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ActBlue PAC Registration & Conduit Structure (US)

Campaign Finance, Established Fact, Financial Influence, United States /

Established Fact ActBlue is registered with the FEC as a qualified non-connected committee (C00401224) and operates as a conduit fundraising platform, collecting and transmitting contributions to Democratic candidates while retaining a 3.95% processing fee per transaction. Citations FEC Committee Profile, ActBlue (C00401224), FEC.gov, https://www.fec.gov/data/committee/C00401224/ Presidential Memorandum, Investigation into Unlawful “Straw Donor” and Foreign Contributions in

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