Campaign Finance

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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Merchant Processing Agreements — Critical Gap; Not Publicly Available (US)

Disputed Fact ActBlue’s agreements with payment processors (reportedly including Stripe and WePay) governing CVV/AVS requirements, chargeback policies, and fraud reporting obligations are not publicly available and have not been produced to investigators. These documents are essential to establishing platform-level fraud control decisions.  Citations Stripe Developer Documentation, https://stripe.com/docs/radar/rules reported processor relationship: industry sources actual ActBlue-specific agreements

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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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FEC Public Contribution Database — Primary Evidentiary Source (US)

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

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No Declassified IC Assessment Specifically Identifying ActBlue as Foreign Exploitation Vehicle (US)

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

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Prepaid Debit Cards — No Verified Exclusion from ActBlue Payment Methods (US)

Disputed Fact Prepaid debit cards, obtainable in many jurisdictions without identity verification, were not confirmed as excluded from ActBlue’s accepted payment methods during the 2020 cycle. Their acceptance would further reduce barriers to anonymous or foreign-sourced contributions. Citations ActBlue, Payment Methods Accepted (archived web page, 2020–2021) Stripe Developer Documentation, https://stripe.com/docs/radar/rules  (not specific to ActBlue implementation)

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CVV/AVS Gap as Potential Foreign Contribution Vector (US)

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,

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ActBlue Enables Illegal Foreign National Contributions

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

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ActBlue Donation Profiles Are Straw Donations (US)

Disputed Fact ActBlue Smurf donation profiles appear to violate federal law. 52 U.S.C. § 30122 (US) prohibits making a contribution in the name of another person, permitting one’s name to be used for such a contribution, or knowingly accepting a contribution made in another’s name. Criminal penalties attach at >$2,000 (misdemeanor) and >$25,000/year (felony). Citations

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ActBlue Leverages FEC Reporting Loophole By Using Straw Donors Used (US)

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

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