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 the News, Aug. 14, 2023, https://justthenews.com/politics-policy/elections/questions-mount-about-actblues-security-after-complaints-unauthorized
ActBlue confirmed to Congress in 2023 that it “did not require a CVV in order to contribute on their website.” Congressional investigators noted this deviated from standard e-commerce fraud controls for card-not-present (CNP) transactions, where CVV is a core PCI DSS-recommended safeguard. https://cha.house.gov/_cache/files/4/5/453a1689-6471-4632-8874-2ea5018820a7/FEE0032E48BFF011537DA5927F7E9298.response-to-house-admin-committee-11-27-23.pdf
Visa Core Rules § 5.7.1; see also Mastercard Transaction Processing Rules ch. 3
“In knowing that foreign actors use fake accounts to exploit donation systems that do not have robust verification processes and systems in place, most individual campaigns and political action committees (PACs) require CVV numbers as part of making an online donation. However, in breaking with most organizations, ActBlue does not require CVV numbers as a requirement for donating, and thus lending itself as a facilitator of fraud.”