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 in American Elections” (April 24, 2025), https://www.whitehouse.gov/presidential-actions/2025/04/investigation-into-unlawful-straw-donor-and-foreign-contributions-in-american-elections/
18 U.S.C. § 1956(c)(7)(D) (FECA violations as specified unlawful activity)