Reasonable Inference
Suspicious Activity Reports (SARs) filed by financial institutions with FinCEN in connection with ActBlue transactions may corroborate fraud patterns already identified through FEC data analysis. In September 2024, House Oversight Chairman James Comer and Republican colleagues formally requested from Treasury Secretary Yellen all SARs related to ActBlue, citing concerns about potential money laundering, identity theft, fraudulent credit card transactions, and evasion of campaign finance law. Treasury subsequently confirmed to Congress that it was reviewing “hundreds of potentially responsive records” — a review described as “one of the most extensive records reviews it has undertaken this Congress” — but did not produce the records before the end of the Biden administration. In March 2025, Chairmen Steil, Comer, and Rep. Langworthy renewed the request to Treasury Secretary Bessent, seeking the SARs “previously withheld by the Biden Administration.” The contents of any SARs produced remain subject to strict statutory confidentiality and have not been publicly disclosed.
Citations
U.S.C. § 5318(g)(1) (authorizing the Secretary of the Treasury to require financial institutions to report suspicious transactions relevant to possible violations of law or regulation), available at https://www.law.cornell.edu/uscode/text/31/5318.
House Committee on Oversight and Accountability, Press Release, “Comer, Langworthy, Oversight Republicans Launch Investigation into Potential Fraud Linked to ActBlue Campaign Contributions, Request Treasury’s SARs on Suspicious Financial Activity” (Sept. 20, 2024), available at https://oversight.house.gov/release/comer-langworthy-oversight-republicans-launch-investigation-into-potential-fraud-linked-to-actblue-campaign-contributions-request-treasurys-sars-on-suspicious-financial-activity/.
Josh Christenson, “Treasury finds hundreds of transactions linked to fundraising platform ActBlue flagged by banks: GOP memo,” N.Y. Post (Oct. 29, 2024), available at https://nypost.com/2024/10/29/us-news/hundreds-of-transactions-linked-to-dem-fundraising-platform-actblue-flagged-by-banks-found-by-treasury-gop-memo/ (reporting on Oct. 25, 2024 memo from Chairman Comer to committee members confirming Treasury review of hundreds of potentially responsive records involving suspicious activity reported by financial institutions, including potential money laundering, fraudulent card transactions, wire transfer fraud, and identity theft).
“Section 1028(a)(7) criminalizes the knowing transfer, possession, or use, without lawful authority, of a means of identification of another person with the intent to commit, or to aid or abet, any unlawful activity that constitutes a violation of Federal law…” (DOJ explicitly lists this as the primary “identity theft” provision used when PII is misused to facilitate another federal offense). https://www.justice.gov/archives/jm/criminal-resource-manual-1502-prosecuting-violations-18-usc-1028