Investigation into Unlawful “Straw Donor” and Foreign Contributions in American Elections
TLDR
This executive order directs the Justice Department to investigate ActBlue for alleged “straw donor” schemes and foreign contributions, citing 22 “fraud campaigns” and 237 foreign-linked donations (0.0003% of volume). Critics note it bypasses the FEC, targets only Democratic fundraising infrastructure while ignoring similar Republican platforms like WinRed, and represents a concerning use of executive power to investigate political rivals.
This memorandum directs the Justice Department to investigate alleged unlawful “straw donor” schemes and foreign contributions through online fundraising platforms, with a specific focus on ActBlue, the Democratic Party’s primary donation processing tool. The memo cites federal campaign finance laws (52 U.S.C. 30121/30122) and claims congressional reports identified 22 “significant fraud campaigns” linked to ActBlue, including 237 foreign IP-sourced donations via prepaid cards during the 2024 election cycle. Attorney General Pam Bondi is tasked with delivering findings within 180 days.
The memo asserts “extremely troubling evidence” of platforms enabling fraud but provides no criminal convictions or verified examples of systemic violations. While ActBlue detected 22 fraud campaigns internally, these were flagged and addressed by the platform itself. The 237 foreign-linked donations represent 0.0003% of ActBlue’s 2024 volume (assuming ~80 million transactions), suggesting isolated incidents rather than widespread abuse.
The memo and accompanying White House fact sheet exclusively name ActBlue, despite Republican-aligned platforms like WinRed facing similar fraud allegations. For example, a 2022 federal court allowed states to probe WinRed over “rampant” fraudulent charge complaints. Furthermore, Congressional Republicans’ report criticized ActBlue’s “lack of legal team” and fraud protocols but offered no comparative analysis of other platforms.
The directive bypasses the Federal Election Commission (FEC), the independent agency tasked with enforcing campaign finance laws, centralizing enforcement under Trump’s DOJ-a departure from procedural norms. Also, ActBlue’s legal team called the memo “unlawful” and a “weaponization of federal power,” noting its compliance with all FEC regulations.
The action follows a pattern of Trump targeting perceived opposition infrastructure, including universities, law firms, and now Democratic fundraising tools. Democratic organizations framed the memo as an attempt to disrupt small-dollar grassroots donations while favoring billionaire donors aligned with Trump.
ActBlue, which processed $4.9 billion in 2024 alone, vowed to challenge the order in court, arguing it jeopardizes millions of donors’ participation. Legal experts criticized the move as a breach of post-Watergate DOJ independence norms. No comparable scrutiny has been applied to Republican fundraising mechanisms, raising concerns about asymmetric enforcement.
This memorandum underscores an escalation in using executive authority to investigate political rivals, with implications for campaign finance transparency and electoral fairness.
MEMORANDUM FOR THE SECRETARY OF THE TREASURY THE ATTORNEY GENERAL THE COUNSEL TO THE PRESIDENT
SUBJECT Investigation into Unlawful “Straw Donor” and Foreign Contributions in American Elections
Federal law (52 U.S.C. 30121 and 30122) strictly prohibits making political contributions in the name of another person, as well as contributions by foreign nationals.
Notwithstanding these laws designed to protect American democracy, press reports and investigations by congressional committees have generated extremely troubling evidence that online fundraising platforms have been willing participants in schemes to launder excessive and prohibited contributions to political candidates and committees.
Specifically, these reports raise concerns that malign actors are seeking to evade Federal source and amount limitations on political contributions by breaking down large contributions from one source into many smaller contributions, nominally attributed to numerous other individuals, potentially without the consent or even knowledge of the putative contributors. The reports also raise concerns that such “straw donations” are being made through “dummy” accounts, potentially using gift cards or prepaid credit cards to evade detection.
Further, there is evidence to suggest that foreign nationals are seeking to misuse online fundraising platforms to improperly influence American elections. A recent House of Representatives investigation revealed that a platform named ActBlue had in recent years detected at least 22 “significant fraud campaigns”, nearly half of which had a foreign nexus. During a 30-day window during the 2024 campaign, the platform detected 237 donations from foreign IP addresses using prepaid cards, indicating that this activity remains a pressing concern.
These activities undermine the integrity of our electoral process. Therefore, I direct the Attorney General, in consultation with the Secretary of the Treasury, to use all lawful authority, as necessary, to investigate allegations regarding the unlawful use of online fundraising platforms to make “straw” or “dummy” contributions or foreign contributions to political candidates and committees, and to take all appropriate actions to enforce the law.
I further direct the Attorney General to report back to me through the Counsel to the President within 180 days of the date of this memorandum on the results of the investigation.
This memorandum is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person.
DONALD J. TRUMP