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Trump attacks ActBlue when WinRed is the culprit [1]

['This Content Is Not Subject To Review Daily Kos Staff Prior To Publication.']

Date: 2025-04-25

There were rumors that Trump was putting together an executive order going after ActBlue. Well, he did do it as a memorandum to Attorney General Pam Bondi.

Considering the amount of donations Republicans collect from unknown and dubious sources, and don't care to tell anybody about, this is an obvious hit job on both the Democratic Party and democracy. ActBlue is like a clearing house for campaign donations and you can specify exactly who you want yours to go to.

Trump's attack is a memorandum called Investigation into Unlawful "Straw Donor" and Foreign Contributions in American Elections.

For the Fact Sheet, you can put "President Donald J. Trump Investigates..." at the front of the memorandum title. Like Trump is going to do any legwork himself. Right.

Straw donations can come in different ways. A large donation can be split up into smaller chunks that can come through checks, credit and gift cards. A shell company can be set up in the United States to make it look like it's coming from an American source. It can go directly to the campaign or political action committees. The Republicans are notorious users of PACs, who don't have to disclose their donors. Dark money is what Obama predicted when the Supreme Court decided in 2010 with Citizens United, and that's what we have today.

Trump going after ActBlue is patently ridiculous because they do source verification so no foreign money is accepted. I can't say that about the Republican version of ActBlue, called WinRed.

Here's a case from 2017, reported in 2022, where Trump got money from straw donors to be seen with Trump and an exclusive dinner. These were Chinese Americans funneling foreign money into Trump's campaign. Exactly the sort of thing he's accusing ActBlue of allowing.

Memo: "...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."

I'm going to do a whataboutism here with what happened to the $250 million Trump raised after the 2020 election to contest the election, and the political action committee didn't exist? What about the $270+ million Trump raked in for his bribe, excuse me, inauguration? Now that you're wondering where Trump has half a billion dollars stashed, let's tear apart Trump's flawed reasoning.

But first, what about WinRed, the Republican version of ActBlue. It's does exactly the same thing, but I can't account for their adherence to reporting laws.

WinRed's operations are shrouded in secrecy. This Campaign Legal Center article from 2022 shows that like ActBlue, it takes a transaction fee of 3.94%. Since 2019 to 2022, they processed $2.8 billion in donations, and $212 million in refunds. They keep the processing fee on refunds anyway. Based on that, they must have earned $114 million. But during that period, WinRed reported just $2,700 in operating expenses, and just $243,000 in "debt" to it's affiliate, WinRed Technical Services, for unpaid legal, consulting and insurance fees. It has never made a payment to WTS to cover that amount.

During the same period, ActBlue processed $5.5 billion and had $85 million in operating expenses.

The Campaign Legal Center filed a complaint against WinRed In June of 2022 to the Federal Election Commission. The complaint can be read as a 19 page PDF. In it, the CLC lays claim to the figures above, noting that the $212 million in refunds is an extremely large amount. Why? Because WinRed, as is shown later with specific cases, charges people without their knowledge and automatically fills in X's in checkboxes in fill-in forms for monthly or repetitive donations. Once they've got your credit card information, they keep using it. Not everyone charged without intent asks for a refund.

From the CLC complaint to the FEC.

Another shady part of the WinRed operation is their "Zero-Touch Merchandise Solution."

"The Zero-Touch program consists of 26 different direct-to-garment items in various sizes and colors. These include best sellers like hats, shirts, membership cards and can coolers. The campaign designs and markets the merch, while WinRed and our verified partners handle order fulfillment, delivery, and customer delivery through our dedicated Donor Support Center."

The accounting for this operation is minimal with "no disbursements or in-kind contributions" listed in WinRed's 2021 report. It's not even reporting as a business at all.

There is also a training program for fundraisers of Republican Party candidates and committees with no disclosure at all in WinRed's FEC reports.​​​​

"WinRed's FEC reports thus paint a picture of a massive political fundraising operation with essentially no expenses."

The CLC tried to follow the money and found it disappeared in the hands of WinRed. The disbursements to candidates and committees is there, but nothing else about their operation.​​​​​

Then there's WinRed Technical Services which is WinRed's technological infrastructure running the website and donation processing and distribution. With almost no cost accounting on this operation "with a miniscule sum that WinRed has reported paying WTS would appear to be wildly below the commensurate fair market rate."

The rest of the complaint is 5 pages detailing campaign finance law violations. Too much to summarize here. Mostly what I've already detailed.

New York Times story in January of 2022 with four State Attorneys General investigating fraudulent tactics by WinRed.

Here's a story of a man who WinRed ripped off for $90,000 across 6 credit cards, and when he was finally able to stop it, they would only refund payments in the last 60 days, so he only got $59,000 back.

If you go to the WinRed page at FEC.gov it shows $1.6 billion in distributions in 2023-2024, but information on expenditures is missing.

If you look at ActBlue, it has complete disclosure.

This New York Times article from 2023 is about Republicans mad about WinRed plans to increase fees. It also adds that Trump, Jared Kushner and Brad Parscale, Trump's campaign manager, helped create WinRed. That's not in the Wikipedia entry. It puts a whole new light on it, doesn't it?

Here's a FEC page with the Campaign Legal Center complaint about Trump making hundreds of millions of dollars in undisclosed payments to subvendors.

What's really annoying is even at the FEC and at Campaign Legal Center's website, I can't find anything about the complaint against WinRed and what happened to the case. All I can find is the CLC filing lots of complaints against the FEC for dismissing complaints.

Let's get our villains straight. The real culprit is WinRed, not ActBlue. But we need to get Trump's angle of attack.

The fact sheet says "the Memorandum notes that a congressional investigation revealed significant fraud schemes using ActBlue and, over a 30 day period during the 2024 election cycle, hundreds of ActBlue donations came from foreign IP addresses using prepaid cards, despite it being illegal for foreign nationals to contribute to U.S. elections."

The problem here is that the memorandum actually says that ActBlue caught the donations and wouldn't process them as a result, and there were 237 of them. There was no Congressional investigation that found them, ActBlue found them. Now you have Trump lying from one document to another. But, as a result, he directs the Attorney General to conduct an investigation into ActBlue.

In the fact sheet, Trump makes accusations he doesn't have in the memorandum. "ActBlue has become notorious for its lax standards that enable unverified and fraudulent donations." It's was their standards that found the attempts at making fraudulent donations.

"The investigation revealed that ActBlue trained employees to 'look for reasons to accept contributions' even in the face of suspicious activity."

This information isn't in the memorandum at all. There is a number of employee review pages in the House report, but nothing that says what Trump claims. It's not even described in the table of contents or the report.

"Until recently, ActBlue accepted political contributions without requiring a card verification value (CVV), making it easy to donate without identity verification."

ActBlue hadn't been asking for the CVV code but they are now. But, unlike WinRed, ActBlue hasn't had all kinds of lawsuits against it for taking money without authorization.

There is a 479 page report PDF from the House Committee on Oversight and Government Reform. Dated April 2, 2025. Odd that it came out on tariff "Liberation Day." The report is actually 19 pages, the rest is "evidence." ActBlue uses an AI supported service called Sift that examines transaction data and determines whether it needs to be reviewed by a human being. Their fraud detection service. The House report claims 99.8% are passed by Sift, leaving 0.2% for review. Footnote on this references Exhibit 1. From that exhibit:

"We have rules that automatically reject donations that use foreign prepaid/gift cards, domestic gift cards, are from high risk/sanctioned countries, and have the highest level of risk as determined by Sift. We manually review all transactions a tier lower than the highest level, even some lower than that if they have certain risky signals (i.e. IP/billing country mismatch)."

I'm not completely sure about what the "countries" is all about because you can't accept any. It is possible to have a U.S. citizen abroad making a donation.

In December of last year a House Committee asked Sift for an accounting of their operations for ActBlue.

In writing the committee report, it looks like they went in with a predetermined conclusion. Here's the table of contents:

The headings are all conclusions without laying out the procedures with which they came to the findings.

ActBlue did change their credit card entry to include the CVV code. This may have been done in response to the House Committee investigation or they planned to do it all along. This is an accusation Trump makes in the fact sheet that without it, there were fraudulent transactions. I could find no cases of people suing ActBlue, but a history of them against WinRed. I stopped listing them when I thought the point was made.

Fact Sheet: "Numerous state attorneys general have opened investigations into ActBlue over suspicious donations made through obscured identities and untraceable means."

The Committee Chairman sent letters to State's attorneys general in Texas, Virginia, Arkansas, Florida, and Missouri in September. But only Ken Paxton of Texas actually did anything. So, the "numerous attorneys general" is a lie. It is only Paxton, and there is no news beyond him starting it because of ActBlue not requiring the CVV code. Reporting deadends at the end of October.

The House Committee report is titled: Fraud on ActBlue: How the Democrats' Top Fundraising Platform Opens the Door For Illegal Election Contributions."

They went in with a foregone conclusion and the the investigation was mostly about Sift, not ActBlue. After the first 10 pages of the evidence, most of the rest is unidentifiable as to having any meaning.

The only thing the Republicans have is the CVV code. The "straw donor" accusation is a ruse. The attempts for foreign donors were caught by Sift for ActBlue. Suspicious ones human beings reviewed. Trump lies in the memorandum, then includes it in the fact sheet. Then he lies in the fact sheet that isn't in the memorandum.

What the Democrats in Congress should have been doing is getting an investigation going into WinRed. WinRed has serious reporting violations and an operation that doesn't follow campaign finance law and just plain old business finance reporting. Going to their listing at the FEC makes this readily apparent. Why the FEC hasn't investigated WinRed is a massive cause for concern. Understandable, but suspect, during Trump years, but why was nothing done during the Biden years? What happened to the Campaign Legal Center's complaint?

Trump's attack is based on the conclusions from the House Committee report. Those conclusions come from almost no real data. It accuses of ActBlue changing the Sift processing rules to allow "straw donations." There are memos by ActBlue about changes, but drawing the conclusion that it is to allow straw donors is not valid. There is ActBlue documentation on putting the CVV capture into effect, like this is a crime. At the end of the report, there is section of ActBlue reports on known fraud attempts and organizations that were doing them and ones that were being used to do them. These are "straw donors" they caught. This isn't evidence of a crime by ActBlue, it's evidence that they are doing everything they can to prevent fraud.

Trump is going after ActBlue because he can. The House investigation is flawed. Anything Ken Paxton could ever come up with should be ignored considering the source.

The real culprit is WinRed.

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