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In November 2023, American Promise released The Problem of Foreign Money in Politics, a report detailing the ways in which foreign money makes its way into state and federal elections in the United States. The report described how alarmingly easy it is for foreign actors to influence election outcomes by funneling money into our campaign finance system.
With the 2024 election likely to wind up as one of the most expensive electoral cycles in American history, with almost $16 billion in federal election spending, we wanted to revisit some of the existing vulnerabilities in our electoral system.
The term “dark money” refers to money spent in elections by groups that aren’t required to disclose their funders. For example, 501(c)(4) organizations are not required to disclose their donors, but they are permitted to spend money to influence elections. Although it is virtually impossible to know the full extent to which foreign money is making its way into our elections, there are some high-profile examples. Recently, the Berger Action Fund, a nonprofit backed by Swiss billionaire Hansjörg Wyss, transferred more than $60 million to progressive groups in 2022 and 2023.
One major nonprofit that receives funding from the Berger Action Fund is the Sixteen Thirty Fund, a dark money nonprofit that received $35 million from Berger Action between 2022 and 2023.
Sixteen Thirty Fund gave out more than $150 million to Democrat-aligned groups between 2022 and 2023, and more recently, gave $6 million in May 2024 to a redistricting ballot initiative in Ohio.
Online fundraising platforms that do not properly verify the identity of donors could be vulnerable to receiving donations from foreign actors, whether intentionally or not. When they do not require a CVV number or billing address, it makes it far more difficult for the platform to identify and block illegal contributions made by foreign nationals.
The fundraising platform ActBlue, which has processed billions of dollars in donations for Democratic candidates and causes, has been criticized for not requiring CVV codes for all donations made with credit cards.
In response to this vulnerability in the campaign finance system, Congressman Bryan Steil (R-WI) recently introduced the Secure Handling of Internet Electronic Donations (SHIELD) Act, which would prevent all political committees from accepting donations from credit and debit cards without a CVV and billing address.
In October 2024, Representative Steil and Senator Ron Johnson sent letters to the Director of National Intelligence, the Director of the FBI, and the Secretary of the Treasury. In those letters, they state that investigation by the Committee on House Administration has uncovered potential abuses of ActBlue’s services by foreign actors to launder money into American campaigns, and they request briefings from those departments on how they are investigating foreign interference in our elections.
We already know that America’s foreign adversaries are seeking to exert influence in our elections. A briefing from the Office of the Director of National Intelligence (ODNI) identified election influence attempts from China, Russia, and Iran.
Foreign actors have been brazen in their attempts to influence American officeholders, to the point of directly offering cash gifts and other financial rewards in exchange for preferential treatment.
NYC Mayor Eric Adams has been indicted by federal prosecutors on multiple charges, including solicitation of a contribution by a foreign national. Prosecutors allege that Adams’ campaign disguised foreign contributions as being from American citizens, leading to his campaign receiving over $10 million in matching public funds.
Former Senator Bob Menendez (D-NJ) was convicted on corruption charges for taking bribes in the form of cash and gold bars from Egyptian agents in exchange for using his position as chairman of the Senate Foreign Relations Committee to benefit Egypt, including helping it access millions of dollars in U.S. military aid.
In Maine, after clear evidence of foreign interference that was legal under existing campaign finance laws, 86% of voters responded by passing the Protect Maine Elections ballot initiative to prohibit spending by foreign nationals in the state’s ballot elections. Within weeks of the new law’s passage, two foreign-owned utility companies filed suit to block the law. In February 2024, a federal district court granted a preliminary injunction to prevent the law from going into effect.
In Ohio, a bill to ban foreign money from the state’s ballot elections was passed by the legislature and signed into law by Republican Governor Mike DeWine in June. In September 2024, a federal district court initially blocked the law on the grounds that it “infringes on lawful resident foreign nationals’ First Amendment right to political speech.” In other words, although the state’s legislature and governor passed the law to protect the integrity of Ohio’s ballot elections against foreign influence, a federal district court overrode that decision by stopping the law in its tracks. Although the Sixth Circuit recently allowed the law to take temporary effect, litigation is ongoing and the law remains vulnerable.
As mentioned above, the 2024 election is estimated to have seen almost $16 billion in total federal election spending, the highest ever election spending total (in nominal dollars). The sheer amount of money flowing into our elections makes it difficult for any investigative organization or regulatory body, let alone an individual citizen, to track the web of influence networks and donors that fuel this spending.
In particular, the prevalence of dark money, which allows donors to hide their identity by funneling contributions through nonprofit organizations and shell companies, leaves our elections vulnerable to foreign influence. The 2024 election saw more than $1 billion in dark money contributions, primarily from 501(c)(4) nonprofits that do not have to disclose their donors and can legally take contributions from foreign entities.
Liberal dark money groups spent more than double their conservative counterparts in 2024, and Democrats benefited more from dark money in 2018, 2020, and 2022.
Foreign money and influence is a significant threat to our elections, but courts are blocking the attempts of legislators and citizens to solve this problem, based on the Supreme Court’s misguided doctrine that equates spending to speech. We need a better constitutional framework for dealing with money in politics. The solution is the For Our Freedom Amendment, which would restore the ability of the States and Congress to pass reasonable regulations on campaign finance and secure our elections from foreign interference.
© 2025 American Promise
