Chairman Memo to Members Re Campaign Finance Treasury Records 10.25.24

Committee on Oversight and Accountability Majority Members
October 25, 2024

Page 1 of 2
MEMORANDUM
TO: Committee on Oversight and Accountability Majority Members
FROM: Chairman James Comer, Committee on Oversight and Accountability
DATE: October 25, 2024
RE: Update on the Committee’s investigation into reports of potentially fraudulent and
illicit financial activity related to contributions to campaigns of candidates for
federal offices mediated by online fundraising platforms like ActBlue
I am releasing this memorandum to update you on new developments in the Committee’s

investigation into reports of potentially fraudulent and illicit financial activity related to
campaign contributions facilitated by online fundraising platforms like ActBlue. The Committee
wrote to the U.S. Department of the Treasury (Treasury), on September 20, 2024, requesting
certain financial records relevant to the Committee’s investigation. 1 Although Treasury has not
yet produced any records, it is currently reviewing hundreds of potentially responsive records
according to three video conference calls between Committee and Treasury staff since the initial
request.
As a reminder, the Bank Secrecy Act (BSA) requires financial institutions to assist U.S.
government agencies in detecting and preventing money laundering by filing Suspicious Activity
Reports (SARs) whenever they encounter instances that might signal criminal activity (e.g.,
money laundering, cash transactions greater than $10,000 daily, tax evasion, etc.). 2 The
Committee requested all Suspicious Activity Reports (SARs) filed with the Treasury Department
by financial institutions which included the term “ActBlue” and transactions related to “money
laundering, counterfeit credit/debit card, credit card or debit card fraud, false statements, wire
transfer fraud, or identity theft” since January 1, 2023. 3 According to Treasury officials, this
request has yielded several hundred records. Treasury revealed this is one of the largest records
reviews it has conducted this Congress.
Recent reports have raised the specter of fraud and evasion of campaign finance law by
individuals exploiting online contribution platforms, especially ActBlue. For example, ActBlue
had not implemented standard procedures to guard against identity theft and fraud such as
1
Letter from Rep. James Comer, Chairman, H. Comm. on Oversight & Accountability to the Hon. Janet Yellen,
Secretary, U. S. Department of the Treasury (Sept. 20, 2024).
2
Suspicious Activity Reports (SAR), Office of the Comptroller of the Currency, U.S. Department of the Treasury.
3
Supra note 1.
Committee on Oversight and Accountability Majority Members
October 25, 2024
Page 2 of 2
requiring a Card Verification Value (CVV) to process online transactions until it received
criticism for not doing so. 4 ActBlue is also being investigated by several state’s officials in
relation to contributions allegedly made via the platform fraudulently without the reported
contributor’s awareness. 5 The Committee is concerned that failure to properly vet contributions
made through online platforms may have allowed bad actors, including foreign nationals not
lawfully admitted for permanent residence or individuals attempting to evade individual
contribution limits, 6 to more easily commit fraud to illegally exploit and violate federal
campaign finance laws.
The Committee’s concerns have only heightened since learning there is a potentially
large volume of responsive documents. Considering this new development, the Committee is
working closely with Treasury to obtain the materials expeditiously. It is imperative that
Congress determine whether legislation is necessary to ensure adherence to statutes related to
campaign finance, and guard against foreign or unfair influence in our elections. Some records
produced by Treasury are protected by the Bank Secrecy Act, and thus we ask you to keep this
information confidential.
The Committee will continue to urge Treasury to produce responsive documents quickly.
I will keep you updated on any further developments of this important investigation.
4
See Charlotte Hazard, Texas AG Paxton’s investigation leads ActBlue to require CVV codes when people make
donations, JUSTTHENEWS (Aug. 9, 2024).
5
Press Release, Attorney General of Texas, Attorney General Ken Paxton’s Ongoing Investigation Into ActBlue
Yields Cooperation On Donor Credit Card Identification (Aug. 8, 2024); Letter from Jason Miyares, Office of the
Attorney General, Commonwealth of Virginia to ActBlue (Aug. 2, 2024); Jeff Victor, Secretary of State
investigating ActBlue Wyoming based on national allegations, WYOMING PUBLIC RADIO (Aug. 19, 2024).
6
See 52 U.S.C. § 30116 (setting forth limitations on contributions and expenditures); see also Federal Election
Commission, Contribution limits, available at https://www.fec.gov/help-candidates-and-committees/candidate-
taking-receipts/contribution-limits/.

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Committee on Oversight and Accountability Majority Members

October 25, 2024

TO: Committee on Oversight and Accountability Majority Members

FROM: Chairman James Comer, Committee on Oversight and Accountability

DATE: October 25, 2024

I am releasing this memorandum to update you on new developments in the Committee’s

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