ActBlue’s Own Lawyers Warned They Might Have Misled Congress on Donation Screening
“Democrats are nervous that any additional upheaval at ActBlue could destabilize the party’s critical fund-raising apparatus ahead of the midterm elections.”
Democratic fundraising powerhouse ActBlue has been under investigation for several years by the Department of Justice and House Republicans over allegations that it maintained a lax vetting process for foreign donations. The GOP wants to determine whether foreigners are using the platform to circumvent campaign finance laws.
After conducting a deep dive of their own into the group’s internal legal memos, emails, resignation letters, Slack messages, and interviews with current and former ActBlue employees, New York Times writers Reid Epstein and Shane Goldmacher published their findings on Thursday.
They discovered that in early 2025, attorneys from the Covington & Burling law firm that represented ActBlue, warned that Regina Wallace-Jones, the organization’s chief executive, “had given a potentially misleading response to congressional Republican investigators in a 2023 letter explaining how the organization vetted donations to ensure that they were not illegally coming from foreign citizens.”
This is a serious matter because foreigners are prohibited from “donating directly to federal candidates or political action committees. Lying to or obstructing Congress is a crime.”
Wallace-Jones had claimed in the letter that ActBlue “carried out ‘multilayered’ screenings of contributions that helped ‘root out’ those from overseas.”
The lawyers found that these screenings were not consistently conducted and issued two memos outlining the potential legal risks associated with the letter.
The Times reported:
One memo raised the specter of a criminal investigation if prosecutors believed that ActBlue had tried to conceal facts about its efforts to prevent foreign contributions.
The memos instigated a meltdown at the highest levels of ActBlue, one of the Democratic Party’s most vital financial organs.
A series of top officials resigned in quick succession. The New York Times revealed those departures last year, but a key cause of the tumult at ActBlue — the legal warnings about potentially misleading Congress over vetting foreign donations — is being reported here for the first time.
I reported on this story in March 2025 here. At the time, the top officials had just resigned and allegations of fraud and money laundering were swirling around ActBlue. I wrote: “Reports last week that at least seven senior officials had departed the organization, along with claims from a remaining lawyer that he faced internal retaliation, have only heightened GOP lawmakers’ scrutiny of ActBlue’s activities.”
According to the Times:
ActBlue is now all but declaring war on its own past lawyers, an extraordinary turn of events at a moment when President Trump has already ordered a Justice Department investigation into the organization. Democrats are nervous that any additional upheaval at ActBlue could destabilize the party’s critical fund-raising apparatus ahead of the midterm elections.
One of the Covington Burling memos read:
It can be alleged that ActBlue accepted and/or facilitated the acceptance of foreign-national contributions into American elections. In addition, because ActBlue’s staff was aware that its system was not as robust as necessary, it could be alleged that these violations were ‘knowing and willful,’ a standard that both increases the penalties the F.E.C. might seek and gives the Justice Department jurisdiction for a potential criminal investigation.
To say the least, the memos created turmoil inside of ActBlue and raised concern about Wallace-Jones’s leadership.
Epstein and Goldmacher describe a video conference held several days after the memos were delivered. “Dana Remus, a Covington lawyer who served as White House counsel in the Biden administration, warned Ms. Wallace-Jones that she was at risk of having legal liability and needed her own personal lawyer, according to two people who were on the call.”
[It’s unclear why Covington and Burling had signed off on Wallace-Jones letter in the first place as she claims.]
Several days after the call, ActBlue fired Covington and Burling.
The second memo states that ActBlue had inquired about the “potential legal risks associated with statements to Congress that may be alleged to be false or misleading.” The lawyers replied that “the maximum penalties were five years in prison and $250,000 in fines, though it added that such a sentence would be ‘extremely unlikely.'”
Advising ActBlue about the letter to Congress, the Covington lawyers wrote, “in our view, the strongest defense is that when read in context, the statements are accurate,” and that the relevant paragraphs “contain qualifying language.”
[Covington and Burling] outlined three potential options for ActBlue:
Provide new information “without explicitly stating that ActBlue is correcting the record”
“Explicitly correct the record”
“Do not provide additional information clarifying the prior statements”
For each option, Covington presented ActBlue with advantages and risks. Some of the most severe risks came from doing nothing.
Epstein and Goldmacher go on to detail the mounting internal conflict within the organization as it grapples with the investigations.
🚨🚨🚨
This ActBlue investigation is among the biggest bombshell campaign finance corruption and actual foreign election interference stories in American politics.
And it was all so publicly obvious, with many urging the media to look into this, but until recently, the media…
— Elise Stefanik (@EliseStefanik) April 2, 2026
Following the exodus of top ActBlue officials last year, Chairman of the House Oversight Committee James Comer (R-KY) joined independent journalist Benny Thompson for an interview. Comer revealed that the Treasury Department had received hundreds of suspicious activity reports (SARs) from banks regarding ActBlue’s transactions.
“But from what we’ve already seen — from media reports and the few bank violations we’ve reviewed — many of our worst theories regarding ActBlue are going to be confirmed,” Comer predicted. “That’s why so many people are hitting the exits at ActBlue right now.”
Johnson shared a previously reported story of an 80-year-old woman from Richmond, Virginia, who allegedly made over 22,000 donations, totaling nearly $800,000, despite living in a rent-controlled apartment and relying on income from Social Security.
Comer further suggested that ActBlue’s system was deliberately designed to facilitate fraud, referencing then-Sen. Marco Rubio’s past concerns about the platform not requiring credit card verification (CCV) codes (the 3-digit security code on the back of every credit card). He implied that this loophole made it easier for foreign entities, possibly from China or Iran, to funnel money into U.S. elections through ActBlue.
The significance of ActBlue to the Democratic Party cannot be overstated. Democrats are said to be panicking because the midterms are coming up and virtually all donations to party candidates are made through this fundraising platform. Fox News reports it has raised $16 billion since 2004.
It would sure be a shame if something were to happen to it!
🚨 Breaking: President Donald Trump has stunned the nation by directing the DOJ to launch a full-scale investigation into ActBlue, the Dems’ key fundraising arm, amid claims of massive election interference and shady overseas donations.
Did you vote for this? pic.twitter.com/VyOjEF0z71— Hazel Moore (@HazelMoore32) April 1, 2026
Elizabeth writes commentary for Legal Insurrection and The Washington Examiner. She is an academy fellow at The Heritage Foundation. Please follow Elizabeth on X or LinkedIn.
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Comments
Investigate, indict, convict, jail, and publicize. Hopefully they can sweep up people from the DNC as well. Bonus for any elected officials. Hehehe Subpoena Schumer and the MINORITY leader and see what they know too. Grap Pelosi’s raggedy old ass and squeeze some I don’t recalls out of her.
ActBlue has done this forever.
Since the Obama days for sure the lack of consistency in efforts to verify eligibility to donate and use of ghost donors (stolen ID) has been a ‘thing’. If we want compliance then the penalties gotta be meaningful. Monthly reporting with mini audits of 1/2 of 1% of contributions by FEC to see if there’s widespread lack of compliance. Then shut it down if the audit comes up hot. Freeze the account, no funds out, no funds in until a full 100% audit is finalized. That would create incentives for rigorous voluntary compliance.
Al Gore and his no controlling authority mumbled when he was grilled about his illegal soliciting of foreign contributions from the white house.
Sure but the Obama era took it to scale with deliberately refusing to take CVV codes or properly document millions of ‘small’ donors and ramped up the level to eleventy. I suspect that b/c some GoP have occasionally been lax there was a decided lack of interest in thorough investigation. Plus someone in the corporate media would say mean things to hurt their feelings and they might be left off a DC cocktail circuit invitation.
Almost any politician these days will do anything to get bucks as long as they think they won’t get caught.
They have. It is the primary vehicle through which they laundered the USAID and other money sent into Ukraine. Send money to Ukraine, some is skimmed and untraceable pre paid Visa card are purchased and the money donated right back to Dems through ActBlue. Rinse and repeat. This is why they screamed so loud and worked so hard going as far a impeaching a President to stop any investigation into where the money was going.
My only question is that we all knew it was happening a few years ago so why wasn’t anything done then? Who blocked or slow walked the investigation?
I (D)on’t who may have blocked the investigation, but I am willing to make an e(D)ucated guess that it was someone from the Obama/Burden administrations.
Let’s just be real, they didn’t give a crap where the money came from.
This is the biggest scandal since “Test Person,” “Doodad Pro,” and “Good Will” donated to the Obama campaign for the 2008 election.
This goes back to the Obama campaign in 2008 turning off verification capabilities. Nothing new. Maybe this is why Pam Bondi was moved out. This has been known for over a year and no grand jury convened. No investigation that we know of.
“Lying to or obstructing Congress is a crime.”
But only if you’re a Little Person.
Want a fun exercise?
Go to OpenSecrets,org and pick a relatively common last name in a given state. (Not Smith or Jones, be more inventive than that. Wilkinson, Sanders, Gonzales, etc.) Then scroll down and see how many times you come across people with that name who give $6 (sometimes $3, but $6 is the usual) several times every week to ActBlue. Congratulations — you’ve found smurfs!
Nothing will happen to the perps. And even if it did, the Communist Party still gets billions – yes, billions – in in-kind contributions from academia and the media.
You didn’t expect them to destroy Portland and Seattle for free.
Prediction: nothing comes of this.
Regarding the DNC…
Boudreaux [hereafter, just B] is a good ol’ Cajun from Thibodeaux, La. He’s also a cop. Goes to see his boss one morning.
B, I want you to go to N’awlins. Dey be sump’n real fishy goin’ on wit de cockfights down dere.
OK, boss.. I’m on it.
Next morning B’s back in his boss’s office. OK, boss, I done figured it out.
In one day???
Yeah. Dere’s three groups involved: da Texas Aggies, da Cajuns, and de DNC from N’awlins.
??? Da Aggies??
Yeah. Along with all da gamecocks, dere was a duck in da mix. Had to mean Aggies was involved.
Ooookay. But da Cajuns??
Somebody bet on da duck.
Ooookay, I can see dat. But da DNC? How you figure dat?
Da duck won!
I can speak directly to this as two fraudulent donations were made in my name through Act Blue to BLM and Planned Parenthood. They have no safeguards and one can easily see how they can launder fraudulent donations through people’s stolen identities.