Investigation into Unlawful “Straw Donor” and Foreign Contributions in American Elections
President Trump issued a memorandum directing the Attorney General, in consultation with the Secretary of the Treasury, to fully investigate alleged misuse of online fundraising platforms for illegal campaign contributions.
The investigation will focus on schemes involving 'straw donors' and foreign nationals attempting to circumvent campaign finance laws.
The Attorney General is required to submit a report on the findings within six months.
Arguments For
Protecting the Integrity of Elections: The investigation aims to uphold the integrity of American elections by preventing illegal campaign contributions and foreign influence. The intended benefit is a fairer and more transparent electoral process.
Enforcing Federal Laws: This action enforces existing federal laws (52 U.S.C. 30121 and 30122) prohibiting illegal campaign contributions. The legal basis is clearly established, and the implementation method involves utilizing existing investigative authorities.
Addressing Systemic Issues: The investigation seeks to address potential vulnerabilities in online fundraising platforms that are being exploited for illegal activities. The evidence cited includes press reports and congressional committee investigations indicating widespread abuse.
Deterrence: A swift and thorough investigation could serve as a deterrent to future attempts to exploit online fundraising platforms for illegal political contributions.
Arguments Against
Potential for Overreach: The broad scope of the investigation could lead to unintended consequences, potentially affecting legitimate political fundraising activities.
Implementation Challenges: Investigating these schemes may be difficult, requiring complex financial tracing processes and extensive resources.
Resource Allocation: The investigation will require significant resources from the Department of Justice and the Department of the Treasury, potentially diverting funds from other important tasks.
Political Motivation: The timing and focus of the investigation might be perceived as politically motivated, thereby undermining the investigation's credibility.
MEMORANDUM FOR THE SECRETARY OF THE TREASURY THE ATTORNEY GENERAL THE COUNSEL TO THE PRESIDENT
This section identifies the recipients of the memorandum: the Secretary of the Treasury, the Attorney General, and the Counsel to the President.
These individuals are tasked with specific responsibilities in the investigation.
SUBJECT: Investigation into Unlawful “Straw Donor” and Foreign Contributions in American Elections
The subject line clearly states the purpose of the memorandum: to initiate an investigation into unlawful 'straw donor' and foreign contributions influencing 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.
This section cites the relevant federal laws (52 U.S.C. 30121 and 30122) that prohibit making political contributions on behalf of another person (straw donations) and contributions from 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.
This paragraph highlights concerning evidence from press reports and congressional investigations, suggesting that online platforms are complicit in schemes to launder illegal campaign contributions.
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.
The paragraph details the methods used to evade campaign finance laws, involving the breakdown of large contributions into smaller, seemingly legitimate donations and the use of 'dummy' accounts and prepaid cards to obscure the source of funds.
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.
This paragraph focuses on evidence of foreign nationals using online platforms to illegally influence US elections, citing a House investigation that found significant instances of fraud with foreign connections.
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.
The President’s directive to the Attorney General and the Secretary of the Treasury is to investigate the alleged unlawful activities and enforce relevant laws.
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.
The Attorney General is instructed to provide a report on the investigation's findings to the President within 180 days.
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.
This is a standard disclaimer stating that the memorandum does not create any legally enforceable rights.
DONALD J. TRUMP
This is the President's signature.