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Breitbart NewsDecember 9, 2024
Ms. Regina Wallace-Jones
Chief Executive Officer
ActBlue
P.O. Box 441146
Somerville, MA 02144
Dear Ms. Wallace-Jones:
The Committee on the Judiciary is charged with upholding fundamental American civil
liberties and protecting the integrity of American elections. According to recent reporting,
ActBlue, a major online political fundraising platform, maintains poor anti-fraud policies that
have allowed bad actors to make fraudulent political donations, including from foreign sources.1
Fraudulent political donations corrupt American elections and could amount to interstate
criminal conduct. As the Committee examines these matters, we write to request your
cooperation with our oversight.
The Federal Election Campaign Act of 1971 (FECA) states that “no person shall make a
contribution in the name of another person . . . and no person shall knowingly accept a
contribution made by one person in the name of another person.”2 Under FECA’s statutory
scheme, fraudulent donors and entities accepting fraudulent donations may face criminal
liability.3 Federal law also prohibits foreign nationals from making contributions, either directly
or indirectly, “in connection with a [f]ederal, [s]tate, or local election,” or to a political party.4
Recent reports suggest that ActBlue may be allowing fraudulent political donations to
occur on its platform. For example, the Committee on House Administration recently conducted
1
See Miranda Devine, Potential ActBlue criminal charges over possible fraud donations once again reveal the
Dems’ fraud campaign, N.Y. POST (Sept. 19, 2024); Josh Christenson, Treasury finds hundreds of transactions
linked to fundraising platform ActBlue flagged by banks: GOP memo, N.Y. POST (Oct. 29, 2024); Breanne
Deppisch, Democrat platform ActBlue subpoenaed by House committee amid concerns foreign donors exploited
security flaws, FOX NEWS (Oct. 31, 2024).
2
52 U.S.C. § 30122.
3
52 U.S.C. § 30109(d)(1)(D); see United States v. Hui, No. 2:23-mj-00865 (E.D.N.Y. 2024); Karen Zraick &
Bianca Pallaro, Chinese Magnate in Straw Donor Scheme Agrees to Leave U.S. in Plea Deal, N.Y. TIMES (May 9,
2024) (detailing a Chinese national’s criminal conviction for operating a “straw donor scheme.”)
4
52 U.S.C. § 30121.
Ms. Regina Wallace-Jones
December 9, 2024
Page 2
a data analysis of Federal Election Commission records that uncovered suspicious transactions
made using ActBlue, including donations larger than the named donor could afford,
“uncharacteristic donations from registered voters suddenly contributing to candidates of the
opposing party,” and “unusually frequent” donations from vulnerable individuals, including
senior citizens and first-time donors.5 Similarly, in response to an inquiry by the Committee on
Oversight and Reform, the Treasury Department confirmed that it was reviewing “hundreds” of
potentially fraudulent ActBlue transactions identified in suspicious activity reports from major
banks.6
ActBlue’s weak anti-fraud protections have opened the door for these suspicious and
potentially criminal donations. Until recently, ActBlue did not require donors to enter a Card
Verification Value (CVV)—a common practice to ensure the safety of online transactions.7
Furthermore, federal law does not currently prohibit contributions made through untraceable gift
cards or other prepaid cards, a loophole that foreign actors could easily take advantage of due to
ActBlue’s weak security measures. Evidence indicates that nationals from China, Russia, Iran,
and Venezuela may have exploited ActBlue’s vulnerabilities to make dozens of fraudulent small-
dollar contributions to Democrat campaigns using the names and addresses of unwitting
American citizens.8
ActBlue’s past failure to implement basic, industry standard fraud prevention procedures
raises questions about its commitment to upholding the principles of the American campaign
finance system. The potential that bad actors, including foreign adversaries, have used ActBlue
to illegally make political donations forces the Committee to examine the potential criminal and
national security ramifications. As such, to further the Committee’s oversight, we request the
following documents and information from January 1, 2020, to the present:
1. All documents and communications referring or relating to ActBlue’s policy on the use
of gift cards and prepaid cards for ActBlue transactions;
2. All documents and communications referring or relating to the potential use of ActBlue
by foreign nationals to make illegal political contributions;
3. All communications between ActBlue and the Executive Branch, including federal law
enforcement, referring or relating to potentially fraudulent transactions on ActBlue;
5
Miranda Devine, Potential ActBlue criminal charges over possible fraud donations once again reveal the Dems’
fraud campaign, N.Y. POST (Sept. 19, 2024).
6
Josh Christenson, Treasury finds hundreds of transactions linked to fundraising platform ActBlue flagged by
banks: GOP memo, N.Y. POST (Oct. 29, 2024).
7
Letter from Regina Wallace-Jones, CEO & President, ActBlue, to Rep. Bryan Steil, Chairman, Comm. on H.
Admin. (Nov. 27, 2023); CVV Codes: The Ultimate Guide for Merchants, TIDAL COMMERCE (last accessed Nov. 7,
2024) (“It’s common practice for merchants to ask for the CVV code to check and see if the buyer is the rightful
owner of the credit card, and is arguably the best way to make sure the customer actually has the card in their
possession.”).
8
Bethany Blankley, AG Paxton: Texas Investigation Into ActBlue Uncovers Suspicious Donations, THE CENTER
SQUARE (Oct. 21, 2024); Tony Perkins (@tperkins), X (Nov. 2, 2024, 12:10 PM),
https://x.com/tperkins/status/1852744980684837132.
Ms. Regina Wallace-Jones
December 9, 2024
Page 3
4. All documents and communications referring or relating to ActBlue’s efforts to deter
fraudulent transactions, including but not limited to (a) information about ActBlue’s
fraud detection team; (b) ActBlue’s guidelines for detecting potentially fraudulent
transactions; and (c) ActBlue’s standard operating procedure when it detects potentially
fraudulent transactions; and
5. A list of all third-party vendors and contractors employed by ActBlue for fraud
prevention.
We respectfully ask that you produce the requested documents as soon as possible, but no
later than 5:00 p.m. on December 23, 2024. Pursuant to the Rules of the House of
Representatives, the Committee on the Judiciary has jurisdiction to conduct oversight of matters
concerning civil liberties, criminal law, and U.S. national security to inform potential legislative
reforms.9 If you have any questions about this matter, please contact Committee staff at (202)
225-6906.
Thank you for your prompt attention to this matter.
Sincerely,
Jim Jordan
Chairman
cc: The Honorable Jerrold L. Nadler, Ranking Member
9
Rules of the House of Representatives R. X (2023).
