FILE_4769
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Breitbart NewsDecember 9, 2024
Mr. Kris Nagel
Chief Executive Officer
Sift
525 Market Street, Sixth Floor
San Francico, CA 94105
Dear Mr. Nagel:
The Committee on the Judiciary and the Committee on House Administration (CHA),
operating under the jurisdiction to protect the integrity of American elections1, write to you with
urgent concerns regarding potential illicit election funding by foreign actors. According to recent
reporting, ActBlue, a major online political fundraising platform, has maintained poor anti-fraud
practices that have allowed bad actors to make fraudulent political donations, including from
foreign sources.2 Fraudulent political donations corrupt American elections and could amount to
interstate criminal conduct. Because Sift has provided “fraud detection and prevention services”
for ActBlue, we write to request your cooperation with our oversight.3
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.”4 Under FECA’s statutory
scheme, fraudulent donors and entities accepting fraudulent donations may face criminal
liability.5 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.6
Recent reports suggest that ActBlue may be allowing fraudulent political donations to
occur on its platform. For example, CHA recently conducted a data analysis of Federal Election
1
Rules of the House of Representatives R. X (K) Committee on House Administration, (L) Committee on the
Judiciary (2023).
2
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).
3
Privacy Policy, ActBlue, https://secure.actblue.com/content/legal-privacy-previous (last accessed Nov. 21, 2024).
4
52 U.S.C. § 30122.
5
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.”)
6
52 U.S.C. § 30121.
Mr. Kris Nagel
December 9, 2024
Page 2
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.7 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.8
ActBlue’s previous privacy policy, which expired on August 19, 2024, indicates that
ActBlue employed Sift as a “third party vendor[]” for “fraud detection and prevention services.”9
Yet, ActBlue’s notoriously weak anti-fraud practices opened the door for these suspicious and
potentially criminal donations to occur. Evidence indicates that foreign nationals could have
exploited ActBlue’s poor security measures to make fraudulent small-dollar contributions to
Democrat campaigns using the names and addresses of unwitting American citizens.10
Adversaries, including China, Russia, Iran, and Venezuela, could have taken advantage of this
vulnerability.11
It appears that ActBlue’s “fraud detection and prevention services” likely failed to stop
fraudulent transactions from occurring on the platform.12 The potential that these bad actors may
have exploited lax security measures provided to ActBlue by Sift forces the Committees to
examine the potential criminal and national security ramifications. As such, to further the
Committees’ oversight efforts, we request the following documents and information from
January 1, 2020, to the present:
1. All documents and communications referring or relating to Sift’s efforts to deter
fraudulent transactions on ActBlue, including but not limited to (a) information about
Sift’s fraud detection team; (b) Sift’s guidelines for detecting potentially fraudulent
transactions on ActBlue; and (c) Sift’s standard operating procedure when it detects
potentially fraudulent transactions on ActBlue;
2. All documents and communications referring or relating to potentially fraudulent
transactions on ActBlue, including but not limited to reports to ActBlue or Sift from U.S.
7
Miranda Devine, Potential ActBlue criminal charges over possible fraud donations once again reveal the Dems’
fraud campaign, N.Y. POST (Sept. 19, 2024).
8
Josh Christenson, Treasury finds hundreds of transactions linked to fundraising platform ActBlue flagged by
banks: GOP memo, N.Y. POST (Oct. 29, 2024).
9
Privacy Policy, ActBlue, https://secure.actblue.com/content/legal-privacy-previous (last accessed Nov. 21, 2024).
10
Bethany Blankley, AG Paxton: Texas Investigation Into ActBlue Uncovers Suspicious Donations, THE CENTER
SQUARE (Oct. 21, 2024).
11
John Solomon, House formally subpoenas ActBlue as feds confirm suspicious activity tied to Democrat
fundraising, JUST THE NEWS (October 30, 2024). Tony Perkins (@tperkins), X (Nov. 2, 2024, 12:10 PM),
https://x.com/tperkins/status/1852744980684837132.
12
Steven Richards, Speaker Johnson shares website to check for fraudulent donations amid ActBlue scrutiny, JUST
THE NEWS (Oct. 23, 2024); see also Speaker Mike Johnson (@SpeakerJohnson), X (Oct. 24, 2024, 9:08 AM),
https://x.com/SpeakerJohnson/status/1849437890620576190; Tony Perkins (@tperkins), X (Nov. 2, 2024, 12:10
PM), https://x.com/tperkins/status/1852744980684837132.
Mr. Kris Nagel
December 9, 2024
Page 3
citizens alleging unauthorized or fraudulent transactions in their name;
3. All documents and communications referring or relating to the use of CVVs for ActBlue
transactions;
4. All documents and communications referring or relating to the use of gift cards and
prepaid cards for ActBlue transactions;
5. All documents and communications referring or relating to the potential use of ActBlue
by foreign nationals, sanctioned individuals or entities, or sanctioned adjacent persons or
entities to make illegal political contributions; and
6. All documents and communications between or among Sift and the Executive Branch,
including federal law enforcement, referring or relating to potentially fraudulent
transactions on ActBlue.
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 Committees have jurisdiction to conduct oversight of matters concerning
elections, civil liberties, criminal law, and U.S. national security to inform potential legislative
reforms.13 If you have any questions about this matter, please contact Judiciary Committee staff
at (202) 225-6906 or CHA staff at (202) 225-8281.
Thank you for your prompt attention to this matter.
Sincerely,
Bryan Steil Jim Jordan
Chairman Chairman
Committee on House Administration Committee on the Judiciary
cc: The Honorable Jerrold L. Nadler, Ranking Member, Committee on the Judiciary
The Honorable Joseph D. Morelle, Ranking Member, Committee on House
Administration
13
Rules of the House of Representatives R. X (K) Committee on House Administration, (L) Committee on Judiciary
(2023).
