‘Substantial risk’: ActBlue’s own lawyers sounded alarms over illegal foreign contributions

Leading Democratic fundraising platform ActBlue is “all but declaring war” on a law firm it fired last year that raised alarms over the group potentially concealing foreign donations from Congress, the New York Times revealed Thursday.

The firm, Covington & Burling, sent a pair of “startling” memos in early 2025 warning that ActBlue President and CEO Regina Wallace-Jones may have misled Republican Wisconsin Rep. Bryan Steil on how the platform makes sure donations are actually coming from U.S. sources, as required by law, according to the NYT. The move reportedly triggered a “meltdown” at what the NYT described as “one of the Democratic Party’s most vital financial organs.

“An aggressive prosecutor may view the November 2023 letter not just as a false statement but as an effort to conceal the foreign contributions,” the firm wrote in one of the memos, the outlet reported.

Covington also indicated in a 2025 memo it determined there was “a substantial risk that some of the funds received” via its client, ActBlue, were “impermissible contributions from foreign nationals,” per the NYT.

“An aggressive prosecutor may view the November 2023 letter not just as a false statement but as an effort to conceal the foreign contributions,” the firm wrote in one of the memos reviewed by the NYT. In another, the firm wrote that it had determined there was “a substantial risk that some of the funds received” by ActBlue were “impermissible contributions from foreign nationals.”

In her 2023 letter to Steil, Wallace-Jones claimed that ActBlue’s approach to preventing fraud “is multilayered, with checks and confirmations occurring throughout the donation process to verify donors and donor information.” The letter came in response to the lawmaker’s October 2023 letter to the ActBlue CEO.

“These measures, which include compliance measures, technological tools, and manual reviews, help to ensure the identity of donors, root out potential foreign contributions, and protect donors from financial fraud,” Wallace-Jones wrote at the time to Steil, who has chaired the House Administration Committee since 2023.

However, Covington stated in the memos that some of the anti-fraud measures that Wallace-Jones described in her letter were not always being enforced by the fundraising platform.

For example, Wallace-Jones wrote in the November 2023 letter that ActBlue required U.S. passport information “from donors providing an address outside of the United States” in order for contributions to be processed. However, Covington’s memos said this claim was not fully true.

ActBlue’s CEO claimed in her letter to Steil, “If a contribution appears to be from a foreign address, ActBlue contacts the donor to request United States passport information. The contribution is refunded if we are unable to make contact with the donor.”

However, Covington wrote in its memos that this was not always the case and donors who used apps like PayPal or Venmo to contribute did not have to verify their passport.

One of the law firm’s memos explicitly stated that ActBlue requested a summary of “potential legal risks associated with statements to Congress that may be alleged to be false or misleading,” according to the NYT.

An ActBlue spokesperson maintained in a statement to the Daily Caller News Foundation that Wallace-Jones’ letter to Steil was “accurate” and “carefully reviewed by inside and outside counsel and key business leaders prior to submission.”

“ActBlue has continually worked to comply with all FEC laws including laws related to appropriately screening for potential foreign contributions, which constitute less than 1% of the total contributions on the ActBlue platform. Of those, many come from the six million American citizens who live abroad—such as US military personnel,” the spokesperson added.

“We have continually improved our processes, even while facing repeated partisan attacks from the Trump Administration and its allies. Most importantly, ActBlue is stable and stronger than ever. We have a passionate team, are expanding our product suite, all while grassroots donors are continuing to break fundraising records,” the spokesperson’s statement continued.

“My investigation into ActBlue remains ongoing. I won’t stop until we have answers,” Steil wrote in a Thursday X post in response to the NYT’s story.

“Our investigation found ActBlue’s internal fraud prevention measures were wholly insufficient for preventing illegal foreign campaign donations. Today’s reporting reconfirms that finding and raises serious questions about whether ActBlue’s CEO intentionally misled Congress at the onset of this investigation,” Steil, House Judiciary Committee Chairman Jim Jordan and House Oversight Committee Chairman James Comer wrote in a joint press release sent to the DCNF.

“We will continue our investigation and keep all options on the table as we seek the truth,” the three Republican lawmakers added.

“In some cases, reports allege that such persons are using untraceable, prepaid cards to ‘wash’ otherwise impermissible funds into apparently clean contributions, possibly including money from foreign sources,” Steil wrote in his October 2023 letter to Wallace-Jones. “Federal law prohibits contributions from foreign nationals to federal, state, or local campaigns.”

“Allegations also suggest that malicious actors employ standard identity theft practices to send unlawful funds through ActBlue platform users, with the names of actual persons used to make contributions without their knowledge or consent,” the Administration Committee Chairman added.

Steil and Marco Rubio — then a Republican Florida senator — expressed concerns in 2023 that the platform did not require donors to submit a credit verification value (CVV), the security code on credit cards used to help prevent fraud. ActBlue has since changed its interface to require CVVs for donations via credit card, but users can still submit contributions on the platform using PayPal, Google Pay and Venmo after uploading CVV-less prepaid gift cards.

The Wisconsin Republican introduced the Secure Handling of Internet Electronic Donations (SHIELD) Act in September 2024 which would have required CVVs for online political donations and would have prevented the use of prepaid gift cards. The House passed the bill in December of that year via a voice vote — however, it did not receive a vote in the Senate.

At least seven senior ActBlue officials resigned in February 2025, The New York Times first reported the following month.

ActBlue, which is organized as a political action committee (PAC), is the primary fundraising platform used for Democratic candidates across the country, regardless of the office they are seeking.

Virginia Senate candidate Mark Moran had been using the platform while challenging Democratic Sen. Mark Warner in the party’s primary. However, less than an hour after leaving the party and switching to an independent run, Moran announced he had been kicked off ActBlue.

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