FRAUD ON ACTBLUE: HOW THE DEMOCRATS’ TOP FUNDRAISING PLATFORM OPENS THE DOOR FOR ILLEGAL ELECTION CONTRIBUTIONS

Source: Interim Staff Report of the Committee on House Administration, Committee on the Judiciary, and Committee on Oversight and Government Reform U.S. House of Representatives April 2, 2025

1 EXECUTIVE SUMMARY The Committee on House Administration, the Committee on the Judiciary, and the Committee on Oversight and Government Reform are charged with ensuring the integrity of American elections.1 To that end, the Committees are examining allegations that ActBlue, a leading political fundraising organization, allowed bad actors, including foreign actors, to exploit its online platform to make fraudulent political donations.2 This interim staff report details the Committees’ troublesome preliminary findings. Internal documents produced to the Committees by ActBlue and its fraud-prevention contractor, Sift, demonstrate a lack of commitment to stopping fraud and paint a picture of complacency on ActBlue’s fraud-prevention team. Put simply, the documents reflect a fundamentally unserious approach to fraud prevention at ActBlue—one that has left the door open for large-scale fraud campaigns on Democrats’ top fundraising platform. In particular, the Committees’ investigation has uncovered evidence that ActBlue made policy changes in 2024 that resulted in more fraudulent donations on the platform. Twice—once in April and once in September—ActBlue changed its fraud-prevention standards to make them “more lenient.”3 ActBlue internally assessed that the April change alone led to between 14 and 28 additional fraudulent contributions each month.4 Internal documents also confirm that before implementing anti-fraud measures, including a requirement that users enter card verification values (CVVs) at the time of donation, ActBlue tested whether the new measures would hurt Democrat fundraising.5 Then, once ActBlue implemented anti-fraud measures, it attempted to hide the changes so that they did not spark discussions of fraud on the platform.6 Internal documents also show that ActBlue staff and executives fail to take the threat of fraud seriously. ActBlue employees regularly demonstrated an unfounded belief that bad actors were not seeking to fraudulently contribute to Democrat campaigns and causes.7

For example, ActBlue’s training guide for new fraud-prevention employees instructed them to “look for 1 Rules of the House of Representatives R. X (K) Committee on House Administration, (L) Committee on the Judiciary, (N) Committee on Oversight and Government Reform (2025). 2 See Letter from Rep. Bryan Steil, Chairman, Comm. on H. Admin., to Ms. Regina Wallace-Jones, Chief Executive Officer, ActBlue (Oct. 28, 2024); Letter from Rep. Jim Jordan, Chairman, H. Comm. on the Judiciary, to Ms. Regina Wallace-Jones, Chief Executive Officer, ActBlue (Dec. 9, 2024); Letter from Rep. Bryan Steil, Chairman, Comm. on H. Admin., Rep. James Comer, Chairman, H. Comm. on Oversight and Gov’t Reform, & Rep. Nick Langworthy, to Hon. Scott Bessent, Sec’y, U.S. Dep’t of Treasury (Mar. 10, 2025); Letter from Rep. Bryan Steil, Chairman, Comm. on H. Admin., Rep. Jim Jordan, Chairman, H. Comm. on the Judiciary, & Rep. James Comer, Chairman, H. Comm. on Oversight and Gov’t Reform, to Ms. Regina Wallace-Jones, Chief Executive Officer, ActBlue (Apr. 2, 2025). 3 ActBlue memorandum, Summary of changes made to Sift rules since 2023; see Ex. 1; ActBlue memorandum, Sift – Rule Change Proposal; see Ex. 2; see also ActBlue memorandum, 2024 Q2 – Sift Rule Change Proposal; Ex. 3; ActBlue memorandum, Sift – RiskWatch (Percentile Scoring) Proposal; Ex. 4. 4 ActBlue memorandum, Summary of changes made to Sift rules since 2023; see Ex. 1. 5 ActBlue product brief, Broader CVV Support Product Brief & Development Checklist; see Ex. 6; see also Email from ActBlue Product Manager to ActBlue Staff (Jan. 2, 2024); Ex. 7; ActBlue memorandum, Capture CVV AB Test – Q4 2023; Ex. 8. 6 ActBlue memorandum, CVV Rollout Communications Plan; see Ex. 9; ActBlue customer service inquiry (Sept. 11, 2024); see Ex. 10; ActBlue customer service inquiry (Oct. 25, 2024); see Ex. 11. 7 See ActBlue memorandum, Summary of changes made to Sift rules since 2023;

Ex. 1; ActBlue memorandum, 2024 Q2 – Sift Rule Change Proposal; Ex. 3. 2 reasons to accept contributions,” rather than err on the side of flagging a suspicious donation. 8 ActBlue also subordinated its efforts to prevent fraud to its diversity, equity, and inclusion (DEI) goals. In 2024, ActBlue’s top fraud-prevention specialist told supervisors that he intended to “focus on DEI work[,]” even as he listed his top goal as “not allowing more than 10 [percent] additional missed fraud.”9

Rather than seeking to reduce or eliminate fraud on the platform, ActBlue’s chief fraud-prevention official was willing to accept 10 percent more fraud while he focused on DEI. These attitudes persisted at ActBlue despite a pattern of fraudulent donations on the platform. In recent years, according to internal documents, ActBlue has detected at least 22 significant fraud campaigns, including patterns of fraudulent donations to Representative Steven Horsford (D-NV), Representative Kevin Mullin (D-CA), Governor Laura Kelly (D-KS), and the Democratic National Committee (DNC). 10 Nine of these 22 fraud campaigns had a foreign nexus, and in three cases, candidates resisted ActBlue’s request that they return suspected fraudulent donations. 11 Internal documents also indicate that there have been instances in which bad actors have fraudulently taken control of user accounts, giving them the ability to make straw donations appearing to be from regular donors.12 ActBlue has even seen brazen instances of fraud in which multiple people have made donations using the same credit card information, and has internally acknowledged multiple incidents in which fraudulent donations evaded ActBlue’s automatic fraud review processes.13 ActBlue acknowledges that serious gaps in its fraud-prevention systems remain. Internal communications explain that “if someone could coordinate a big attack where each individual donation fell below the [fraud review] threshold, they would go through.”14 For some donations, ActBlue’s fraud-prevention controls do not even apply. Transactions made using PayPal are not subject to ActBlue’s standard fraud-prevention process through Sift, 15 and it is unclear whether ActBlue collects card verification values (CVVs) for the first donation in a series of recurring contributions—which constitute almost half of ActBlue’s donations.16 Altogether, ActBlue’s internal documents and communications paint a damning picture: despite repeated instances of fraudulent donations to Democrat campaigns and causes from domestic and foreign sources, ActBlue is not demonstrating a serious effort to deter fraud on its 8 ActBlue meeting notes,

Things to go over with associates about how we can be better about catching fraud; see Ex. 12. 9 [ActBlue Fraud Specialist] 2024 Goals; see Ex. 13 (emphasis added). 10 ActBlue memorandum, Known Instances of Fraud [Associates]; see Ex. 14; ActBlue memorandum, Known Instances of Fraud (Dec. 1, 2024); see Ex. 51. 11 Id. 12 ActBlue memorandum, Proposal for Solution to ActBlue Express Profiled Compromised During a Fraud Attack; see Ex. 19; see also ActBlue memorandum, Proposal for ActBlue Express Profile Recovery for Compromised Donors; Ex. 20. 13 ActBlue memorandum, Boeing VP Fraud Situation; see Ex. 15; ActBlue memorandum, Sift Rule Proposal – Same Payment Fingerprint; see Ex. 21. ActBlue meeting notes, [Fraud Specialist] : [Donor Support Manager] Work Time (May 17, 2022); see Ex. 16; Email from ActBlue Fraud Specialist to Sift personnel (July 18, 2024); see Ex. 17 14 ActBlue memorandum, 2024 Q2 – Sift Rule Change Proposal; see Ex. 3. 15 ActBlue memorandum, Fraud Prevention FAQ; see Ex. 18. 16 ActBlue memorandum, CVV Rollout Communications Plan; see Ex. 9; Sarah Potter, The power of recurring contributions, ACTBLUE (Sept. 16, 2019). 3 platform.

At best, ActBlue’s conduct displays a profound disrespect for the principle that only Americans should decide American elections. At worst, it may violate the Federal Election Campaign Act of 1971 (FECA), which states that persons who “knowingly accept a contribution made by one person in the name of another person” may face criminal liability.17 The Committees are deeply committed to protecting the integrity of American elections, and will continue investigating to inform potential legislative reforms to improve and strengthen our democracy. This oversight work is necessary and important to ensure that American elections are free, fair, and decided by Americans alone.