November 21, 2024
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Dark money” groups and shell companies are on track to steer more money from undisclosed sources to the 2023-2024 election than any prior cycle

In 2023 alone, shell companies and dark money groups injected over $162 million into political groups such as super PACs, surpassing the level of dark contributions seen at the same point in any prior election cycle, a new OpenSecrets analysis of Federal Election Commission data found.

OpenSecrets has tracked more than $2.8 billion in dark money spending & contributions reported to the FEC since the Supreme Court’s Citizens United v. FEC decision in 2010.

While federal campaign finance law requires political committees including super PACs to disclose donors to the FEC, the ultimate source of funding can be concealed behind contributions from shell companies or dark money groups, such as 501(c)(4) nonprofits that do not disclose their donors 

During the 2022 election, federal political committees reported taking in $616.8 million from such donors, more than any prior midterm cycle.

So far this election cycle, contributions from dark money groups and shell companies is outpacing all prior elections and may even surpass the roughly $660 million in contributions from unknown sources that flooded 2020 elections — a cycle that attracted over $1 billion in total dark money, counting political ad spending as well as contributions. 

But more dark money is pouring into federal elections that is not disclosed to the FEC.

During the entire 2022 election cycle, 501(c)(4) nonprofits that don’t disclose their donors reported less than $25 million in spending to the FEC — the lowest total since the Supreme Court’s 2010 Citizens United decision rolled back restrictions on corporate political speech and the SpeechNow.org v. FEC ruling paved the way for super PACs to spend unlimited sums on independent expenditures.

This has led to a rise in “gray money” spending by groups like super PACs that are required to disclose their donors but are funded — at least partially — by entities like dark money groups and shell companies where the ultimate source of funding is not disclosed.

Democrats benefiting more from dark money

Super PACs and other political committees supporting Democrats have reported about $85 million in political contributions from dark money groups and shell companies during the 2024 cycle to date, while political committees supporting Republicans have reported about $74 million.

The 2024 election cycle is on track to be the fourth consecutive cycle where Democrats benefit from more dark money than Republicans, though a lot can change during an election year.

This trend began during the 2018 midterm cycle when liberal dark money groups first outspent their conservative counterparts. That’s despite Democratic rhetoric decrying dark money and a series of failed efforts by some members of the party to crackdown on political contributions from undisclosed sources.

Liberal political committees reported about $318 million in political contributions from dark money groups and shell companies during the 2022 cycle while conservative political committees reported roughly $263 million.

Presidential race drives dark money contributions

Dark money groups registered as 501(c) nonprofits have collectively reported about $2.3 million in spending to the FEC during the 2024 election cycle. The bulk of that spending was reported by Defending Democracy Together, a dark money group that opposes former President Donald Trump in the presidential race. 

Defending Democracy Together poured another $2.5 million into contributions to super PACs. In December, the organization routed $2 million of that to Republican Accountability PAC, which shares leadership with the dark money group. The groups are part of a coalition that organized to fight against Trump, along with a super PAC that goes by Republican Voters Against Trump, which launched a $50 million campaign this week to fight the former president in the 2024 presidential race. 

Another $500,000 of the dark money group’s contributions went to a June 2023 contribution to Tell It Like It Is PAC, a super PAC run by allies of former New Jersey Gov. Chris Christie, who dropped out of the 2024 presidential race in January.

With the 2024 presidential election set to be another showdown between President Joe Biden and Trump, outside spending and dark money are likely to continue pouring in.

Americans for Prosperity Action, a hybrid PAC at the center of a network of conservative donors and activists led by billionaire Charles Koch, has reported more contributions from dark money groups than any other political committee at this point in the 2024 election cycle. 

As a hybrid PAC, also known as a Carey committee, AFP Action has the ability to operate both as a traditional PAC and a super PAC, as long as it maintains a separate bank account for contributions and another for independent expenditures.

AFP Action, which signaled its opposition to Trump in early 2023, endorsed Nikki Haley in November and spent nearly $50 million on the election before the former UN ambassador dropped out of the race. The super PAC reported receiving $25 million of that from Stand Together Chamber of Commerce, the flagship group at the center of the Koch political network.

Weeks before Haley dropped out, AFP Action halted its spending on the presidential race and said it will instead focus down the ballot on congressional races.

The League of Conservation Voters, a 501(c)(4) environmental advocacy group that does not disclose its funders, has also emerged as a top dark money contributor, steering more than $12.9 million to LCV Victory Fund, an associated super PAC.  

While LCV Victory Fund has spent less than $750,000 to date — mostly on the race to replace ousted Rep. George Santos (R-N.Y.) — the super PAC is historically a major spender and is building a war chest to spend big money again in 2024. 

During the 2022 midterms, LCV Victory Fund spent more than $33.3 million boosting Democrats and attacking Republicans in key swing states across the country, including Colorado, Arizona, Georgia, Pennsylvania, New Hampshire, Nevada and Wisconsin, according to independent expenditure reports.

Multiple groups boosting Biden in the presidential election are also among this cycle’s top brokers of dark money.

Future Forward USA Action, a 501(c)(4) nonprofit group that does not disclose its donors, has steered millions to an associated super PAC run by former Biden aides and has spent millions more on its own ads.

In addition to being run by the president’s former aides, Biden White House advisers have publicly signaled to donors that the president supports Future Forward’s efforts. 

Future Forward USA, the group’s hybrid PAC, has received over $8 million of the $25 million it raised from the closely-tied dark money group. While the super PAC has not reported any outside spending to the FEC as of March 11, Ad Impact has tracked more than $109 million in ad time reserved. 

Future Forward USA Action launched a multimillion-dollar ad blitz in 2023. But since its ads stop short of explicitly urging viewers to vote for Biden’s reelection, the spending is not legally required to be disclosed to the FEC even though the ads tout Biden’s record along with B-roll footage of the president.

Future Forward became the third-largest funder of advertising in the 2020 presidential general election, with the super PAC spending $126.4 million during the final months of the 2020 election. 

In January, the super PAC announced plans to reserve $250 million in advertising in battleground states, allocating $140 million to television and $110 million to digital ads. The ads are projected to start the day after the Democratic National Convention concludes in August, the New York Times reported.

The constellation of groups that have announced plans to support Biden also includes other super PACs funded in part by allied dark money groups.

In 2023, the American Bridge hybrid PAC announced it plans to spend $140 million on ads ahead of the 2024 election while Priorities USA planned to drop another $75 million. Despite their big spending plans, neither super PAC has broken seven figures in spending during the 2024 cycle and are still ramping up operations. 

Party groups steer dark money into 2024 elections

Groups affiliated with Democratic or Republican leadership in Congress have consistently ranked among the top-giving dark money groups each recent election cycle — and 2024 is no exception.

In 2023 alone, the four main groups affiliated with party leadership in the House and Senate steered more than $46.4 million to political committees such as super PACs that can spend unlimited sums on elections. 

Majority Forward, a 501(c)(4) nonprofit aligned with Senate Democratic leadership that does not disclose its donors,spent over $18.7 million into contributions to federal political committees in the first year of the 2024 election cycle. 

Senate Majority PAC, the main super PAC aligned with Senate Democrats, reported receiving about $16 million of Majority Forward’s contributions in 2023.

During the 2022 midterm cycle, Majority Forward contributed more money to federal political committees than any other dark money group, with its contributions nearing $76 million. 

Duty and Country, a super PAC aligned with congressional Democrats that has been active in recent elections, was funded in 2020 by Duty and Honor, a 501(c)(4) nonprofit dark money group funded by and affiliated with Majority Forward. IRS filings indicate that the dark money appendage has since shuttered. Majority Forward is now funding the super PAC directly. In 2023, Majority Forward was Duty and Country’s sole donor. 

Majority Forward is the sole donor funding Last Best Place PAC, a new super PAC that has spent on ads attacking former Navy SEAL and entrepreneur Tim Sheehy, who is running for the Senate seat held by Sen. Jon Tester (D-Mont.). 

While the super PAC’s advertising explicitly mentions Sheehy’s Senate campaign, it has yet to report any independent expenditures to the FEC. Instead, it reported all of its media spending as operating expenditures, lumping the spending on political ads together with salaries, office supplies and overhead costs — and resulting in the Campaign Legal Center filing an FEC complaint against Last Best Place PAC.

House Majority Forward, Majority Forward’s congressional counterpart aligned with Democratic U.S. House leadership, made another nearly $8.3 million in political contributions in 2023. All of those contributions went to House Majority PAC, the main super PAC aligned with House Democrats.

In addition to making political contributions to its closely-tied hybrid PAC, House Majority Forward has spent millions on ads and billboards targeting swing district House Republicans.

One Nation, a 501(c)(4) nonprofit aligned with Senate GOP leadership that poured more money from undisclosed sources into 2022 elections than any other group, made nearly $5.2 million into contributions in 2023. 

During the 2022 cycle, the Senate GOP-aligned dark money group gave $75 million to Senate Leadership Fund, a super PAC tied to retiring Senate Minority Leader Mitch McConnell (R-Ky.) that shares staff and resources with the dark money group. 

One Nation was also the biggest dark money contributor of the 2020 election cycle. 

American Action Network, a 501(c)(4) group aligned with House Republican leadership, dropped another $82.2 million into federal elections during the 2022 election cycle. The dark money group steered at least $30.7 million of that into TV and online ads boosting Republican candidates, according to AdImpact data provided to OpenSecrets.  

The 501(c)(4) group’s roughly $51.5 million in contributions largely went to the Congressional Leadership Fund, a hybrid PAC aligned with GOP House leadership that spent more than $227.3 million to boost Republicans in 2022 midterms.

American Action Network has also started spending on ads in battleground districts.

Open Secrets

Committees Researcher Andrew Mayersohn contributed to this report.