A presidential memorandum directing the Attorney General to investigate ActBlue

Editor's note: the president's memorandum directs an investigation naming the main Democratic fundraising platform, but no court or official finding establishes it as unlawful or retaliatory.

Federal law flatly prohibits contributions made in another person's name and contributions by foreign nationals. In April 2025 the chairs of three Republican-led House committees released a report on ActBlue, the platform that processes the great majority of small-dollar Democratic donations. The report found that the platform had detected at least twenty-two significant fraud campaigns in recent years, nearly half with a foreign nexus, and that over a thirty-day window in the 2024 cycle it recorded 237 donations from foreign IP addresses using prepaid cards. It said staff had been trained to look for reasons to accept contributions. ActBlue has cooperated with the congressional inquiries and denies wrongdoing; it has since stopped accepting gift cards and now requires a card verification value.

On April 24, 2025 the president signed a memorandum titled Investigation into Unlawful Straw Donor and Foreign Contributions in American Elections. It directs the Attorney General, in consultation with the Secretary of the Treasury, to use all lawful authority to investigate the unlawful use of online fundraising platforms for straw, dummy, or foreign contributions, and to take all appropriate actions to enforce the law. It names ActBlue. It directs the Attorney General to report the results of the investigation to the president, through the Counsel to the President, within 180 days. The accompanying fact sheet names ActBlue directly and describes its standards as lax.

The countervailing facts are on the face of the document. The conduct described is illegal if it occurred, the House findings are specific, and several state attorneys general had opened their own inquiries. ActBlue is a partisan institution rather than an individual, and the memorandum creates no legal right and compels no charge. What the record documents is narrower and does not depend on ActBlue's conduct: a president directing the Attorney General, in writing, to investigate a named organization that is the financial infrastructure of the opposing party, and to report the results back to him personally within a set deadline. No charge has been brought. This record is Tier B. The related directive instructing federal agencies to investigate organizations by ideological indicia is documented at WLE-15.