Straw Donor Scheme Funnels Over $2.5 Million to Six Federal Committees

The face from a dollar bill at the bottom of a tunnel of dollar bills stacked on top of each other

Voters have a right to know who is spending money to influence their vote and our government. Transparency is necessary to understand who is supporting which candidates and why, so that voters can make informed choices at the ballot box. That’s why federal law requires candidates and committees to disclose their contributors.  

One way that wealthy special interests attempt to keep their political spending secret is by using shell companies or other intermediary entities or persons, known as “straw donors,” to conceal the true source of their political contributions.  

In a typical straw donor scheme, the true contributors transfer money to a straw donor — usually an obscure LLC or corporate entity that they control — and then direct the straw donor to make a political contribution in its name, concealing the true contributors’ identities.

Straw donor schemes have long been illegal, but they have become increasingly common since the Supreme Court’s 2010 decision in Citizens United v. FEC touched off a torrent of “independent” election spending, much of it from corporations and wealthy individuals using their resources to drown out the voices of everyday Americans.  

As of January 2024, “independent” election spending this election cycle has already topped $318 million — on pace to exceed any previous election — and a record amount of that spending is “dark” money, i.e., spending where the source of the money is obscured.

Campaign Legal Center (CLC) recently identified an obscure entity called “Ardleigh Impact Corporation” that appears to be a straw donor, which is why we filed a complaint with the Federal Election Commission (FEC).

Our complaint alleges that whoever is behind Ardleigh violated federal law by using it as a shell company to conceal the true contributors. It is urgent that the FEC investigate these allegations to fulfill voters’ right to know who is attempting to influence their vote.

Ardleigh was registered in Delaware at the end of October 2023 and began making federal political contributions in February 2024. So far, the corporation has purported to contribute $2,575,000 to six different federal committees.

In the months between its formation and political donations, Ardleigh does not appear to have conducted any commercial activity from which it could have generated sufficient funds to contribute $2.5 million.

The corporation’s reported address is a residential property linked to a federal super PAC, and it has no website or social media presence, nor is there record of Ardleigh in any business database or chamber of commerce.  

These circumstances strongly suggest that Ardleigh was created and funded for the purpose of funneling millions of dollars into federal elections while concealing the true donor’s identity, a blatant violation of the law.

In recent years, the FEC has, on occasion, investigated apparent straw donor schemes and imposed penalties for those violating the law. For example, in October 2022, the FEC fined the operator of a straw donor scheme $25,000 for contributing $75,000 to a super PAC through an LLC.

The FEC must investigate Ardleigh and enforce the law by imposing appropriate penalties. Holding those that violate the law accountable will help deter future straw donor schemes.  

Having complete and accurate information about who is spending money to influence their decisions at the ballot box is crucial for voters seeking to meaningfully participate in the democratic process.

Sophia is a Senior Researcher/Investigator on CLC's Campaign Finance/Ethics team.