Voters have a right to know who is spending to influence their vote and their government. Federal campaign finance laws protect this right by requiring federal candidates and committees to disclose their contributors.
But these laws haven’t stopped some wealthy individuals and special interests from trying to conceal their political contributions. One mechanism is known as a “straw donation.”
In a straw donation, a donor makes political donations by directing its funds through another person or entity — often a shell company created for this purpose — which then contributes those funds to a political committee in its own name while concealing the identity of the true source of the donation.
The political committee reports only the intermediary entity as the contributor, and the true source of the funds remains hidden.
As wealthy special interests pump larger and larger sums into our elections, straw donor schemes — which keep voters in the dark about the true sources of political spending — are an increasingly common practice despite being explicitly prohibited by federal law.
Identifying Straw Donors and Seeking Accountability
Campaign Legal Center (CLC) exposes straw donation schemes by analyzing campaign finance data, investigating potential straw donations, and filing complaints with the Federal Election Commission (FEC), which is responsible for civil enforcement of federal campaign finance laws.
For example, in January 2025, CLC filed a complaint with the FEC against an obscure entity called “Building Our Future Today, LLC” (BOFT), asking the Commission to investigate an apparent straw donor scheme.
Apart from its political contributions, BOFT exists only on paper. There’s nothing in the public record — no storefront, website, social media profile, etc. — indicating it has conducted any business.
Yet somehow, BOFT was able to make over $2.5 million in political contributions to two different super PACs just two months after it was created in August 2024. CLC’s complaint alleges that BOFT was not the true source of these contributions.
Instead, it appears that BOFT was provided funds by one or more unknown persons seeking to conceal their identities by illegally funneling their contributions through the company instead of contributing in their own names.
The two super PACs receiving this windfall of political money, Badger Values and Progressive Century Project, were formed within weeks of BOFT, and they reported no other contributions from any source other than BOFT.
Both super PACs quickly spent BOFT’s millions on election ads and then faded into obscurity — a hallmark of a “pop-up” super PAC.
Straw donors and mysterious super PACs are often linked.
In another complaint filed with the FEC in January 2025, CLC alleged that a pop-up nonprofit called “Promoting American Values for Everyone, Inc” (PAVE) made $625,000 in straw donations to a super PAC called “Oakland Corps PAC” (OC PAC) in the final days of the 2024 election.
Both PAVE and OC PAC were formed just weeks before the election. Like many straw donors, PAVE has no public activities that could explain the source of its funding.
PAVE and OC PAC reportedly share an address — strongly suggesting, as CLC alleges in our complaint, that the same individual or group set up both PAVE and OC PAC to secretly spend over $625,000 to influence the 2024 election.
A New Trend in Straw Donor Schemes Emerges
While straw donations are a longstanding problem, BOFT and PAVE differ from one another. BOFT was incorporated as an ordinary corporation, but PAVE was registered as a nonprofit entity.
Because certain nonprofit entities are allowed to spend money on elections and do not have to disclose their donors, wealthy special interests have long used them to secretly spend money backing their preferred candidates.
In the 2024 election, these “dark money” groups poured hundreds of millions of dollars into election spending, leaving voters with no idea who was spending to influence their vote.
But nonprofits aren’t exempt from the law prohibiting straw donations. Like everyone else, nonprofits can’t legally be used as straw donors to funnel contributions from the true contributors to super PACs.
This pattern — as illustrated by PAVE and other recent straw donor complaints that CLC has filed — indicates how wealthy special interests are continually working on new ways to secretly influence elections.
CLC is always on the lookout for straw donors. When a contribution doesn’t add up, our team files a complaint to protect voters’ legal right to know who is behind money in politics.
Defending free and fair elections is a continual process that does not end after each election. To keep up with CLC’s complaints against alleged straw donors, check out our action page.