Assembly Passage 55–42!
Wisconsin Becomes First State to Advance Real Safeguards Against Foreign-Linked Online Donations – and no we did not break Capitol rules by taking this picture from the Assembly Gallery – as legislators took the photo and sent it to us after the vote.
On Wednesday, the Wisconsin Assembly took a historic step, passing AB 385 by a 55–42 vote, making Wisconsin the first legislative body in the nation to advance model legislation that can actually stop foreign-sourced political contributions disguised within billions of dollars of unverified credit-card and gift-card transactions.
For years, we have documented this issue at www.wisconsinffc.com, including how unverified online contributions created an enormous loophole that allowed foreign funds to blend invisibly into U.S. political donations. Yesterday’s vote marks the first time any governing body has responded with a workable solution that closes the loophole at the banking and payment-processing level, where it must be fixed.
A Business & Industry Solution — Not a Political Loophole Factory
Many well-meaning reform efforts over the past decade failed because they tried to write political rules for a technical problem. That approach only created more loopholes.
Wisconsin succeeded where others did not because the solution in AB 385 focuses squarely on the mechanics of online financial transactions — making sure that payment institutions cannot process donations that skip basic verification steps.
This is the same core concept that led to our groundbreaking 2020 research on “smurfs,” which President Trump shared nationally, exposing how repeated unverified transactions could be pushed through automated systems. That research, and our earlier 2015 white paper on credit-card verification standards, helped lay the groundwork for this moment.
Constructive Questions Improved the Final Bill
We remain extremely grateful to the bill sponsors and staff who have worked on this issue for years. We also appreciate the legislators — from both parties — who raised constructive questions in committee hearings. Their input led to clarifying adjustments in the final substitute amendment to AB 385, without weakening the core protections.
Unlike earlier hearings, the Assembly floor debate this week reflected a recognition that the final approach is targeted, workable, and free of unintended consequences.
The Technical Expertise Behind This Victory
In the final days before the vote, the person I relied on more than anyone was Doug Braun, one of the pioneers of modern online banking.
Doug served as Chief Technology Officer for InteliData, the company that built some of the first large-scale online-banking platforms used by major U.S. banks. I had the privilege of working directly with him in the 1990s — including writing the operations manuals for the nation’s first commercial home-banking server implementation, which BB&T later called “the best in the home-banking industry.”
Doug helped our team validate that the final language in AB 385 would:
Prevent the processing of unverified credit-card contributions
Avoid accidental blocking of legitimate donors
Be fully feasible for banks and processors to implement
Close the exact loopholes exploited for years through unverified small-dollar transactions
Having someone who actually built the systems that run online financial transactions was indispensable. His expertise allowed us to answer every technical challenge raised during debate with absolute clarity.
Why This Bill Passed — and Why Wisconsin Leads the Nation
AB 385 passed with bipartisan support — narrow, but real. We believe legislators responded to three things:
The problem is real, documented, and urgent
Our team spent years exposing how unverified online contributions allowed foreign funds to pass through U.S. campaigns. This concern is not theoretical.The solution is industry-based, not political
Banks and processors already use verification systems everywhere else in the economy. Elections should not be the only place where those protections are disabled.The legislation is clean and practical
It protects campaigns, protects donors, and closes the loophole without burdening honest political activity.
Special Thanks
We particularly thank Rep. Dave Murphy, the lead Assembly sponsor, whose testimony was instrumental in clearing up misconceptions and securing passage. His testimony is available here:
https://docs.legis.wisconsin.
AB 385 now moves to the Wisconsin Senate, where we look forward to continuing to work with lawmakers, staff, and technical experts to ensure Wisconsin becomes the first state in America to fully close the online-donation verification loophole.
For background on our earliest work on this issue, you can read the original 2015 white paper here:
https://docs.google.com/
Wisconsin can — and should — lead the country in election integrity through real safeguards that prevent foreign interference, strengthen confidence, and protect lawful political participation.
