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Memo: Exposing ActBlue's Questionable Fundraising Practices and Efforts to Legislate Reform

Memo: Exposing ActBlue’s Questionable Fundraising Practices and Efforts to Legislate Reform

“The leadership of Wisconsin Faith and Freedom led the charge to shine light on the concerning practices going on at ActBlue.  Their early work highlighted many of the exact problems we are working to correct today.” Rep. Bryan Steil (WI-01)

Please see this table of contents to enable you to skip to the pieces of this document that are most helpful, or call/text 404.606.3163 or email jpudner@wisconsinffc.com with any questions.

Table of Contents

    1. Introduction
    2. Preamble – Other Priorities Besides ActBlue
      • a. Allowing Wisconsinites to Vote on Whether or Not to Allow Late-Term Abortions
      • b. Two Bills to Protect Women’s Sports from Men Claiming to Be Women; Recognizing Only 2 Genders
      • c. Enforcing Immigration Laws
      • d. Protecting Voter ID Laws
      • e. Not Allowing Public Union Lobbyists to Use Taxpayer Money to Lobby for More Taxpayer Money
      • f. Support the Taxpayer Protection Pledge
      • g. Support School Choice
    3. Background: John Pudner’s Initial White Paper on ActBlue
    4. HR4177 Legislation & Congressional Efforts
    5. Focus on State Legislation (2016-2019)
      • New Mexico Victory
      • Texas Legislative Push
    6. Groundbreaking Research (2020)
      • Documenting ActBlue’s Abuses
      • Trump’s Retweet and Sanders’ Attack
    7. Congressional Investigation into ActBlue (2025)
    8. Key Articles and Resources
    9. Future Efforts and Hopes for Reform
    10. Summary of White Paper Findings and Reform Proposals
  • Please Assist in Our Efforts

1. Introduction

This document focuses on the leadership of Wisconsin Faith & Freedom Coalition’s President, John Pudner, in efforts to ban ActBlue’s processing of billions of dollars in unverified contributions. ActBlue will be a centerpiece of our efforts moving forward, but for context, we begin with a preamble of other key priorities from our first year of operation and the potential additional areas of focus in the future.

2. Preamble – Other Priorities Besides ActBlue

In our first year of operation in 2024, the Wisconsin Faith & Freedom Coalition focused on several important issues. These issues are vital to our broader mission, and we remain committed to addressing them as we continue to advocate for conservative values in Wisconsin. Below is an overview of the specific priorities we worked on during the 2024 session.

a. Allowing Wisconsinites to Vote on Whether or Not to Allow Late-Term Abortions

In 2024, we focused on Assembly Bill 975, which would allow voters to decide whether or not to permit late-term abortions. This bill included strong testimony from our president, John Pudner, in the Assembly, which passed the measure.
 Read or listen to John Pudner’s pro-life testimony here

b. Two Bills to Protect Women’s Sports from Men Claiming to Be Women; Recognizing Only 2 Genders

We supported the following two bills aimed at protecting women’s sports and ensuring fairness:

  • Assembly Bill 377: This bill amends the statutes to designate sports based on the biological sex of the participants.
  • Assembly Bill 378: This bill addresses similar protections for the University of Wisconsin and technical college sports. We have also worked on additional issues surrounding restroom and prison access, as well as the prevention of sex-change operations on minors.

c. Enforcing Immigration Laws

We support strengthening and enforcing immigration laws to maintain national security and the integrity of our legal immigration system.

d. Protecting Voter ID Laws

We are committed to ensuring that voter ID laws remain in place, helping to safeguard election integrity.

e. Not Allowing Public Union Lobbyists to Use Taxpayer Money to Lobby for More Taxpayer Money

We oppose the practice of public union lobbyists using taxpayer dollars to lobby for more public funds.

f. Support the Taxpayer Protection Pledge

We are proud to support the Taxpayer Protection Pledge, a commitment to limit government spending. We appreciate Grover Norquist and Americans for Tax Reform for featuring John Pudner as a speaker at national gatherings.

g. Support School Choice

While we strongly support school choice, we are grateful that the state of Wisconsin already has the best advocacy organization in the country (https://schoolchoicewiaction.org/) in this area. We continue to lend our support where needed. 

  1. Background: John Pudner’s Initial White Paper on ActBlue (September 2015)

Click here for links to dozens of national articles on our efforts to call attention to and stop ActBlue’s movement of billions of dollars in unverified contributions to left-wing causes.

In September 2015, John Pudner published a comprehensive white paper outlining ActBlue’s vulnerabilities, particularly its lack of safeguards for verifying campaign contributions. Pudner’s work highlighted the risks of illegal foreign donations, money laundering, and fraud facilitated by the platform’s unverified donation process. The white paper, titled Closing Credit Card Contribution Loopholes, was delivered in person to every Congressional and Senate office as part of a three-day blitz by Pudner and his team, which included Diane Cullo, Beatrice Torralbo, and lobbyist Chuck Cunningham. The white paper and the resulting advocacy formed the foundation for a sustained, multi-year effort to regulate ActBlue’s fundraising practices.

You can access the full white paper here.

  1. HR4177 Legislation & Congressional Efforts (December 2015)

In December 2015, Pudner’s white paper was submitted for drafting by Cong. Paul Gosar, which led to the introduction of HR4177, the first legislative attempt to curb ActBlue’s unverified fundraising practices. Gosar agreed to sponsor the bill, with Pudner securing Congressman Dave Brat, who Pudner recruited and launched a campaign for the previous year to defeat Majority Leader Eric Cantor, as the first co-sponsor. Chuck Cunningham, working as a lobbyist, played a key role in securing 83 co-sponsors for HR4177. This bill aimed to address the issue of unverified donations by requiring stronger safeguards and increasing accountability in the donation process. A companion bill was also introduced in the Senate.

Links:

  1. Focus on State Legislation (2016-2019)

New Mexico Victory
 Between 2016 and 2019, Pudner’s efforts shifted to securing state-level reform. In New Mexico, his organization at the Take Back Our Republic Action (www.takebackaction.org) succeeded in passing regulations that addressed ActBlue’s unverified donations, though it was a small victory. This served as a demonstration that state action could be effective in curbing the platform’s problematic fundraising practices.

Texas Legislative Push
 The most significant state-level success came in Texas. Pudner’s team, led by State Director Chad Wilbanks, toured the Capitol to call attention to the practice in legislative meetings, and the wheels were set in place that eventually would require credit card platforms to use Full Match AVS (Address Verification Service) to help prevent money laundering and other fraudulent activities. An op-ed in the Dallas Morning News by Pudner helped raise awareness of the issue. Despite setbacks, these efforts paved the way for a broader movement toward stronger regulations at the state level.

Links:

  1. Groundbreaking Research (2020)

In a 2020 exclusive to Fox News, Pudner and his team published research that revealed major issues with ActBlue’s operations, including evidence that billions of dollars flowing through ActBlue to left-wing causes were supposedly from unemployed individuals. These findings were shared through various media outlets and publications after the Fox News exclusive was retweeted by President Donald Trump. Pudner’s work was met with liberal backlash, particularly from Senator Bernie Sanders, but it succeeded in bringing further national attention to ActBlue’s practices.

Key publications included:

  1. Congressional Investigation into ActBlue (2025)

In 2025, Representative Mike Steil spearheaded a Congressional investigation into ActBlue, leading to subpoenas for access to ActBlue’s suspicious activity reports. This investigation resulted in the resignation of several ActBlue executives and further fueled the ongoing debate over the platform’s questionable practices. This investigation was a key milestone in the larger effort to regulate ActBlue and its fundraising processes.

Key news and reports:

  1. Key Articles and Resources
  1. Hopes for Reform, Cong. Steil’s Leadership & Praise for WIFFC

With the conclusion of his work with Take Back Our Republic and Take Back Our Republic Action, John Pudner now continues the fight for transparency and accountability in political fundraising through his new organization, Wisconsin Faith and Freedom Coalition. The ongoing goal is to secure both state-level reforms, such as the Full Match AVS system in Texas, and push for federal legislation that addresses the loopholes in ActBlue’s operations. The mission remains clear: to close the loopholes that allow for unverified donations and foreign influence in U.S. elections.

After Congressman Steil’s investigation of ActBlue resulting in stories like this around the world, “ActBlue, the Democratic Fundraising giant that has helped raise over $16 billion … is in turmoil as seven senior executives have abruptly resigned … raising serious concerns about the groups stability …”  (Times of India, March 2025), Steil issued the following statement about the work Wisconsin Faith and Freedom President John Pudner did since he and Peter Schweizer first uncovered their process a decade ago:

“The leadership of Wisconsin Faith and Freedom led the charge to shine light on the concerning practices going on at ActBlue.  Their early work highlighted many of the exact problems we are working to correct today.” Rep. Bryan Steil (WI-01)

  1. Summary of White Paper Findings and Reform Proposals

The white paper, Closing Credit Card Contribution Loopholes, published by Pudner 10 years ago was ahead of its time, identifying key weaknesses in the current system of campaign finance regulation related to credit card contributions. The most significant findings are:

  1. Loopholes in Credit Card Donation Systems: Many campaigns, including those using ActBlue, failed to implement basic fraud-prevention mechanisms like the CVV code and AVS, which left the system vulnerable to foreign contributions and fraudulent donations.
  2. Robo-Donations and Anonymous Contributions: Without proper verification, campaigns could accept “robo-donations” or recurring small contributions that evade legal limits and reporting requirements.
  3. Foreign Contributions: The lack of verification systems makes it easy for foreign entities to donate to U.S. campaigns, violating federal laws prohibiting foreign contributions.
  4. Reform Proposals:
    • Directing the Federal Election Commission (FEC) to close the loophole and enforce regulations.
    • Amending laws regulating financial services to ensure that credit card platforms meet minimum standards for fraud prevention.
    • Encouraging political parties to implement internal policies that require compliance with fraud protection standards.

The white paper proposes legislative action at both the state and federal levels, as well as steps for political parties to voluntarily adopt best practices to protect the integrity of U.S. elections.

  1. Please Assist in Our Efforts

The left has long outflanked the right in one specific area – when a political campaign ends the Soros Machines and other left-wing mega donors continue to fund the organizations they need to build BETWEEN organizations. We thank all the organizations and individuals who backed our efforts to get out 402,000 candidate comparisons credited by one Congressman for delivering Wisconsin to Trump in the 2024 election, and another 200,000 for the 2025 Supreme Court race.

Please let us know if you can help with our grassroots efforts, to visit the Capitol or help with legislation, to host events in your county, or to make a tax deductible contribution to the “Wisconsin Faith and Freedom Coalition” by going to https://wisconsinffc.com/donate/ for instructions on donating by mailing a check, going on line for a credit card contribution or wiring instructions.

If you are reading this document in printed form, you can scan below to access an electronic version to access links. 

Wisconsin Faith and Freedom Coalition

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    1433 N. Water Street, Suite 400
    Milwaukee, WI 53202

  • 414.207.4382
  • jpudner@wisconsinffc.com

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Let us know if you want a deep dive on winning over lawmakers after the campaign ends, how to run an effective church outreach push, or what’s working with third-generation canvassers in swing counties across America—or ask us to go deeper into one of the past issues covered in any of the dozens of headlines from past media appearances and speeches written about at wisconsinffc.com.

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