Return to News Apr 24, 2025

TO: Interested Parties

FROM: Ezra Reese, Jacquelyn Lopez, and Avery Woodard, Elias Law Group LLP

RE: New Presidential Memorandum Directs Investigation into Online Political Fundraising Platforms

This afternoon, President Trump signed a presidential memorandum (the “Memo”), directing the Attorney General of the United States to investigate allegations of unlawful contributions made via online fundraising platforms. The purported goal of the Memo is to crack down on illegal “straw donor” and foreign contributions in American elections. In reality, the Memo represents a political attack against a prominent Democratic fundraising platform. The Memo and accompanying fact sheet focus significant attention on ActBlue and do not mention any other platform by name.

The Memo directs the Attorney General to investigate allegations of straw contributions (i.e., contributions made in Donor A’s name, but using Donor B’s funds) and contributions by foreign nationals, made via online fundraising platforms. The referenced allegations seem to stem from a recent report issued by the U.S. House Committee on Administration, Committee on the Judiciary, and Committee on Oversight and Government Reform, which found 22 instances of fraud on ActBlue’s platform in 2024. Relying on this report and press, the Memo asserts that “online fundraising platforms have been willing participants in schemes to launder excessive and prohibited contributions to political candidates and committees ” and that “malign actors are seeking to evade Federal source and amount limitations on political contributions by breaking down large contributions from one source into many smaller contributions…potentially without the consent or even knowledge of the putative contributors.”

This President’s demand that the Attorney General investigate platforms that facilitate the fundraising efforts of his political opponents is merely the latest in a stream of actions that violate the post-Watergate norm that presidents are not to interfere with Department of Justice actions.

If you have any questions about the Memo, or about the Trump Administration’s efforts to investigate or harm its political adversaries, please do not hesitate to reach out to your counsel at Elias Law Group.

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