Dominic Rapini, a cybersecurity professional and 2022 Republican candidate for Connecticut’s secretary of the state, has been investigating straw donors—individuals who pose as a second-party and fraudulently make a donation in their name—and has identified $2 million in donations through ActBlue made in the name of 18 different Connecticut residents, most of whom are elderly or retired.

Rapini believes all of them are straw donors, and five have signed affidavits saying Federal Election Commission (FEC) records of their donation history do not reflect donations they have made.

The issue has recently come to the forefront of national politics, with a number of Republican-led states investigating apparently fraudulent donations. Congress and Donald Trump’s administration have also taken notice of the issue.

But attorney general William Tong has yet to take action on the issue, and his office is refusing to answer questions about whether they will investigate ActBlue’s apparent straw donor problem.

The giving patterns Rapini flagged are unusual because they involve a high number of donations, occurring with unusual frequency. According to broader FEC records, they are unusual for many ActBlue donors. It’s also unusual, more generally, because the average American does not contribute to political campaigns.

According to data from LendingTree, only 26 percent of Americans planned to donate to a political campaign in 2024, a ten percent decrease from the previous presidential cycle. In 2024, 55 percent of Americans had no plans to donate to a political campaign. Roughly two-thirds of Americans have never donated to a campaign.

Demographics play a factor in an individual’s likelihood of contributing. Generally, men are more likely than women to donate, Democrats are more likely to donate than Republicans and Republicans are more likely to donate than independents.

Income also plays a role. In 2024, 37 percent of individuals who made more than $100,000 annually said they were likely to make a political donation, while only 17% of those who made less than $30,000 said the same thing. Among the 55 percent of people who told LendingTree they did not plan to donate during the 2024 election, half said they couldn’t afford to contribute.

For those Americans who do donate to campaigns, small-dollar donations are the norm.

According to Open Secrets, only 1.05 percent of the general U.S. population contributed over $200 to federal candidates and PACs during the 2024 election cycle.

Only 131,042 individuals in America gave the maximum amount to candidates in the same cycle. Only 365,411 individuals gave that amount or more to candidates, PACs, and other groups in 2024.

While small dollar donations are more common, many of them are made to PACs and party committees rather than directly to candidates.

According to USAFacts’ analysis of FEC data, as of August 2024, over 75 percent of spending in the 2024 election cycle came from PACs and party committees, with donations passing through ActBlue and WinRed accounting for the largest contributions to election fundraising. Individual candidates collected about $2 billion between January 2023 and April 2024, while PACs raised $5.6 billion, and party committees raised $929.9 million.

ActBlue alone had raised more than $1.1 billion by August 2024, outpacing WinRed’s $623.1 million by nearly 80 percent. Since 2014, ActBlue’s fundraising has outpaced all other fundraising PACs in every election cycle.

In May 2024, ActBlue was the only PAC or party committee to raise over $1 billion.

In Connecticut, political contributions, particularly to Democrats, are above average.

According to Open Secrets, the total number of itemized contributions that came from Connecticut donors during the 2024 election cycle, ranked 18th in the nation. Total itemized contributions equaled roughly $155.6 million. Roughly $71 million went to Democrats. That amount is ranked the 15th highest in the nation. By contrast, roughly $34 million went to Republicans, ranked 27th highest in the nation.

Individual donations from Connecticut residents were high during the 2024 election cycle. For donors who gave $200 or more, Connecticut ranked 16th in the nation. It ranked 19th for PAC donations and 14th for soft money, which goes to political parties rather than candidates.

There are anomalies in donation amounts and frequency in FEC filings for ActBlue data, even compared to the already unique group of individuals who make recurring political donations.

In Connecticut, residents can use ActBlue to contribute to federal campaigns, either for Congressional or presidential candidates, to PACs, and to other interest groups. They cannot donate to state and local candidates because of conflicts between state law and the way ActBlue operates, though some legislators have pushed for a change.

Inside Investigator reviewed Federal Election Commission (FEC) filings that show donations made through ActBlue by donors from Connecticut in 2024 and identified several anomalies in the data. These are similar to the anomalies that Rapini flagged.

Among the individuals whose donor profiles Rapini flagged are Barbara Schmerzler, a retired real estate broker who is in her 80s, and Clifford Slayman, a retired Yale professor in his 80s.

Between them, FEC records show they’ve donated over $250,000 to ActBlue since its beginnings. Rapini identified over $110,000 in total giving that Schmerzler and Slayman have supposedly donated to various campaigns and political action committees (PACs). The majority of both Schmerzler’s and Slayman’s donations were routed through ActBlue.

When Schmerzler signed an affidavit in May 2023, FEC data showed 2,5491 donations totaling $41,000 had been made in her name. Schmerzler attested that the frequency of donations and the amount of money donated did not reflect donations she had made.

When Slayman signed an affidavit in April 2023, FEC data showed 7,539 donations totaling $213,163 had been made in his name. Slayman also attested that the frequency of donations and the amount of money donated did not reflect his donations.

Inside Investigator analyzed donations both Schmerzler and Slayman, according to FEC data, made to ActBlue over time. Schlerzer’s donor data shows $13,652.39 in giving, with the majority occurring between 2015 and 2021 and additional donations in 2024.

Rapini’s analysis of the 18 donors he identified as likely being straw donors noted that the frequency of donations ramped up over time, with the largest increase coming around the 2022 election cycle.

That trend is also reflected in Schmerzler’s ActBlue donations.

Between 2015 and 2019, Schmerzler’s recorded donations ranged from 6 to 66 per year. In 2020, the FEC recorded 276 donations. In 2021, that number rose to 1,523—an average of over 4 donations per day. Given that roughly 1 percent of the population donates more than $200 to campaigns and PACs per year, that number of donations is a red flag. Schmerzler’s recorded ActBlue donations more than doubled between 2020 and 2021. In 2020, she is recorded as having donated $3,230.60 through ActBlue. The next year, that number rose to $7,352.09.

The majority of Schmerzler’s recorded donations are also small, in most years averaging no more than $20. In 2021, when she is recorded as having donated over $7,000, her average donation was $4.83. Most frequently, her donations in 2024 totaled $5.

On several dates, Schmerzler is recorded as donating over 30 times a day.

But there are also numerous donations that look almost like microtransactions, totaling thirty or sixty cents.

Another potential tell that something is amiss is in how Schmerzler’s occupation and employment information is reported. Schmerzler, a retired real estate broker, has no significant history of political giving to candidates in Connecticut. The only donation to her name in the State Elections and Enforcement Commission (SEEC) database is a $700 donation to a PAC for realtors made in 2008.

Her employer is listed as US Homefinders, Inc. In FEC filings, Schmerzler’s occupation is listed as a realtor, but her employer is listed as ‘self,’ without any specific details. For donations made in Schmerzler’s name in 2024, her occupation and employer are both listed as ‘not employed.’

Schmerzler is retired rather than unemployed. There are numerous entries in FEC data noting that contributors are unemployed, so there is no overlap between the two designations. Broken down by contributor occupation, both unemployed and retired individuals accounted for the majority of donations in 2024 made by Connecticut residents to ActBlue.

That, according to Rapini, is another red flag. Among the 18 likely straw donors from Connecticut he identified, 10 had their occupation listed as retired in FEC data and 3 had their occupation listed as not employed.

There is a similar pattern to Slayman’s data. According to the SEEC, Slayman has a longer period of donating to state-level political campaigns, spanning from 2010 to 2022. At no point during that time period did Slayman’s donations to Democratic and Working Families candidates exceed $25. In 2014, Slayman made 5 donations to former governor Dannel Malloy’s campaign and former lieutenant governor Nancy Wyman’s campaign. Those donations totaled $105. In other years, he made single donations to campaigns ranging from $75 to $10.

But according to ActBlue, while Slayman was making small dollar donations to political campaigns in keeping with the average donor profile, he was making hundreds of donations totaling hundreds of thousands of dollars to federal candidates and PACs.

In 2014, the FEC records 420 separate donations Slayman supposedly made through ActBlue, totaling $10,924.75.

FEC records show donations made in Slayman’s name each year between 2006 and 2024, with the number of donations made ranging from 4 in 2007 to 1,124 in 2021.

As with Schmerzler’s data, the FEC’s records show a significant increase in donation frequency around the 2022 election cycle. In 2021, Slayman’s record shows donations totaling $19,975.83. In 2022, they show donations totaling $28,941.

One red flag Rapini identified in broader FEC records for Schmerzler, Slayman, and others with suspicious donation records is donations made to an extremely high number of committees, averaging 90.

The FEC’s data shows a similar pattern. Across Slayman’s donation records, money he supposedly donated to ActBlue was earmarked for 523 different campaigns and PACs. Schmerzler’s donations were earmarked for 101 different campaigns and PACs.

FEC data from 2024 showing ActBlue donations by Connecticut residents follows a similar pattern, showing multiple individuals giving thousands per month in small dollar donations. The vast majority of donors list their occupation as either unemployed or retired.

Inside Investigator’s analysis also flagged several dates where there were significantly higher rates of contributions. For example, the sum of donations made to ActBlue by Connecticut donors on June 26, 2024, was approximately $62,320. The next day, that amount tripled to approximately $184,931. Across the month, the average donation per day was approximately $60,042.

That same month, Inside Investigator’s analysis flagged donations made by an unemployed woman from Stamford totaling approximately $13,140. The average donation across donors that month was approximately $69. In July, donations made in her name totaled approximately $9,250. The average donation across donors that month was approximately $72.

July also saw donations spike towards the end of the month. On July 20, Connecticut donors gave approximately $56,886 to ActBlue. The next day, donations rose to approximately $585,996.

Similar spikes occurred in August, October, and December.

Across all 12 months of data Inside Investigator reviewed, individuals who were either unemployed or not employed made up the majority of donors.

While these donations are clearly fraudulent in the sense that neither Schmerzler nor Slayman actually gave the money FEC records say they did, one might wonder what the issue is? Money was not stolen from Schmerzler or Slayman to make the donations in their names.

One potential issue is that straw donors could be using their identities to skirt federal laws that limit the amount of money that can be donated directly to campaigns and PACs. Individuals can only give up to $3,500 per year directly to a candidate’s campaign and $5,000 per year to a PAC.

Straw donations made under the name of an individual who is ultimately not doing the giving are one potential way to avoid that cap. Another concern is foreign actors trying to influence elections, an issue that dates back to the Watergate era and has featured in federal campaigns since Trump’s first Republican presidential campaign.

Federal law prohibits foreign nationals from contributing or donating to American political campaigns. Taking the information, most of which is publicly available, of U.S. residents and using it to make donations in their name is one way foreign nationals could skirt that ban. In recent conversations about alleged fraudulent donations routed through ActBlue, donations from foreign I.P. addresses have been a concern.

Rapini, a cybersecurity professional, is certain that the donations are not the work of bots and are also not accounting or database errors. He also noted that the significant spike in the frequency of donations around the 2022 election occurs across all 18 donors he identified, which he says is suspicious.

As concerns about donations made on ActBlue have gained increased attention from politicians in Washington, the company’s security protocols have also drawn criticism.

Until recently, ActBlue did not require donors paying with credit cards to enter a card verification value (CVV)—the three or four digit number on credit cards designed as a security feature to prevent fraud—in order to complete a transaction. The platform also accepted donations using prepaid gift cards. Between September and October 2024, ActBlue identified 237 suspicious donations tied to the use of prepaid debit or gift cards, leading to the ban of their use.

ActBlue began requiring a CVV code in January 2024. In September 2024, ActBlue stopped accepting gift cards as a payment method.

Between September 2022 and October 2024, there were almost ten times as many fraudulent transactions identified on the platform. While a report from the U.S. House of Representatives’ Committee on Oversight and Government Reform (COGR) identified 1,900 confirmed fraudulent transactions, Republicans suspect there are considerably more.

The report contains internal documents obtained from ActBlue that document staffers’ concerns with the platform’s security policies.

While the platforms’ changes for CVVs and prepaid gift cards on their face seem to minimize the risk of fraud, the COGR report alleges ActBlue made other changes that were “carefully calibrated to minimize the effects on ActBlue’s donation volume and reputation.” Essentially, the report alleges that the platform took other steps to allow potentially fraudulent transactions to go through to make up for donations that might be lost because CVVs became required and prepaid gift cards were no longer allowed.

ActBlue uses Sift, an AI decision-making tool, to help identify potentially fraudulent transactions. Sift assigns a score to each transaction that assesses the risk of fraud. If the score falls below a certain threshold, the transaction goes through. If it rises above that threshold, the transaction is automatically rejected or manually reviewed.

COGR’s report alleges that ActBlue changed that practice in September 2024. Instead of reviewing all transactions with a score above the Sift threshold, the platform instead began reviewing a “set percentage of the most fraudulent transactions.”

“The changes we’ve made this last year have already meant we’re ‘accepting’ more fraud.” a snippet from an internal ActBlue document about this change that is contained in the COGR report reads.

According to the report, ActBlue also tested out changes like requiring CVVs prior to implementing them in order to understand if they “would have negative impacts to conversion.” They also took steps to minimize the rollout of that change in order to minimize coverage “so that the media, Congress, and other parties would not inquire more broadly about ActBlue’s fraud policies.”

Both exchanges occurred after ActBlue changed its policies to stop accepting prepaid gift cards.

In another internal document contained in the COGR report, ActBlue staffers recommend telling donors attempting to pay with gift cards whose donations were declined and flagged to get in touch with their bank “for further information about why the contribution is not being processed.”

In another email exchange with a donor attempting to use a prepaid American Express card, an internal message between ActBlue employees states a higher up with whom the issue was discussed said “we wouldn’t want to comment on the gift cards and instead just refer them to their bank.”

ActBlue eventually messaged the donor and told them to “contact the card issuer and inform them that all attempted contributions were one-time and not set up to recur.” They also recommended donating for an amount less than the total amount of the gift card, stating it could “improve the success rate of a charge at times.”

That report led to a presidential memorandum ordering attorney general Pam Bondi to investigate how foreign actors are using “straw” and “dummy” donors on online fundraising platforms to make political donations that skirt laws prohibiting foreign contributions to candidates and committees.

Recently, Congressional Democrats in the House of Representatives have countered Trump’s order with allegations that WinRed is also being exploited by foreign actors. Democrats on the House Judiciary, Oversight and Administration Committee asked the U.S. Treasury Department to turn over suspicious activity reports for WinRed; America PAC, created by Elon Musk in 2024 to support Trump; and several cryptocurrency tokens that have been promoted by members of the Trump family.

This is not the first time ActBlue’s and WinRed’s policies have come under scrutiny. In 2021, several Democrat-led states launched investigations into both platforms over their automatic enrollment of donors into recurring donation programs.

To date, reactions to the allegations against ActBlue have come exclusively from the right.

Connecticut attorney general William Tong has not publicly addressed the straw donor allegations. His office has also not responded to questions about whether it intends to investigate the claims.

According to Rapini, he asked Tong about his findings during an appearance on the Gary Byron Show. He later sent his findings through the mail to Tong’s office, but never received follow up communication.

In response to questions about whether Attorney General William Tong’s office had received allegations of fraud against ActBlue or planned to take any actions against ActBlue, spokesperson Elizabeth Benton told Inside Investigator that it had previously disclosed consumer protection investigations into Act Blue and WinRed.

In 2021, following reporting from the New York Times, Connecticut, New York, Maryland, and Minnesota launched an investigation into both donor platforms’ use of prechecked boxes that automatically enrolled donors into making recurring donations on either a weekly or monthly basis. Those investigations are still active, and Tong’s office told Inside Investigator it could not discuss them.

Benton did not respond to a follow up question specifically asking about the more recent straw donor allegations against ActBlue.

But it’s actually something of a fluke that small dollar donation records like Schmerzler’s and Slayman’s are available at all. Their availability has been the subject of scrutiny by First Amendment advocates who argue that the law is applied inconsistently and in a way that risks chilling political speech.

Under current campaign finance law, candidates are not required to disclose data on donors who contribute $200 or less through direct donation. However, the FEC does require intermediary platforms like ActBlue and WinRed to disclose data on donors who give less than $200.

That’s because ActBlue and WinRed often acts as conduits to other candidates and PACs. While donors can donate directly to the platforms, donations made to ActBlue and WinRed are more often earmarked for other candidates or committees. Both platforms allow candidates and PACs to set up pages on their websites that accept donations on their behalf. While anyone who donates through that website is ultimately sending money to that candidate or PAC, the platform is acting as an intermediary. While it sends the money where directed by the donor, it is technically ActBlue or WinRed that is receiving the donation.

The FEC’s regulations require that intermediaries like ActBlue and WinRed report the original source of all earmarked contributions, as well as the end point for which they have been earmarked.

That practice has led to several federal lawsuits, led by attorneys with the Institute for Free Speech (IFS).

In a case from July 2024 filed in the U.S. District Court for the Northern District of Ohio, IFS attorneys argued that the speech of their clients, Colleen and Steve Oliver, was unconstitutionally chilled by the FEC’s disclosure requirements for online platforms because as business owners they feared having that information public could impact their business.

“Colleen Oliver donates money to federal candidates. Because she doesn’t want her donations to reflect on her husband Steve or his business, Colleen makes sure to keep her donations under $200, the threshold over which direct donations to candidates are publicly disclosed. To her surprise, one such donation was disclosed anyway, simply because the candidate used a conduit platform to receive donations.” the complaint in their lawsuit states.

The lawsuit also states that while Steve would also like to donate to certain candidates, “he does not wish his small dollar donations to be disclosed, fearing that such disclosure could result in donation requests from other officials and candidates, and cause potentially awkward relations with, or adverse treatment from, those to whom he wouldn’t donate.”

That the Olivers feel they have to withhold contributions, which effectively amount to an expression of political speech, over fear of retaliation is unconstitutional, IFS alleges.

“So applied, this provision requires conduit committees to report the identity of each donor who donated via the conduit committee starting at a $0 threshold. This is an unconstitutionally low threshold under the First Amendment. It burdens donors’ rights of association and expression of political speech without advancing any important government interest.” the lawsuit claims.

The case was voluntarily dismissed in November 2024.

IFS filed a similar case in the U.S. District Court for the Northern District of Texas in February of this year. Plaintiff Tony McDonald serves as the Tarrant County Republican Party and, according to the lawsuit, is concerned that donations he makes in his personal capacity could impact his position in the party and public perception of the party’s stances.

According to the lawsuit, McDonald sometimes gives to candidates not necessarily because he supports their campaigns or positions, but to help their campaigns do things like qualify for debates. In June 2019, McDonald donated $1 to Marianne Williamson’s presidential campaign in order to help her qualify for the presidential debates. He did know that the donation was processed by ActBlue and would be publicly reported.

McDonald is also concerned that reporting of some of his giving could be construed as support from the Tarrant County Republican Party.

“If McDonald’s small donations are revealed, he fears repercussions for himself and the Tarrant County Republican Party, in the form of demands for similar donations from other candidates, confusion over the Tarrant County Republican Party’s stance in primary races, and misunderstandings regarding the intent and implications of McDonald’s donations.” the lawsuit states.

While McDonald wants to continue to donate, according to the lawsuit he is afraid to because his donations might be disclosed if they go through conduit sites.

“Thus, McDonald is chilled in his ability to express his political views through donations to his chosen political candidates. McDonald is forced to choose between freely voicing support for candidates and policy through monetary donations and maintaining his privacy.” the suit claims.

Both of these cases highlight that, because of the way ActBlue and WinRed are structured, donors don’t always necessarily know they aren’t giving directly to a candidate. Because both platforms allow candidates to create pages that they can share with potential donors, it’s not always apparent donors are being routed to an intermediary website rather than to a site that directly accepts donations to their campaign.

As with many public records—which campaign filings are—what’s disclosed involves a tradeoff between public interest and privacy interests.

While Connecticut residents currently can’t use ActBlue to make donations to state and local races, legislators have recently toyed with the idea of changing that.

As a majority of in-state candidates take public funds from the Citizens Election Program (CEP), what candidates who participate in the program can accept from individual donors is already limited. To qualify for public financing, eligible candidates must raise a certain amount of money from small dollar donations, with a certain percentage coming from donors who live in their district. Once they qualify for and receive CEP funding, they are not allowed to accept individual contributions or money from other sources.

Some online donation platforms, including ActBlue, are currently prohibited as a result of the way a contribution is defined by state law.

Essentially, those platforms collect “tips” to cover the cost of credit card transactions. That “tip” is paid to the platform, rather than the candidate or PAC. Under current state law, that’s considered an in-kind contribution, which candidates who receive CEP money are not allowed to receive.

In 2024, legislators introduced a bill that redefined the definition of contributions and expenditures under campaign finance law and would have allowed platforms that use “tips,” like ActBlue, to collect donations from state and local candidates and committees. While the bill passed the Senate, it was never taken up by the House of Representatives. During the bill’s committee process, lawyers from SEEC expressed concern with the breadth of language in it.

Similar language has not been introduced this year.

The availability of that data could be considered something of a double-edged sword: while there may be privacy and speech concerns around the availability of small dollar donation data that is not available outside platforms like ActBlue and WinRed, making it available does also increase public transparency of patterns in political donations and enable the detection of potential fraud.

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