Conservative think tank laying groundwork for a second Trump term raised millions from a single anonymous donor

A nonprofit that employs numerous Trump administration officials and is laying the groundwork for the former president’s potential second term raised more than $23 million last year – nearly a third of which came from a single anonymous donor, previously unreported tax documents show.

The documents show that America First Policy Institute – a think tank that’s been described as a “White House-in-waiting” and has released a spate of conservative policy proposals – burned through most of the funds it raised, spending $22 million over the course of the year. That included the rental of Donald Trump’s Mar-a-Lago resort for a fundraising gala that featured a keynote speech by Trump himself.

But AFPI’s windfall has also sparked tensions with Trump’s team, with some advisors concerned the group has been taking in donations that would be better routed to the former president’s campaign or affiliated political action committees, a source familiar with the internal conversations told CNN. The debate comes as Trump and his allies have laid out a vision for a second term in which he would wield presidential power in radical and unprecedented ways.

As a charitable organization under tax rules, AFPI is barred from engaging in campaign activities, and it has said it’s preparing policies for the next Republican president – whether that’s Trump or someone else. But the group’s leadership looks like a Trump administration reunion, with officials such as former Small Business Administration head Linda McMahon, former National Economic Council director Larry Kudlow, former acting director of the Domestic Policy Council Brooke Rollins, and former acting Homeland Security secretary Chad Wolf.

The group raised $23.6 million in 2022, up from more than $14 million the previous year, according to a tax document filed last month with the New Mexico Attorney General’s office. An auditor’s report also filed with the office said that “approximately 31% of the Organization’s contributions in 2022 were provided by one individual,” which would mean a total donation of more than $7 million. The donor was not named, and the group is not required to publicly disclose their identity.

AFPI’s board of directors includes several wealthy GOP donors such as Texas energy magnates Tim Dunn and Cody Campbell, Florida philanthropist Trish Duggan, and Goya Foods CEO Bob Unanue, as well as former Speaker of the House Newt Gingrich. A new addition to the board in 2022 was Mark Pentecost, a Florida entrepreneur who runs a skincare and nutrition company but does not have as significant a history of political donations.

The group doesn’t publicly disclose any of its donors. But additional tax documents reviewed by CNN reveal that it received some donations from foundations connected to wealthy businessmen or their estates, including the Jackson Howard Foundation, which gave about $304,000, the Leandro P Rizzuto Foundation, which gave $260,000, the Dunn Foundation, which gave $250,000, and the Herche Family Foundation, which gave $200,000.

Good government advocates have argued that large anonymous donations to groups like AFPI should be concerning because they allow megadonors to shape policies that a future president could enact.

“The idea that dark money is going to have such a strong influence on the shaping of government personnel and policy is frightening and threatening to democracy,” said Jack Beermann, a Boston University professor who’s studied presidential transitions. “You don’t know who’s beholden to who and for what.”

AFPI spokesperson Marc Lotter said in an email that “donors do not dictate the policy priorities or work of our experts,” adding that the group was “a policy organization, not a transition” organization. He declined to identify AFPI’s largest anonymous benefactor and said that the group had received contributions from a total of 44,000 donors since its inception in 2021.

According to the tax filing, the group employed 81 people and had 50 volunteers in 2022. It spent more than $22 million, with about $9.4 million going to salaries and benefits, including more than $550,000 in total compensation for Rollins, the group’s CEO.

The group also listed expenses of $963,000 as “rent/facility costs” for a fundraising gala that included a speech by Trump at the former president’s Mar-a-Lago resort. The tax return reported that AFPI spent a total of about $1.1 million on the event and raised $1.6 million from it.

Lotter said that the gala was a three-day conference with meetings, speeches and events “spread across eleven venues,” including Mar-a-Lago. He declined to say how much of the total facility expenses went to renting the resort.

AFPI has released a bevy of policy proposals, including stripping most civil service protections for federal employees, implementing work requirements for government benefits, and completing the US-Mexico border wall. The group is also developing plans to “implement the President’s agenda faster and more effectively than any administration in history,” which it says includes drafting dozens of executive orders that Trump or another conservative president could issue immediately.

AFPI isn’t the only group preparing for a potential second Trump term – the Heritage Foundation’s Project 2025 is also conducting similar efforts, including releasing a 900-page book of policy plans and vetting potential appointees. The Heritage Foundation reported receiving more than $95 million in contributions in 2022, and donated several hundred thousand dollars to other conservative nonprofits partnering with it on Project 2025. AFPI didn’t report any contributions to other groups last year.

Trump’s allies have acknowledged that his first term as president was constrained by his team’s inexperience in turning campaign rhetoric into policy, as well as officials who slowed down or blocked some of his most extreme plans. AFPI and Project 2025 are working to make sure that’s not the case if Trump returns to the White House.

But increasing private tension between Trump’s campaign and various outside groups recently spilled into public view after a series of articles were published on the efforts of these groups to plan for a second Trump term. Trump’s top campaign advisers, Susie Wiles and Chris LaCivita, issued a statement pushing back on the influence of the organizations last month.

“The efforts by various nonprofit groups are certainly appreciated and can be enormously helpful. However, none of these groups or individuals speak for President Trump or his campaign,” the statement read.

Some Trump advisers have expressed concern that AFPI has been fundraising on the former president’s name, ultimately taking money that they believe should be going to the candidate directly. Trump’s allies have also been annoyed at what they describe as attempts at taking credit for policy plans that were not vetted and approved by Trump or the campaign, two sources close to the former president said.

Trump’s leadership PAC made a $1 million donation to AFPI in 2021, but has not given to it since then, according to campaign finance records.

Lotter noted that Trump has spoken at multiple AFPI events in recent years, including the group’s most recent gala last month, which was again held at a Mar-a-Lago. He said the group includes eight former Cabinet-level officials, 20 former White House senior staff, and nearly 50 senior administration officials.

“We are proud to be the home of the America First movement and building an organization to promote America First policies for the next 100 years,” he said.

Heath Brown, a City University of New York professor who’s written multiple books on presidential transitions, said that outside groups planning for transitions – and tension between external efforts and candidates who don’t want to be seen as “measuring the White House drapes” – isn’t new. Heritage, for example, helped plan for Ronald Reagan’s transition in 1981.

But in the rush to prepare after an election victory, carefully drafted plans from external nonprofits often fall by the wayside, Brown said. The most important question is which officials Trump or another Republican president-elect picks to advise them on the transition – and the proposals being circulated by groups like AFPI can be seen as auditions for those jobs.

“That’s the seat at the table that everybody’s vying for,” Brown said. “That’s where the real important work goes on.”

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