Even Trump Can’t Make Sense of His Own Dark-Money Maze
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An inquiry from the feds has thrown new light on the murky relationships between a dozen Trump-aligned groups. And the problem traces back, as do so many other problems in Trumpworld, to a familiar name: former top aide Corey Lewandowski.
When Lewandowski got himself fired from a pro-Trump super PAC last fall—after allegedly sexually assaulting a big donor—the group brought in a clean-up crew. When Lewandowski refused to step down, they opened up a new super PAC without him.
That super PAC—the preposterously titled “Make America Great Again, Again!”—was the 12th in a sprawling labyrinth of political groups and nonprofits that comprise the Trump fundraising network. And in terms of the incestuous confusion, it may have been the one that finally tipped the scales; federal election officials now want to know why some of the super PAC’s payments aren’t being properly reported.
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Brendan Fischer, deputy executive director of good government group Documented, said the extent of Trump’s network is unparalleled.
“It is worth emphasizing: All of this is totally unprecedented for a former president,” Fischer told The Daily Beast. “Even if Trump kept it simple, and just had one hard money PAC, a single super PAC, and a pair of 501(c)(3)/501(c)(4) nonprofits, there would be no parallel with any former president in American history.”
Anyone who’s taken even the quickest of peeks at Trump’s personal financial disclosures would recognize the pattern.
His first such disclosure revealed positions with more than 500 entities, nearly 400 of which used his name or initials. And Trump has “organized” the mess in a stultifying Russian-nesting-doll structure—companies within companies within companies. Frequently, one company will be held under multiple Trump companies at the same time, each with stakes in still other Trump companies.
This isn’t an accident. The structure gave the Trump Organization an enormous amount of financial flexibility, while making it difficult to follow the billions of dollars that Trump, his family, and his accountants move across the organization.
When Trump hauled his private life into politics, he brought this practice with him, too.
The full Trump-aligned apparatus counts a dozen separate political committees and dark money organizations. Almost all of them share one of three names.
Here they are:
Make America Great Again PAC (converted from the old Trump campaign)
Make America Great Again Action (super PAC)
Make America Great Again, Again! (super PAC)
Trump Make America Great Again (small-dollar joint fundraising committee)
Make America Great Again Policies Inc (a 501(c)(4) nonprofit)
America First Policy Institute (a 501(c)(3) nonprofit)
America First Works (formerly America First Policies; a 501(c)(4) nonprofit)
America First Legal Foundation (a 501(c)(3) nonprofit)
America First Action (super PAC)
Save America (leadership PAC)
Save America JFC (joint fundraising committee)
Trump Victory (high-dollar joint fundraising committee)
“Typically, former presidents focus on their presidential library, or start a charitable foundation, but Trump is staying in the political game and raising a staggering amount of cash,” Fischer said.
It is staggering.
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For instance, the Trump-endorsed America First Action super PAC pulled in nearly $200 million between 2017 and 2020. Its sister nonprofit, America First Works—formerly America First Policies—posted $51.3 million in revenue for 2020, doling out nearly $40 million in grants.
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The TMAGA PAC raised $884 million for 2020, with Trump Victory tossing in another $336.3 million. Those guns mostly fell quiet last year, while Trump’s three new PACs built up a $124.4 million stash, with another $12.5 million in the MAGAA! super PAC.
And we won’t know how much those other dark money nonprofits raised in 2021, or what they did with it, until after the midterms.
As Trump and the Republican Party gear up for 2024, these groups are in various stages of repair. However, that also appears to have created some internal problems. In fact, according to a filing on Wednesday, even the Trump campaign admits it isn’t always able to follow its own money.
Fischer chalked up the mess to a few factors, including Trump’s will-he-or-won’t-he candidate status, his relationship with the Republican National Committee, and disarray among his associates.
But Brett Kappel, a specialist in campaign finance and nonprofit law at Harmon Curran, perceived something more designed.
“The central lesson of Watergate is ‘Follow the money,’” Kappel told The Daily Beast. “And this byzantine structure of different types of legal entities—which are subject to different fundraising restrictions and file different reports with different agencies according to different filing schedules—appears to be designed to make that task as difficult as possible.”
To illustrate, these organizations can be divided into two groups: PACs and joint fundraising committees, and “dark money” nonprofits.
The PACS and joint fundraising committees are Trump’s political organizations. They disclose their finances to the Federal Election Commission. But they don’t all follow the same filing schedule, and, depending on what kind of committee they actually are, they can raise and transfer different amounts of money from different types of people and organizations.
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Of these groups, Save America leadership PAC is currently Trump’s main squeeze. Most of the money he raises goes there. The Save America JFC is a joint committee that splits donations between Save America and MAGA PAC, which used to be the Trump campaign. Weirdly, MAGA PAC doesn’t get much out of this joint arrangement—more than 90 percent of every contribution goes to the Save America PAC.
And the super PACs are, as mentioned above, something of a mess.
As for the “dark money” nonprofits, unlike the PACs, these groups file with the IRS. They don’t have to disclose their donors at all (hence “dark money”). They also only file once a year, and because those deadlines are so late, it can take nearly two years for a transaction to become visible to the public.
The IRS restricts their activities, too. Some groups have leeway to be political (the 501(c)(4) groups). Some must focus on social welfare (the 501(c)(3) groups). The Trump network has a healthy helping of both.
Sometimes, however, these PACs and nonprofits can overlap, even sharing employees and office space, like America First Action and America First Policies did during the Trump administration.
And while they appear to be giving that another go, as the FEC found, it hasn’t been so clean this time.
Enter Lewandowski.
After Trump left the White House, the industriously sycophantic Lewandowski wormed his way back into his graces, winning the right to run the Make America Great Again Action super PAC. At the same time, he quietly created a Florida nonprofit, Make America Great Again Policies Inc.
But MAGA Policies didn’t appear to do anything—at all. There has been no reporting on any actual activity since it was created. Zero. It is a black box.
Then Lewandowski reportedly sexually assaulted a Trump donor and got himself booted from orbit. More experienced hands took over the new MAGAA! super PAC, led by former Florida attorney general Pam Bondi, and that also got complicated.
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According to a new corporate filing in Florida, Bondi—who also happens to lead the massive America First Policy Institute nonprofit—also took over Lewandowski’s mysterious MAGA Policies nonprofit, adding former Trump administration officials Ric Grenell and Matt Whitaker, as well as Donald Trump Jr. paramour Kimberly Guilfoyle. All of those people are also on the new super PAC’s payroll.
But here’s the rub: The super PAC hasn’t been paying them directly. The nonprofit has, as part of a “cost share agreement.”
On Tuesday, the FEC sent the super PAC a letter saying that’s not cutting it. The group needs to explain exactly what they mean by “cost share agreement,” the letter said, because what they provided is not adequate.
Kappel said the FEC may be trying to figure out whether the two groups are “financially and operationally independent.” If the super PAC was found to be “connected” to the MAGA Policies nonprofit, he said, that means it can only raise money from people tied to the nonprofit—and not from the general public. That would be a death blow, and the group would be forced to reorganize itself yet again.
Fischer said he wouldn’t be surprised to see more groups strategically shut down, like Trump Victory began doing last year.
“It might be more straightforward for Trump to shut down MAGA PAC,” he said, though he pointed out that MAGA PAC appears to own the campaign’s valuable supporter data, which might make it more cost-effective to retain for joint fundraising efforts.
But, Fischer pointed out, even though the constellation of Trump-aligned groups is basically unnavigable, it always could have been worse.
“Recall that Brad Parscale also started the ‘American Greatness’ super PAC in 2021, which never really got off the ground,” he said.
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