Money Laundering and Elections

Non-profits organized and licensed as 501(c)(3) entities get donations to them characterized as tax deductions, and they are prohibited from engaging in any form of political campaign for or against a candidate. Non-profits organized and licensed as 501(c)(4) entities, on the other hand, are allowed to engage in political campaigns, including direct partisan politics.

So far, everything’s jake.

However.

Quite a number of 501(c)(3)s sent all of their donations to 501(c)(4)s explicitly to help fund politicians’ campaigns and to allow their donors’ donations engage in those direct partisan politics. That’s strictly, narrowly legal.

Here are three examples, though, of something more nefarious.

  • Democracy Matters Foundation provided 96% of its 2024 expenditures to its affiliated(!) 501(c)(4), Democracy Matters, some $31.38 million
  • Guarantee Our Votes Project spent just 0.2% of its $13,919,873 on 2024 legal and office expenses; the remainder went to donations like $13.85 million to America Works USA
  • America Votes Education Fund in 2024 gave $20,748,002 to its 501(c)(4) affiliate(!) America Votes. It claimed a token $532 in office expenses and $274 in fundraising expenses that year, and it had no paid employees

Should that sort of thing be legal? It looks like money-laundering to me.