How an Oil & Gas nonprofit in Berkeley became the international funding rail for a federal-worker political operation — and the Congressional caucus built to protect it.
A four-page PDF surfaced this week. On its face it is a fundraising memo. It has a friendly title — "How to Contribute to Federal Workers Alliance for Democracy" — and it walks a donor through five ways to send money: online credit card, Zelle, bank wire, donor-advised fund, and gifted stock. It is written in the cheerful, slightly earnest voice that nonprofit development offices use everywhere. It could be from any advocacy group in America.
But read it with a forensic eye, and the document does something else. It quietly publishes an international SWIFT correspondent-banking rail for a federal-worker organizing operation that is, by its own internal training materials, engaged in electoral activity targeting the sitting executive branch of the United States government. It routes every one of the five payment channels through a single 501(c)(3) tax shelter — a California "climate and fossil fuel" nonprofit whose IRS-filed charitable purpose has nothing to do with federal workers, democracy training, or elections.
That nonprofit is the Oil & Gas Action Network — OGAN. The EIN is 82-0941015. It is a 501(c)(3) registered in Berkeley, California and tax-exempt since May 2017. Its filed mission, verbatim from its own Form 990, is to conduct research and public education about the environmental and human-health impacts of oil and gas extraction. It is also, according to the document in circulation, the legal shell through which an anonymous international donor can wire money — dollar-for-dollar, SWIFT/BIC routed — into a federal-worker resistance project that the 501(c)(3) has not disclosed to the IRS as part of its program activity.
On the other end of that rail sits a Congressional caucus of twenty-six sitting lawmakers whose geographic footprint and operational ally list match the exact population being organized. The caucus launched on February 4, 2026. FWAD's encrypted "coordinated shutdown" strategy call happened on April 15, 2026. Seventy-one days apart. One corridor. One operation.
This is the story of that pipeline. It is also the story of a structure. A structure that looks, at every level, like the one the Department of Justice indicted three days ago in Montgomery, Alabama.
The PDF is titled "How to Contribute to Federal Workers Alliance for Democracy." Its opening sentence sets the structure: "Contributions are made through our 501(c)(3) fiscal sponsor, Oil & Gas Action Network (OGAN), who then directs those funds to us." Every channel in the document — five of them — routes money to OGAN's accounts first, then to FWAD internally.
Contributions are processed with a 3.9% Stripe fee. The page is public and linked from FWAD's website. This is the only channel with a transaction fee — a structural design that pushes larger donors toward the no-fee channels below.
Funds sent to finance@OilGasAction.org. Donors are instructed to place "Federal Workers Alliance for Democracy" in the memo. If they cannot add a memo, the document instructs them to email a FWAD point of contact directly "so we can make sure our fiscal sponsor routes your contribution to us." That single sentence is operationally important. It confirms — in the organization's own written words — that OGAN is not merely holding funds; it is actively routing them internally, based on instructions from the sponsored project.
This is the section that matters most. The document publishes two separate wire instructions — one for domestic incoming wires, one for international — and flags in the opening sentence: "Both domestic and international incoming wires are processed using the instructions below." The international block is titled, in bold, "International Incoming Wire Instructions that require SWIFT/BIC Code."
PNCCUS33SWIFT/BIC codes exist for one function: routing bank wires across international borders. A domestic climate-advocacy nonprofit, soliciting from grassroots American donors — as OGAN presents itself to the IRS — does not need a correspondent-bank block. The PNC correspondent routing exists for a specific case: a sender outside the United States wants to wire funds to a U.S. beneficiary account, and the sending bank needs a SWIFT code to find the U.S. bank.
The document, on its face, tells foreign senders how to do that — and tells them to earmark the funds for FWAD in the memo line. This is, in plain language, an affirmative solicitation of international contributions to a federal-worker political-organizing project hosted inside a climate-advocacy 501(c)(3).
Three options listed. Option 1: donors direct their DAF to "Oil & Gas Action Network" — the document notes "OGAN is in most of the larger funds' databases already." Option 2: EIN 82-0941015 is published. Option 3: the document instructs donors to email matt@oilgasaction.org — Matt Leonard, OGAN's executive director — who will "help you navigate." Across all three, the memo must read "Federal Workers Alliance for Democracy."
The DAF channel is particularly consequential because donor-advised funds at major sponsors — Fidelity Charitable, Schwab Charitable, Vanguard Charitable, community foundations — are granted to the public charity of record: in this case OGAN, operating under its stated environmental purpose. The DAF sponsor has no obligation and no mechanism to verify that the funds are actually being used for environmental research. That verification is OGAN's responsibility. The donor's advised grant is logged against OGAN's charitable purpose. The memo-line redirect to FWAD is invisible to the upstream DAF sponsor.
Executed through National Financial Services (DTC number 0226) into OGAN's account B9G-103856, coordinated by SharePower Responsible Investing — a financial advisor named Jeremy A. Pearce in Arkansas (479-279-7970). The stock-gift channel strips even more identifying information: the original donor is the financial-advisor client; what arrives at OGAN is a transferred equity block with the receiving-account coordinates, and the internal memo-line requirement once again ensures it is booked to FWAD rather than to OGAN's environmental programs.
Five parallel channels. One common tax shelter. One internal routing instruction. Each channel is engineered to maximize donor reach — ActionNetwork for small grassroots, Zelle for frictionless individual transfers, wire for large USD senders, SWIFT for international, DAF for philanthropic billionaires, stock for appreciated-asset donors. Each channel routes through OGAN. Each channel requires the memo line "Federal Workers Alliance for Democracy." The document is a manual for one thing: getting money to FWAD while the tax receipt is issued in OGAN's name.
Every 501(c)(3) in the United States files a Form 990 annually, and on that form the organization states — in one sentence — its mission. This is the sentence that defines the legal boundary of its charitable purpose. The IRS grants tax exemption against that stated purpose. Donors are told their gift will fund that purpose. State attorneys general enforce against deviations from that purpose.
Here is OGAN's mission statement, verbatim, as reproduced on its GuideStar profile drawn from its Form 990:
Conducting research and educating the public on issues related to the protection of the environment and human health from the impacts of oil and gas ext… — OGAN Form 990 Mission Statement (GuideStar, truncated as displayed)
Nineteen words. Every word is about the environment and oil and gas extraction. The IRS classifies OGAN under the NTEE category Environmental Quality, Protection and Beautification / Alliance/Advocacy Organizations. There is no labor category. No civic-engagement category. No election category. No federal-workforce category.
Now hold that sentence next to what FWAD is actually doing under OGAN's legal personality.
On April 15, 2026, FWAD hosted a Jitsi video call. A presentation was delivered by a former senior advisor from the U.S. State Department's Bureau of Democracy, Human Rights, and Labor — a twenty-year veteran of international democracy work spanning the National Democratic Institute, OSCE election observation, Counterpart International, IREX, International IDEA, and the Third Summit for Democracy. The slide deck was titled "The US Authoritarian Electoral Strategy." It framed the sitting U.S. executive branch as authoritarian. It presented Poland, Turkey, and Hungary as tactical models for American federal workers. It prescribed data-gatekeeping, leaking election information to journalists and foreign observers, and internationalizing disputes to foreign bodies. It included a Hatch Act compliance section. It assigned federal employees specific electoral tasks: voter registration, get-out-the-vote operations, poll working, election observation, and candidate campaigning.
None of that is research or public education on the environmental and human-health impacts of oil and gas extraction. None of that is adjacent to that purpose. None of it is a permissible extension of that purpose.
It is a completely different charitable activity, executed under a 501(c)(3) whose legal charter does not describe it.
Under federal tax-exempt doctrine, operating substantially outside the stated exempt purpose is grounds for revocation of tax-exempt status. When the operational mismatch is concealed from donors through a routing scheme, it crosses from exempt-purpose violation into the territory of donor fraud. When that concealment is achieved by representations made to a federally insured bank for the purpose of opening and maintaining accounts to move the funds, it crosses further into the territory of false statements to a financial institution — 18 U.S.C. § 1014. These are not abstract doctrinal questions. They are the exact counts the Department of Justice returned against the Southern Poverty Law Center on April 21, 2026.
OGAN's revenue, as reported to the IRS, tells its own story:
That is a 11.75× revenue increase in three years for an organization that, by its own characterization, has no offices, no lobbyists, and a single paid executive drawing $93,600. Climate-advocacy nonprofits do not grow 12× in three years on the strength of their environmental research output. Fiscal-sponsorship books of business do. The money is arriving because sponsored projects — with their own independent donor networks, their own fundraising operations, and their own political targets — are routing their revenue through OGAN's tax ID.
Two schedules on OGAN's 990 tell the rest of the story. The first is Schedule F — Statement of Activities Outside the United States. Every Form 990 filed by OGAN from fiscal year 2022 through fiscal year 2024 — the period of the revenue jump — includes a Schedule F. The IRS requires Schedule F whenever an organization has grantees, program activity, fundraising, or business operations outside U.S. borders. A Berkeley-based climate advocacy nonprofit, operating an ostensibly domestic grassroots training program, has no obvious need to file a Schedule F every year. It is filing one anyway.
The second is Schedule I — Grants and Other Assistance to Organizations, Governments, and Individuals in the United States. Schedule I is where a fiscal sponsor, in theory, discloses its sponsored projects — by name, EIN (if any), amount, and purpose. If FWAD is disclosed there, the question is how it is described — because if it is characterized as climate-related activity, the Schedule I itself becomes a potentially false statement. If FWAD is not disclosed there at all, the question is where the money appears on the return and whether the project's existence is acknowledged anywhere in OGAN's public IRS filings.
Both possibilities point toward a regulator.
OGAN's Schedule I for fiscal year 2022 disclosed three formal grants. One of them is the tell.
Our Revolution is not a climate organization. It is a 501(c)(4) political action organization founded on August 24, 2016, as a direct continuation of Senator Bernie Sanders's 2016 presidential campaign. Its stated purpose, in its own words, is to "create, support, promote and elect progressive candidates from school board to US Senate." It endorses candidates. It funds primary campaigns. It is, by its own IRS designation, explicitly political.
And here is the specific detail that converts this from a surprising grant into a traceable operational link: Our Revolution's executive director, Joseph Geevarghese, is a career federal-worker organizer. Before joining Our Revolution in 2019, Geevarghese led Good Jobs Nation and helped launch the "Fight for $15 & Union" movement, organizing walkouts by thousands of low-wage federal contract workers. His organizing specialty, before he took over Our Revolution, was federal contract-worker organizing. That is not a climate-issue skill set. That is the skill set FWAD now needs, sitting one tax-exempt shell away.
A "climate" 501(c)(3) grants $47,500 to a 501(c)(4) political action organization whose executive director's career specialty is federal-worker organizing. That grant sits under OGAN's environmental-protection exempt purpose. No donor to OGAN's climate mission was told that $47,500 of their contribution was being redirected to an electoral organization.
The second 2022 grantee is listed on the Schedule I simply as "For All." The grant is small by institutional standards but the name on a Schedule I is a matter of public record — a climate research nonprofit made a $15,200 gift to an organization its own return describes as "For All." The question for regulators is what specific 501(c)(3)-permissible environmental activity the recipient delivered in exchange for that grant. The same question applies to all three 2022 recipients and to the recipients OGAN listed in its 2023 Schedule I: three grantees spread across the District of Columbia, Georgia, and Pennsylvania — three jurisdictions whose common thread is federal election infrastructure, not oil and gas environmental research.
The third 2022 grant, reported on OGAN's Schedule F, is a $30,000 wire transfer to Europe. The stated purpose on the return: "climate campaign."
This matters because it converts the SWIFT rail on the FWAD funding document from a published solicitation into an established practice. OGAN has been moving money internationally through bank wires for at least three fiscal years. The direction of flow in 2022 was outbound — U.S. funds to a European recipient. The FWAD funding document now publishes the inverse direction of flow — foreign donor, inbound, via SWIFT/BIC, into the same OGAN banking infrastructure. The same correspondent-banking relationship. The same Beneficial State Bank account.
An organization that files Schedule F every year, that has publicly wired money to Europe for "climate campaign," and that now publishes an international wire rail into its U.S. account with memo-line instructions to earmark incoming funds for a federal-worker political-organizing project is not a hypothetical risk. It is a structure in operation.
The Internal Revenue Code permits a 501(c)(3) to grant funds to a 501(c)(4) only under strict conditions. The grant must be restricted in writing to exclusively 501(c)(3)-permissible activities. The grantor must be able to document that the grantee used the funds only for those restricted activities. The restriction cannot be generic "charitable education" — it has to be activity-specific, traceable, and verifiable.
Our Revolution's primary activity is electoral. If OGAN cannot produce a written restriction and a paper trail showing the $47,500 was spent on something other than electoral activity, the grant is a direct exempt-purpose violation — independent of, and additional to, the mismatch between OGAN's climate charter and its fiscal sponsorship of FWAD. Two legal violations off a single line item.
FWAD is not the only political-organizing project operating under OGAN's tax-exempt umbrella. It is one of several. Two others are public.
Third Act was founded by Bill McKibben — the same 350.org founder whose protest-organizing apparatus Matt Leonard (OGAN's executive director) came up through as a lead organizer for nine years. Third Act's Virginia, DC, and Maryland chapter operates a public fundraising page stating, in plain language: "Donations made are tax-deductible, through our fiscal sponsor Oil and Gas Action Network."
That chapter's geographic target is not a climate-issue geography. It is the federal workforce corridor. Virginia, DC, and Maryland together house the bulk of the career federal civil service, and — as documented below — eighteen of the twenty-six sitting members of the Congressional Federal Workforce Caucus.
A separate politically-oriented project, independently operating on OGAN's 501(c)(3) platform. Its public donation page carries the same boilerplate: "Donations are made through our Fiscal Sponsor (Oil and Gas Action Network)."
Between FWAD, Third Act DC/MD/VA, and Climate Emergency Mobilization Task Force — three named sponsored projects, plus the forty-plus additional allied projects OGAN publicly claims — the pattern is not a one-time exception. It is OGAN's core business.
OGAN's 501(c)(3) tax-exempt shelter is functioning as a general-purpose political-organizing platform, with a sponsorship book heavily weighted toward projects targeting the federal workforce and federal elections. The stated exempt purpose — environmental research on the impacts of oil and gas extraction — is a legacy description from the organization's 2017 founding. The operational reality is a backpack-style fiscal-sponsor platform that has grown twelve-fold in three years by onboarding sponsored projects whose missions bear no relation to the stated charitable purpose of the shelter they now operate inside.
On February 4, 2026 — exactly seventy-one days before the encrypted FWAD strategy call of April 15, 2026 — a bipartisan, bicameral Congressional caucus formally launched in Washington. It is called the Federal Workforce Caucus. Twenty-six sitting members of Congress. Twenty-five Democrats. One Republican (Rep. Mike Lawler of New York's 17th district — the bipartisan fig leaf).
The launch press conference was held at the United States Capitol. Speaking at the podium alongside the founding members was Skye Perryman, President and CEO of Democracy Forward — the 501(c)(3) I documented in earlier INSIDE JOB installments as the legal arm of the FWAD coalition. The caucus and the coalition did not meet at that launch by accident.
The first thing the roster tells you is the geographic concentration. Count the home states:
Eighteen of twenty-six members — 69 percent of the entire caucus — represent the Washington D.C. federal workforce corridor. A "national" caucus that is two-thirds Maryland and Virginia is not a national caucus. It is a constituency caucus for the people being organized on the other side of the pipe.
Those federal workers being organized are the same federal workers receiving training from FWAD — the sponsored project of the 501(c)(3) (OGAN) that is also fiscally sponsoring Third Act DC/MD/VA, a separate political-organizing project operating in the same exact corridor.
Among those twenty-six caucus members is Rep. Jamie Raskin (D-MD-8). Raskin was quoted prominently at the caucus launch press conference, describing the purpose of the caucus as defending "the professional civil service and the public servants" from the current administration.
Raskin has a documented endorsement history with the 501(c)(4) that OGAN directly funded. Per public-record tracking of Our Revolution's endorsement activity, Our Revolution endorsed Jamie Raskin for Congress in 2020. The endorsement was carried through Our Revolution Maryland — the state chapter based in Silver Spring — which operates endorsement and candidate-support machinery in the exact state whose delegation accounts for nine of the twenty-six caucus members. In 2016, when Raskin first ran, Our Revolution's Maryland infrastructure (jointly with Progressive Neighbors) had already backed him.
OGAN → Our Revolution → Raskin is a three-step chain, every step of which sits on a public record. The first step is a Schedule I line item on OGAN's 2022 Form 990. The second step is the 501(c)(4) designation of Our Revolution. The third step is a documented endorsement of a now-sitting caucus member.
Three layers. One operation. A Congressional caucus at one end that provides the legislative shield. An operational apparatus in the middle — FWAD, Branch4, FUN, Third Act DC/MD/VA — that provides the body inside federal agencies. A 501(c)(3) at the other end that provides the tax-exempt funding rail, including the published international wire channel. Each layer is legally insulated from the others by 501(c) walls and Congressional protocol. But the synchronization of the three is not in dispute. It is on public record.
The caucus launched on February 4, 2026. The FWAD "coordinated shutdown" call happened on April 15, 2026. Seventy-one days apart. Same target population. Same operational corridor. Same narrative voice. You do not build a Congressional caucus and a federal-worker resistance operation in parallel by accident.
Under California and federal nonprofit law, the directors and officers of a 501(c)(3) are the legally responsible fiduciaries for the organization's adherence to its exempt purpose. They sign the Form 990 under penalty of perjury. They are the parties against whom the IRS, the California Attorney General's Registry of Charitable Trusts, and the Department of Justice bring enforcement actions when the exempt purpose is misused.
OGAN's board, per its own Form 990 and GuideStar self-reporting as of October 28, 2025, consists of six individuals. Their professional histories are substantially identical — and they matter, because these are not environmental-science researchers, conservation scientists, or public-health professionals. These are professional protest organizers from the anti-fossil-fuel direct-action movement of the 2010s.
Leonard is OGAN's sole paid officer. Per his LinkedIn profile and multiple archived biographies, he spent nine years as a protest organizer with 350.org, along with additional tenures as a protest trainer for Greenpeace, Rainforest Action Network, and the Ruckus Society. He was a lead organizer of the Tar Sands Action protests against the Keystone XL pipeline. His training is direct action — the tactical discipline of designing, staffing, and executing confrontational protest events. He is the executive director of OGAN; he is also the named DAF contact on the FWAD funding document, who personally helps donors route funds through the donor-advised-fund channel.
FY 2024 compensation from OGAN: $93,600 salary plus $14,492 other. On that figure alone, the revenue growth does not flow to him personally. It flows past him, into the operational accounts that then route to FWAD and the other sponsored projects.
Krill simultaneously serves as Executive Director of Earthworks — a substantially larger DC-based environmental-litigation and policy nonprofit that targets mining and extractive industries. Her cross-organizational role as chair of OGAN's board places her at the top of two interlocking environmental-advocacy organizations. An Earthworks ED chairing a second environmental 501(c)(3) is unremarkable. An Earthworks ED chairing a 501(c)(3) that is fiscally sponsoring federal-worker political organizing is a fiduciary question: what was approved by the board, and on what characterization. Any Schedule I grant from OGAN to Earthworks — should the PDF review of OGAN's 2023 Form 990 Schedule I surface one — would be a related-party transaction required to be disclosed on Part VI, Section A, Line 2.
Parkin is a career protest organizer with more than a decade at Rainforest Action Network and ongoing leadership at Rising Tide North America. He has organized direct-action protests across North America, Europe, and Australia, including Keystone XL actions and a West Virginia protest with the climate scientist James Hansen in which Hansen and thirty others were arrested. Rising Tide North America's methodology is blockade-and-disruption civil disobedience against fossil fuel infrastructure. That tactical vocabulary — blockade, disruption, infrastructure targeting — is now part of the institutional knowledge base OGAN's board brings to its fiscal sponsorship program.
Davies spent over a decade as a campaign director for Greenpeace. She currently serves as Executive Director of Plastic Solutions Fund — another environmental nonprofit — and is married to Scott Parkin. She is on the OGAN board as secretary while running an unrelated environmental fund and while married to another OGAN director. This is the kind of interlocking relationship that IRS Form 990 Part VI, Section A, Line 2 is designed to disclose as a related-party transaction. A well-run 501(c)(3) declares these relationships clearly on every return.
Paz y Miño's background is campaign organizing across a series of left-of-center organizations since the 1990s, including Amnesty International USA and Amazon Watch. As treasurer he is the officer legally responsible for the organization's financial controls — the person who signs off, under penalty of perjury, on the accuracy of the financial representations in the Form 990. Treasurers of fiscal-sponsor nonprofits are in the most exposed position in any Schedule I, Schedule F, or donor-fraud inquiry. That is where the specific accounting representations live.
Breaux came to OGAN from People's Action and the Center for Story-Based Strategy, with prior involvement in 350.org Keystone XL protest organizing. Center for Story-Based Strategy is a messaging and narrative-design consultancy that trains activist organizations in controlling media frames and public perception of their operations. That skill set — building sympathetic narrative architecture around direct-action operations — is itself relevant to how OGAN's fiscal sponsorship of FWAD has been publicly framed.
The common thread across all six is the Keystone XL campaign of the early-to-mid 2010s. Four of the six — Leonard, Parkin, Breaux, and Davies through her Greenpeace portfolio — were operationally involved in the national Tar Sands Action coalition that built the contemporary U.S. civil-disobedience toolkit against fossil-fuel infrastructure. That toolkit is not an abstract academic template. It is a concrete operational playbook: escalation ladders, media coordination, legal-support networks, bail funds, media-framing protocols, arrestable-action choreography. It is the tactical infrastructure behind every major climate protest of the last fifteen years.
That playbook is now being redirected. Not toward Chevron, not toward TransCanada, not toward the Dakota Access pipeline. Toward the federal workforce.
The federal-worker organizing ecosystem is not a single project with a single name. It is a redundant architecture, deliberately distributed across at least two separate fiscal sponsors, that operates under a single methodological framework and targets a single population.
The two backpacks:
This is not an accident of naming. The two operations launched together, use the same operating system, and recruit from the same target population. Their shared methodology traces to the academic work of Erica Chenoweth at Harvard's Nonviolent Action Lab and Maria Stephan at the Horizons Project — co-authors of Why Civil Resistance Works: The Strategic Logic of Nonviolent Conflict — which has been adopted across both Branch4 and FWAD as the doctrinal foundation for translating international civil-resistance methodology into domestic federal-employee organizing.
FWAD itself is a rebrand. Its original name was Federal Workers Against DOGE — a direct reference to the DOGE advisory body within the current administration. The acronym FWAD was preserved through the rebrand. Its X account remains @Fedsagainstdoge. The original domain federalworkersagainstdoge.com still resolves, with an archived capture from July 2, 2025 on the Wayback Machine showing the identical mission language, identical site architecture, and identical operational fingerprint as the current federalworkersfordemocracy.org. The Fired But Fighting newsletter, Issue 9 (June 2025), refers to the organization by its original name in a partner publication.
The rebrand is methodologically instructive. "Federal Workers Against DOGE" names an adversary. "Federal Workers Alliance for Democracy" names an aspiration. The first name tells readers what the organization is actually doing. The second name tells readers what the organization would prefer to be described as doing. The rebrand was a narrative sanitization. The operation underneath it did not change.
Two 501(c)(3) shells, two different upstream foundation donor bases — ACRE's tends to flow from racial-economic-justice philanthropy; OGAN's from climate philanthropy (Schmidt Family Foundation, Arca Foundation, Winslow Foundation) — but the same operational target, the same doctrinal framework, and the same target population of federal employees. If one backpack fails regulatory scrutiny, the other keeps running. It also lets donors with different political sensitivities each route funding into the same operational target without their names touching.
The redundancy is the tell. You do not build two parallel 501(c)(3) backpacks with near-identical names running near-identical programming unless the goal is specifically that each one can survive if the other is pulled under regulatory review.
The April 15 Jitsi call was hosted under FWAD's banner — which is to say, under OGAN's tax-exempt legal personality. The slide deck prescribing Poland/Turkey/Hungary tactics, the Hatch Act module, the electoral task assignments to federal workers — all of it was delivered under OGAN's charitable umbrella. Not Branch4's. Not ACRE's. OGAN's. The fiduciaries legally responsible for that content are Matt Leonard, Jennifer Krill, Scott Parkin, Nicky Davies, Paul Paz y Miño, and Rae Breaux.
On April 21, 2026 — three days before this document surfaced — a federal grand jury in Montgomery, Alabama returned an eleven-count indictment against the Southern Poverty Law Center. The counts: wire fraud, false statements to a federally insured bank, and conspiracy to commit concealment money laundering. The alleged conduct, per the Department of Justice: SPLC raised donor money under its stated civil-rights mission, used approximately $3 million of those funds over nearly a decade to pay informants inside extremist groups without disclosing that use to donors, and set up banking infrastructure through false statements to a federally insured bank in order to conceal the transactions.
The indictment is novel. Legal experts have raised doubts about whether the specific wire-fraud theory survives motion practice. But the architecture of the theory is what matters for OGAN.
Strip the SPLC case to its structural elements and you get this: (1) a 501(c)(3) raised money from donors under one stated purpose, (2) used the money for a different purpose donors were not told about, (3) set up banking infrastructure to move the money in a way that concealed the actual purpose, and (4) made representations to a federally insured bank that were inconsistent with the actual use of the accounts.
Map those four elements onto OGAN, using only public-record evidence:
That is a referral-grade legal theory — not a conviction, not a closing argument, and not a claim that OGAN will be indicted tomorrow. It is a claim that the same structural pattern the Department of Justice is currently testing against SPLC in Montgomery is present here, on the face of a public solicitation document, against a 501(c)(3) whose stated exempt purpose bears no relation to the sponsored project actually being funded, and against a grantmaking history that includes a direct cash grant to a 501(c)(4) political organization whose endorsed candidates are now sitting members of the caucus formed seventy-one days before the coordinated-shutdown call on the FWAD side.
The public-record facts currently support a clean investigative referral package with multiple jurisdictional hooks:
The question is exempt-purpose adherence. Does OGAN's fiscal sponsorship of FWAD exceed the boundaries of its filed charitable purpose? Does the Schedule I on its most recent 990 disclose FWAD at all, and if so, how is it described? Does the Schedule F disclose the foreign-activity structure implied by the published SWIFT rail? Standard EO Division review tools apply.
OGAN is California-registered. The state Attorney General has primary enforcement authority for charitable-purpose deviations under California Corporations Code and the Supervision of Trustees and Fundraisers for Charitable Purposes Act. The Registry has authority to audit, require restated filings, and initiate revocation proceedings.
Jurisdiction over 501(c)(3) regulation and IRS enforcement policy. The fiscal-sponsor shell structure, where climate nonprofits front federal-worker political organizing under undisclosed Schedule I line items, is a category of abuse Congress can hold hearings on regardless of whether DOJ moves.
Jurisdiction over federal elections and federal workforce. The Pompi slide deck, delivered under FWAD's banner and therefore under OGAN's tax-exempt umbrella, is the evidentiary core of the Hatch Act and federal-election-law questions. These committees have both investigative and oversight tools to compel testimony and document production.
OSC enforces the Hatch Act. The written electoral task assignments to federal employees in the Pompi deck — voter registration, GOTV, poll working, election observation, candidate campaigning — are the exact categories of activity OSC investigates when conducted by covered federal employees in their official capacities.
OGAN's principal banking relationships (Beneficial State Bank, Oakland) and principal place of business are in the Northern District. Any SPLC-style donor-fraud or false-statements-to-a-bank theory would venue there. The U.S. Attorney's Office is the referral destination once a predicate is established.
The SWIFT correspondent-bank rail is the element most specifically in FARA's jurisdictional neighborhood. If any portion of international wires received through that rail originates from foreign nationals or foreign entities, and FWAD is engaged in domestic political activity targeting the U.S. federal government, the Foreign Agents Registration Act question is live. FARA does not require foreign-government origin — it requires activity on behalf of a foreign principal, which can include foreign organizations, foreign political parties, and foreign-based individuals. The predicate question is whether foreign money is in the pipe. The SWIFT rail is, at minimum, an invitation for it to be, and OGAN's 2022 Schedule F confirms a $30,000 wire to Europe for "climate campaign" — the reverse direction of flow on the same banking infrastructure.
Every fiscal-sponsor shell story has the same shape. A 501(c)(3) with a respectable stated mission. A sponsored project that uses the shell's tax status without appearing in the shell's public-facing mission. A donor base that believes it is funding the stated mission. A banking infrastructure that converts the shell's tax-exempt standing into an operational funding rail for the sponsored project. A grantmaking pattern that reaches political organizations whose endorsed candidates sit on a Congressional caucus protecting the operation. And a governance structure of fiduciaries who either (a) understand the mismatch and sign the 990 anyway, or (b) do not understand the mismatch and have failed their fiduciary duty of due care.
OGAN is not, on the public record, a malicious organization. Its stated climate mission is real. Its staff genuinely believe in the work they have done for fifteen years on Keystone XL, tar sands, Chevron divestment, and fossil-fuel infrastructure opposition. The problem is not their climate work. The problem is that they have opened their 501(c)(3) as a general-purpose political-organizing shelter whose current tenants are a federal-worker resistance operation (FWAD), a regional political chapter of a McKibben-founded advocacy network (Third Act DC/MD/VA), a climate-emergency mobilization task force, and a grantmaking book that in 2022 included a direct cash grant to Bernie Sanders's 501(c)(4). Their donors, their state attorney general, and the Internal Revenue Service have not been clearly told any of this in the form the disclosure laws require.
The document that surfaced this week solves the central evidentiary problem in most fiscal-sponsor investigations, which is that fiscal-sponsor abuse is usually invisible because the abuse is internal routing. Here, the routing is published. The SWIFT code is published. The memo-line redirect is published. The DAF EIN is published. The stock-transfer coordinates are published. The grantee names on the 2022 Schedule I are published. The caucus roster is published. The endorsement history of Our Revolution is published. Every single step of the chain, from international wire to sitting member of Congress, exists on a piece of paper that the public can read.
Whoever wrote that document wrote it for donors. They did not write it for regulators. But because they wrote it at all, they wrote it for both.