The Pipes

There is a structural difference between a street and a sewer. A street is visible. The cars on it are licensed and titled. The drivers are identifiable. The traffic flows are publicly observable, and disputes about right-of-way are adjudicated in open courts. A sewer is also infrastructure — but it is buried, deliberately. What flows through it is not meant to be seen. The point of the design is that the things flowing through cannot be traced back to where they came from.

The American philanthropic system has both kinds of infrastructure. The publicly visible kind is the conventional foundation — the Ford, the Rockefeller, the MacArthur — whose grant decisions are reported on annual Form 990s, whose grantees are listed by name, whose program officers attend conferences and publish white papers and answer reporters' questions. The sewer is something else. The sewer is the post-2008 architecture of fiscal sponsorship, donor-advised funds, and pass-through nonprofits that has been built, layer by layer, across the past two decades — an architecture in which the original donor is not, as a matter of legal design, identifiable to the public, in which the relationship between the donor and the ultimate grantee is severed by intermediaries, and in which the operational result is that hundreds of millions of dollars per year flow into political and policy advocacy without any disclosure of who paid for it.

This part documents that architecture. The lattice is the staffing. The litigation arm is what the apparatus does. The pipes are what sustains both.

The argument is structural and falsifiable. If the integrated network this series has been documenting is sustained by ordinary philanthropy — wealthy donors making conventional contributions to civil-society organizations whose work they support — then the documentary record will show that ordinary philanthropy is what funds it. Major foundations giving named grants to identified organizations. Individual donors writing checks that appear in 990 filings. Standard 501(c)(3) charitable contributions following the standard 501(c)(3) charitable disclosure regime. If the integrated network is something different — a directorate operating through pass-through structures designed to obscure the relationship between donors and grantees — the documentary record will show that, too.

The documentary record shows the second thing. This part lays out how.

The Path So Far

Part I established the indictment. April 21, 2026. Eleven counts against the Southern Poverty Law Center. Wire fraud, bank fraud, conspiracy to commit concealment money laundering. More than $3 million paid through shell LLCs to informants affiliated with white-supremacist organizations between 2014 and 2023. The Intelligence Project at the operational center of the indicted conduct.

Part II established the operator. Tina Tchen. Three operations across roughly sixty days. The standard Obama-network institutional fixer template.

Part III established the lattice. Five fourth-branch hires across five years at SPLC — Margaret Huang, Ann Beeson, Susan Corke, Jennifer Riley Collins, Josh Bekenstein. A parallel installation at the Anti-Defamation League through Jonathan Greenblatt. A coordinated designator layer simultaneously severed by FBI Director Patel in October 2025.

Part IV established the litigation arm. Marc Elias and Elias Law Group on the civil side. The Soros-funded prosecutor network — Foxx, Krasner, Gascón, Boudin, Gardner, Bragg, Willis — on the criminal side. Two enforcement arms operating outside the constitutional accountability of state legislatures and federal Congress.

Part V, this part, establishes what sustains all of it. The financial infrastructure. The pipes through which billions of dollars per year flow into the integrated network — much of it through structures designed to obscure the relationship between original donors and ultimate grantees. The architecture is not, in the strict legal sense, illegal. It is, on the documentary record, lawful. What it is not is transparent. And the structural argument this part is making is that the lack of transparency is not incidental. It is the point.

What the Pipes Are Built To Do

The analytical problem this part has to solve is the money problem. American campaign-finance law and tax-exempt-organization law together establish a complex but coherent disclosure regime. Federal political committees that engage in election-related activity must report their donors to the Federal Election Commission with full names, addresses, employers, and contribution amounts. State election authorities impose their own disclosure rules on state-level political activity. Tax-exempt organizations under section 501(c)(3) of the Internal Revenue Code must file Form 990 annually with the Internal Revenue Service, listing their major donors, their major grantees, and the broad categories of their expenditures. Tax-exempt organizations under section 501(c)(4) — the "social welfare" category that permits a substantial amount of political and policy advocacy — file similar disclosures, with the notable exception that they are not required to publicly disclose individual donor identities.

That last exception is the seam through which the American philanthropic-political system has been transformed across the past two decades. The Citizens United v. FEC decision in 2010 lifted the ceiling on independent political expenditures by corporations and unions. The post-2010 expansion of dark-money political spending, conducted through 501(c)(4) social-welfare organizations that do not disclose their donors, has been one of the defining political-finance phenomena of the twenty-first century. The first generation of dark-money infrastructure was built on the right — Americans for Prosperity, the Koch network's web of 501(c)(4)s, Crossroads GPS, and the broader conservative donor-class apparatus that the post-2010 decade produced.

The second generation, built largely between 2015 and 2024, has been the progressive analog. It is larger. It is more institutionally consolidated. And, by 2024, it has come to dominate the American philanthropic-political landscape at a scale that the conservative-aligned analog never reached. Politico's characterization of the Sixteen Thirty Fund — the largest single 501(c)(4) in the progressive infrastructure — captures the ironic structural fact that has driven this transformation: that "Democrats and allies have embraced the methods of groups they decried as 'dark money' earlier this decade, when they were under attack from the money machines built by conservatives including the Kochs."

The pipes documented in this part operate within the formal American legal framework. Each entity in the architecture — the for-profit consulting firm, the affiliated 501(c)(3) and 501(c)(4) nonprofits, the donor-advised funds at the major brokerage houses, the legacy foundations — is a lawful actor. Each filing is, so far as is publicly known, an accurate filing. The IRS has not, in any of its public actions, found that any of these entities has violated its tax-exempt status (though the August 2023 IRS complaint against Arabella Advisors, the September 2023 District of Columbia Attorney General investigation, and the November 2025 dissolution of Arabella itself indicate that the regulatory landscape is shifting).

What the architecture produces, at scale, is the routing of money through structures that are designed to make the relationship between original donor and ultimate grantee difficult or impossible to trace. The architecture is the answer to the question of how a small number of identifiable donors and a relatively small number of integrated philanthropic institutions can sustain an apparatus of the size and scope documented in Parts I through IV — without the names of those donors and institutions appearing on the front pages of newspapers or in the campaign-finance disclosure databases that traditional political accountability mechanisms depend on.

The architecture has six layers, each documented in turn in the sections that follow.

Arabella Advisors

Arabella Advisors was a Washington, D.C.-based for-profit consulting firm founded in 2005 by Eric Kessler, a former senior staffer in the Clinton administration's environmental policy office. The firm was structured as a private limited-liability company. Its business model was to provide back-office services — strategic advisory, operational management, accounting, human resources, legal compliance, and grantmaking administration — to a network of affiliated tax-exempt nonprofit organizations under exclusive long-term consulting agreements. The nonprofits, in turn, paid Arabella tens of millions of dollars per year in management fees.

By the time of the firm's November 2025 dissolution, Arabella had built and managed a network of seven affiliated nonprofits — the New Venture Fund, the Sixteen Thirty Fund, the Hopewell Fund, the Windward Fund, the North Fund, the Telescope Fund, and the Impetus Fund — collectively known in the philanthropic-research community as the "seven sisters." Across the eighteen-year span from the founding in 2005 to the dissolution in November 2025, the affiliated nonprofits generated combined revenues of approximately $9.2 billion and made expenditures of approximately $7.8 billion, with at least $200 million paid to Arabella itself in management fees.

The Founder

Eric Kessler graduated from Hamilton College and joined the Clinton White House's environmental policy team in the mid-1990s. He left government service in the early 2000s and founded Arabella in 2005 with seed capital and an initial client list drawn from progressive-aligned philanthropic donors he had developed contacts with during his Clinton administration tenure. He served as Arabella's senior managing director from the founding through 2019. He concurrently served as president and board chair of the New Venture Fund (the largest of the affiliated nonprofits) from 2017 to 2019, and as the New Venture Fund's board secretary through August 2019.

The dual role — for-profit consulting firm principal and 501(c)(3) president of the firm's largest client — is what placed Kessler at the center of the August 2023 IRS complaint filed by the conservative-aligned watchdog organization Americans for Public Trust, and the September 2023 District of Columbia Attorney General investigation that issued subpoenas to six of the affiliated Arabella entities. Both proceedings argued that Kessler's dual role constituted a form of "private inurement" — the IRS-prohibited practice of a tax-exempt organization paying excessive compensation to a related party — and that the long-term exclusive consulting agreements between the affiliated nonprofits and Arabella were not, by IRS standards, arm's-length transactions.

The Fiscal-Sponsorship Model

The structural innovation that made the Arabella architecture possible is fiscal sponsorship — a provision of American tax-exempt-organization law under which a 501(c)(3) public charity can serve as the legal-and-tax umbrella for projects that do not have their own tax-exempt status. The fiscally sponsored project operates under the sponsor's 501(c)(3) determination letter, accepts donations through the sponsor's bank accounts, and is governed by the sponsor's board. In exchange, the sponsor charges the project a fee — typically 7 to 15 percent of the project's annual revenue — and assumes the legal-compliance burden of operating the project within the bounds of 501(c)(3) tax-exempt rules.

The model itself is not new. Tides, the San Francisco-based progressive-aligned grantmaker founded in 1976, pioneered fiscal sponsorship in its modern American form in 1979. What Arabella did, beginning in 2005, was scale the model. By 2024, the New Venture Fund alone was hosting more than 280 fiscally sponsored projects under its 501(c)(3) umbrella, with combined annual budgets in the hundreds of millions of dollars. Each project operated under its own publicly visible name — typically a project of "Floridians for a Fair Shake" or "Michigan Families for Economic Prosperity" or one of the dozens of other state-and-issue-specific trade names that the New Venture Fund and Sixteen Thirty Fund have used — but at the legal-entity level, all of them were the same 501(c)(3). One Form 990. One set of audited financials. Hundreds of projects.

The Dissolution

On November 17, 2025, GlobeNewsWire ran a press release announcing that a new entity, Sunflower Services, had acquired the fiscal-sponsorship business of Arabella Advisors. The press release framed the transaction as a routine corporate restructuring — a "purchase" of the fiscal-sponsorship services line of business from one corporate entity by another. The structural reading is different. The transaction occurred against the backdrop of an active IRS complaint, an active District of Columbia Attorney General investigation, the prior March 2025 briefing of senior White House officials by Capital Research Center on the Arabella network, and the broader regulatory and political environment that had made Arabella's business model substantially riskier than it had been a decade earlier.

Arabella Advisors itself — the for-profit consulting firm, the entity that had collected the $200 million in management fees, the entity Kessler had founded in 2005 — dissolved. The fiscal-sponsorship business survived, transferred to Sunflower Services. The four primary nonprofits — New Venture Fund, Sixteen Thirty Fund, Hopewell Fund, Windward Fund — continued to exist as separate 501(c) entities. The architecture survived; the for-profit firm at its center did not.

What this means for Part V's argument is that the Arabella episode is not a closed historical case. It is a structurally significant moment in the evolution of the philanthropic-political dark-money infrastructure in the United States. The for-profit firm that scaled the fiscal-sponsorship model dissolved under regulatory pressure. The model itself did not.

NVF, Sixteen Thirty, Hopewell, Windward

The four primary nonprofits that Arabella managed — and that Sunflower Services now manages — together constitute what philanthropic researchers refer to as the four-fund cluster. Each fund has a distinct legal structure and operational focus. Together they functioned, under the Arabella corporate parent, as the largest single conduit of progressive-aligned philanthropic and political-advocacy spending in the United States.

New Venture Fund (NVF)

The New Venture Fund was incorporated in October 2006, one year after Arabella's founding, as a 501(c)(3) public charity. It was originally named the Arabella Legacy Fund and was renamed the New Venture Fund in 2007. It is the largest of the four-fund cluster.

For the most recent year for which Form 990 data is available, the New Venture Fund reported gross receipts of approximately $887.4 million on its 2023 IRS filing. It hosted more than 280 fiscally sponsored projects. It paid Arabella Advisors approximately $30 million in management fees in 2021, the most recent year for which complete fee data is available, and the cumulative fees paid to Arabella from 2007 through 2021 totaled more than $228 million across the four funds.

The New Venture Fund's largest institutional donors over the 2018–2022 reporting window, as documented through Capital Research Center's analysis of public 990 filings, included the Bill and Melinda Gates Foundation, the Open Society Foundations (which gave the New Venture Fund $61.9 million across the period), the Ford Foundation (whose grants to the New Venture Fund through 2024 cumulatively exceeded $28 million), and a constellation of additional foundations and high-net-worth donor vehicles. The New Venture Fund served as the fiscal sponsor for projects including the Media Democracy Fund (an Open Society Foundations-supported initiative on internet policy), Governing for Impact (the policy memo and advocacy organization that produced substantial influence on Biden administration regulatory priorities), and dozens of other named projects across environmental, voting-rights, immigration, and health-policy advocacy.

Sixteen Thirty Fund (1630)

The Sixteen Thirty Fund was incorporated in 2009 as a 501(c)(4) social-welfare organization — the tax classification that permits substantial political and policy advocacy and that does not require public disclosure of donor identities. It is the largest single 501(c)(4) in the progressive-political-advocacy infrastructure, and it is the entity at the center of the "dark money" framing that Politico and other mainstream-press outlets have applied to the Arabella network.

In the 2020 election cycle, the Sixteen Thirty Fund spent approximately $410 million on political and election-adjacent activity. In 2022, it spent approximately $196 million. In 2023, an off-year, it raised approximately $181 million. From 2016 through 2024, the fund directed $101.6 million in contributions to 52 state ballot-measure campaigns across 19 states, with a documented success rate (positions on ballot measures that prevailed) of 77.4 percent.

The fund's donor base is, by the structural design of the 501(c)(4) classification, not publicly disclosed in detail. What has been documented through partial disclosure, voluntary reporting, and investigative journalism includes major contributions from Pierre Omidyar (who gave the fund $45 million in 2020 alone), Hansjörg Wyss (the Swiss-born American philanthropist who has channeled funds through the affiliated Berger Action Fund into the Sixteen Thirty Fund and adjacent Arabella entities over multiple years), Michael Bloomberg (who gave $250,000 to a super PAC linked to the Sixteen Thirty Fund), and what OpenSecrets characterized in 2018 as "thirteen multi-million dollar secret donors" — three of whom gave $51.7 million, $26.7 million, and $10 million respectively in that single year.

Hopewell Fund and Windward Fund

The Hopewell Fund and Windward Fund are smaller but structurally analogous 501(c)(3) public charities, also managed under the Arabella umbrella. The Hopewell Fund was created to host newer fiscally sponsored projects, particularly in health-related and women-focused advocacy. The Windward Fund was founded in 2015 with an environmental and climate focus.

Open Society Foundations gave the Hopewell Fund $16.8 million and the Windward Fund $4 million across the 2018–2022 reporting window. The Bill and Melinda Gates Foundation committed $6 million to the Windward Fund in 2023, the bulk earmarked for methane-emissions-reduction advocacy.

The Structural Pattern

The four-fund cluster operates as a single integrated philanthropic-and-political-advocacy apparatus. The 501(c)(3) funds (NVF, Hopewell, Windward) accept tax-deductible contributions and conduct charitable and educational work. The 501(c)(4) fund (Sixteen Thirty) accepts non-tax-deductible contributions and conducts political and policy advocacy. Donors who want to support an issue area can make tax-deductible contributions to the (c)(3) side and political contributions to the (c)(4) side, with the operational coordination between the two managed by the same shared administrative infrastructure (formerly Arabella, now Sunflower Services).

The ProPublica-and-OpenSecrets-documented practical effect is that the boundary between charitable activity and political activity — a boundary the IRS has long treated as legally significant for tax-exempt-organization purposes — operates, in the Arabella architecture, as a procedural rather than an operational line. The same donors fund both sides. The same infrastructure manages both sides. The same projects can move, by routine internal restructuring, from the (c)(3) side to the (c)(4) side as the political environment changes.

This is the structure that Open Society Foundations has channeled $153.5 million into across 2018–2022 — divided as $61.9 million to NVF, $70.7 million to Sixteen Thirty, $16.8 million to Hopewell, and $4 million to Windward. It is the structure that has, as a documented matter, sustained substantial portions of the litigation arm and the prosecutor-funding network documented in Part IV.

Open Society Foundations

The Open Society Foundations is George Soros's grantmaking institution. It is the largest single private philanthropic funder of progressive-aligned civil-society work in the United States and globally. As of 2024, the institution reported total assets exceeding $25 billion and had expended more than $24.2 billion in grants since its 1993 founding.

The institution's structure has shifted substantially across the past three years, in ways that matter for the structural argument this part is making.

The 2017 Transfer and the Renaming

In 2017, Soros transferred $18 billion from his personal wealth into the philanthropic institution. The transfer made what was then called the Open Society Institute one of the largest American philanthropies overnight, and it concentrated in a single family-controlled grantmaking institution a quantity of philanthropic capital comparable in size to the Ford Foundation.

In 2020, the Open Society Institute was renamed the Open Society Foundations. The renaming was framed publicly as an organizational consolidation; the structural significance was that the shift to "foundations" (plural) reflected the increasingly federated nature of the OSF grantmaking network, with regional and program-specific foundations operating under a unified board.

The 2022–2024 Transition

In December 2022, Alex Soros — George Soros's 37-year-old son — was elected chair of the OSF board. He succeeded his father, who remained involved as founder but transferred operational governance to Alex.

In June 2023, the OSF board approved layoffs of at least 40 percent of its 800 international staff, along with the closure of multiple regional offices — particularly in Europe and Africa, where OSF had spent more than $209 million in 2021 alone. The layoffs were framed as a strategic shift toward larger, more focused grants to a smaller number of institutional grantees, rather than smaller grants to a larger number of regional civil-society organizations.

Mark Malloch-Brown, the British diplomat who had served as OSF president from January 2021 through June 2024, stepped down. On March 11, 2024, OSF announced that Binaifer Nowrojee — a Kenyan-Indian human-rights lawyer who had served at OSF for twenty years and most recently as vice president of programs — would succeed Malloch-Brown as president, beginning June 1, 2024. She is the first woman from the global South to lead OSF.

In July 2024, OSF announced that the multi-year reorganization was substantively complete, and committed $400 million over eight years to "green economic development" as the institution's first major post-reorganization grantmaking initiative. As part of the reorganization, OSF distributed $300 million in final grants to organizations whose ongoing funding from OSF was being terminated.

The U.S. Programs and the Structural Implication

The OSF U.S. Programs portfolio — the grantmaking arm responsible for OSF's domestic American funding, which is the relevant arm for this series — was confirmed in OSF's August 2023 internal communications to be exempt from the 40 percent international staff layoffs at least until March 2025, after the November 2024 American presidential election. The roughly 60 OSF employees in the U.S. Programs office continued operating through the election cycle without significant staff disruption.

This is the layer that funded the integrated network documented in Parts I through IV. The grant from OSF U.S. Programs to the Southern Poverty Law Center for Voting Rights work (documented in Part III as part of the Beeson vertical's funding base). The grant pattern that supported the Soros prosecutor network's electoral cycle infrastructure. The grant flows to the Arabella four-fund cluster — $153.5 million across 2018–2022. The grant flows to the Tides infrastructure — $17.8 million in 2022–2023. The grant flows to dozens of additional litigation, advocacy, and journalism organizations across the integrated progressive-civil-society ecosystem.

The reconstituted OSF board, as of late 2023, had seven members: Alex Soros (chair), his half-sister Andrea Soros Colombel, his stepmother Tamiko Bolton Soros (George Soros's wife), Maria Cattaui (a veteran international business nonprofit leader), Ivan Krastev (a Bulgarian political analyst and think-tank chair), Daniel Sachs (a Swedish financier), and Mark Malloch-Brown (continuing in a transitional capacity). The structural significance of the seven-member board is that operational governance of OSF's $25 billion philanthropic apparatus is concentrated in a small number of family members and longtime advisors — a concentration that Inside Philanthropy noted explicitly when it characterized the new board structure as leaving OSF "in the hands of a small circle of family members and longtime advisors."

The Russia-India-Pakistan Banning and the Structural Counter-Pattern

The OSF's grantmaking is not uniformly accepted around the world. In November 2015, Russia banned the Open Society Foundations and the Open Society Institute Assistance Foundation from operating in its territory, with the Russian government formally declaring that "the activity of the Open Society Foundations and the Open Society Institute Assistance Foundation represents a threat to the foundations of the constitutional system of the Russian Federation and the security of the state." In 2016, India's Ministry of Home Affairs placed OSF on a watchlist forbidding it from extending financial assistance to other Indian NGOs or individuals without prior explicit permission. In 2017, the government of Pakistan ordered OSF to cease operations in the country.

These are not, in this part's analytical frame, endorsements of the Russian, Indian, or Pakistani governments' broader treatment of civil society. They are, however, documentary evidence of a structural reality: that the Open Society Foundations' grantmaking is, in the domestic political contexts of multiple countries, treated as an external political-advocacy actor whose operational profile triggers state-level regulatory responses analogous to those that have, in the post-2023 period, begun to be applied to similar political-advocacy actors in the American context.

The Through-Line to Part III's Beeson Vertical

The Open Society Foundations grantmaking universe is the financial pipe that runs most directly through the lattice documented in Part III. Ann Beeson — the Chief Program Officer at SPLC from 2021 through her resignation, and the Open Society Institute U.S. Programs Vice President for six years (2002–2008) before her SPLC tenure — is the personnel embodiment of the OSF-to-SPLC routing the structural argument depends on. The grantmaking decisions Beeson supervised at OSI in the 2000s established the institutional relationships between OSI and the dozens of progressive litigation, voting-rights, and policy organizations whose work the post-2020 SPLC then operationalized through the lattice this series has been documenting.

OSF's U.S. Programs portfolio funded the institutions Beeson then went to staff and lead. The personnel circulation and the financial circulation were, in operational terms, the same circulation. Part III documented the personnel side. Part V is documenting the financial side.

Ford, Rockefeller, Hewlett, MacArthur, Carnegie

The Open Society Foundations, for all its scale and political prominence, is not the largest single American philanthropic institution. Several of the legacy progressive foundations — Ford, Hewlett, MacArthur, Rockefeller, Carnegie — operate at comparable or greater scale, and several of them have been giving to progressive-aligned civil-society infrastructure for decades longer than OSF.

Ford Foundation

The Ford Foundation was established in 1936 by Edsel Ford and Henry Ford with the original Ford Motor Company stock that diversified the family fortune. For most of the second half of the twentieth century, the Ford Foundation was the largest private foundation in the United States by endowment.

For fiscal year 2024, Ford reported assets of $17.5 billion and expenses of $1.04 billion. The expenses figure — $1.04 billion in a single fiscal year — places Ford in a category of philanthropic giving that no individual donor and few institutional foundations approach. Ford's grantmaking under president Darren Walker (2013–2025) shifted substantially toward what Walker characterized in a 2015 New York Times op-ed as "not only generosity, but justice" — a programmatic frame that made Ford the single largest private philanthropic funder of progressive civil-society infrastructure in the United States across the 2014–2024 decade.

By 2024, conservative philanthropic researchers had documented Ford's grantmaking running at approximately $20 million per month into progressive-aligned advocacy organizations — a pace of nearly $700,000 per day. Ford's grants in the relevant window included $28.1 million to the New Venture Fund (across 18 separate grants), $24.6 million to Rockefeller Philanthropy Advisors, $10.8 million to the Amalgamated Charitable Foundation (the SEIU-linked charitable arm), $3.4 million to the Center for American Progress, and a long list of additional grants to progressive-aligned organizations across the litigation, advocacy, and journalism portfolios.

Rockefeller Foundation

The Rockefeller Foundation was established in 1913 by John D. Rockefeller. It currently reports an endowment of approximately $4 billion.

Rockefeller's grantmaking has been less politically charged than Ford's in the post-2014 period, but the foundation has nonetheless been a significant funder of the integrated network this series has documented. Rockefeller gave the Tides Foundation $50 million across 2022–2023, supporting Tides' progressive-aligned grantmaking and fiscal-sponsorship operations. Rockefeller has also been a significant funder of community-violence-intervention initiatives and of the broader criminal-justice-reform infrastructure that informs the progressive-prosecutor policy framework documented in Part IV.

Hewlett, MacArthur, Carnegie

The William and Flora Hewlett Foundation reports an endowment of approximately $14 billion. The John D. and Catherine T. MacArthur Foundation reports an endowment of approximately $6.3 billion (some recent estimates place it at $8 billion). The Carnegie Corporation of New York reports an endowment of approximately $4 billion.

Each of these foundations has been a substantial funder of progressive-aligned civil-society infrastructure across the past decade. MacArthur, in particular, has made what the foundation publicly characterizes as "big bets" on criminal-justice reform and climate-change advocacy — programmatic categories that have channeled substantial MacArthur grantmaking into the broader institutional progressive-prosecutor and progressive-litigation networks. Hewlett has supported election-administration research, voting-rights litigation, and the broader infrastructure of progressive-aligned election-policy advocacy.

The May 2025 Coalition

In May 2025, the Wall Street Journal reported that the Ford Foundation, the MacArthur Foundation, the Bill and Melinda Gates Foundation, the Charles Koch Foundation, and the Council on Foundations had begun to informally coordinate strategy on the question of how to respond to potential Second Trump administration regulatory action against tax-exempt-organization status. The reporting was significant because it documented, for the first time in a mainstream-press venue, the explicit institutional coordination among the largest American philanthropies — across, notably, both the progressive-aligned (Ford, MacArthur, Gates) and the conservative-aligned (Koch) sides of the foundation universe — in response to perceived regulatory pressure on the philanthropic sector as a whole.

The Original Pioneer

The Tides infrastructure is older than Arabella, smaller than Open Society, and structurally more decentralized than either. It is the original American architecture for fiscal-sponsorship-based progressive-civil-society funding, and it is the architectural template that Arabella subsequently adapted, scaled, and (in some structural respects) consolidated.

Tides was founded in 1976 by Drummond Pike, a California political activist who had previously worked at the Youth Project — a Washington-based grantmaking organization that channeled funds from young wealthy donors to progressive-aligned causes. Pike's founding seed funding came from Jane Bagley Lehman, the granddaughter of R.J. Reynolds (the tobacco industrialist) and a former president of the progressive-aligned Arca Foundation. Lehman served as Tides' chair from 1976 until her death in 1988; Pike served as chief executive officer until 2010.

In 1979, Pike extended Tides' operations to include fiscal sponsorship — using Tides' 501(c)(3) status as the legal-and-tax umbrella under which new progressive-aligned political and policy organizations could fundraise and operate before achieving their own IRS recognition. The model was a deliberate alternative to the conventional foundation form. Where conventional foundations gave grants from their own endowments to existing tax-exempt grantees, Tides provided the tax-exempt umbrella that allowed entirely new organizations to operate without going through the years-long IRS recognition process. The result, by the 2020s, had been the incubation under Tides of more than 1,400 distinct progressive-aligned political and policy organizations.

The Five-Entity Structure

Tides is currently organized as five legally distinct 501(c)(3) entities operating under shared coordination. The Tides Network is the home-office entity — the corporate parent that provides shared administrative services, executive leadership, financial management, legal compliance, and human-resources support to the operating entities. The Tides Foundation is the grantmaking entity, managing over 400 donor-advised funds. The Tides Center is the fiscal-sponsorship entity, providing the 501(c)(3) tax-exempt umbrella under which approximately 90 fiscally sponsored projects currently operate, with a standard fee of 9 percent of project annual revenue (6 percent above $1 million; 15 percent on government grants). Tides, Inc. and the Tides Two Rivers Fund are smaller adjacent entities supporting specific programs.

In 2024, the combined six Tides 501(c)(3) entities (the five plus the affiliated 501(c)(4) Tides Advocacy) reported $785.6 million in revenue, $905.7 million in expenses, and $784.3 million in net assets. The Tides Foundation alone made $442.5 million in grants in 2024 — $395 million to domestic recipients and approximately $47 million to undisclosed foreign recipients. The Tides Foundation gave $28.1 million to the affiliated 501(c)(4) Tides Advocacy in 2024, which represented 30 percent of Tides Advocacy's total revenue for the year.

The High-Profile Fiscally Sponsored Projects

Tides' fiscally sponsored project portfolio includes projects whose names recur throughout the integrated network this series has documented. Among them: the Black Lives Matter Global Network Foundation (transferred to the Tides Center from Thousand Currents in July 2020); Palestine Legal; Fair and Just Prosecution (the operational hub for the progressive-prosecutor network documented in Part IV); the Kairos Center; the Alliance for Global Justice; the Arab Resource and Organizing Center.

The structural significance of this project list, for purposes of this series, is that the Tides infrastructure is one of the operational pipes through which the integrated network's institutional projects — including projects directly relevant to the litigation arm and the criminal-prosecution arm documented in Part IV — receive their administrative and financial-back-office support.

The Tides infrastructure is funded by substantially the same donor and institutional-funder universe documented in the preceding sections of this part. Open Society Foundations gave Tides $17.8 million across 2022–2023. The Rockefeller Foundation gave $50 million across 2022–2023. The Bill and Melinda Gates Foundation gave $30 million across 2022–2023. The pattern that emerges, when the major-funder data is examined across Arabella, Open Society, Ford, Rockefeller, Hewlett, MacArthur, and Tides, is that the same constellation of donors and institutional funders appears, at scale, across multiple pipes. This is what the structural argument means by "directorate." The entities are legally distinct. The grantmaking is operationally coordinated. The donor base, at the largest contribution levels, is substantially overlapping.

The $326 Billion Anonymizing Pipe

The donor-advised fund is the third major architectural innovation in the post-2010 American philanthropic landscape. The donor-advised fund is a 501(c)(3) public charity affiliated with a for-profit financial-services firm — Fidelity Charitable, Schwab Charitable (now branded as DAFgiving360), Vanguard Charitable, and the Goldman Sachs Philanthropy Fund being the four largest — that accepts donor contributions, invests them, and disburses them to ultimate grantees at the donor's direction.

The structural innovation that distinguishes the DAF from the conventional charitable-trust or private-foundation form is that the DAF disburses to ultimate grantees in the name of the DAF — not in the name of the original donor. A grant from a Fidelity Charitable account to a 501(c)(3) advocacy organization is reported, on that organization's Form 990, as a grant from "Fidelity Investments Charitable Gift Fund" — not as a grant from the individual donor whose contribution to the DAF originally funded it. The donor is identifiable only to Fidelity Charitable's internal records.

The IRS does not require DAF sponsors to disclose individual donor identities to the public. The architecture is, by deliberate legal design, an anonymizing pipe. Critics characterize it as the largest single mechanism in the American philanthropic system through which charitable contributions can be made anonymously to politically charged advocacy organizations.

The Scale

As of 2024, total DAF assets in the American philanthropic system reached $326 billion. Annual disbursements from DAFs to ultimate grantees totaled $64.9 billion. DAF assets, at the institutional-class level, now exceed the combined assets of the Ford, Rockefeller, Hewlett, MacArthur, and Carnegie foundations.

Fidelity Charitable, established in 1991 and the first national DAF program, is the largest single American grantmaker — public or private. Fidelity Charitable held $48.3 billion in assets as of June 2022 and granted $11.8 billion in 2023, $14.9 billion in 2024 (a 25 percent year-over-year increase), and a record $18.3 billion in 2025 (a further 23 percent increase). Fidelity Charitable's lifetime grantmaking, since its 1991 founding, exceeds $84.5 billion to more than 406,000 organizations.

Schwab Charitable / DAFgiving360 held $26.4 billion in assets as of June 2022. Vanguard Charitable held approximately the same. Together, the three DAFs disbursed an estimated $50 billion or more annually as of 2024 — more than 10 percent of all American charitable giving.

The DAF-to-DAF Transfer Phenomenon

A structurally significant feature of the DAF architecture is what philanthropic researchers have begun documenting as the DAF-to-DAF transfer phenomenon. In 2023, $4.4 billion moved from one DAF provider to another — up from $1 billion in 2019, an increase of 200 percent across the four-year period.

The transfer phenomenon is structurally significant because it complicates the traditional understanding of what a donor's "contribution" to a DAF means. In the DAF-to-DAF transfer pattern, donors instead recommend that their DAF transfer assets to a different DAF — typically because the recipient DAF offers different investment options, lower fees, more international grant capability, or alignment with the donor's values. The transfer pattern has the operational effect of further obscuring the relationship between original donor and ultimate grantee. A contribution that begins at Fidelity Charitable, transfers to a community-foundation DAF, transfers again to a sectoral DAF, and is finally disbursed to a 501(c)(3) advocacy organization, has — by the time of the final disbursement — lost any visible connection to the original donor.

The DAF infrastructure is, in this respect, the most architecturally pure example of the structural critique this part is making. Each DAF is a lawful 501(c)(3) public charity. Each disbursement is a lawful charitable grant. Each donor, internally to the DAF, is identified. Each receiving organization is, on its Form 990, accurately identified. What the architecture as a whole produces is a system in which $326 billion of American philanthropic assets — more than 10 percent of all American philanthropic giving — flow through structures that, by deliberate legal design, sever the relationship between original donor and ultimate grantee from the public record.

That is the pipe.

Where the Money Goes

The preceding sections have documented the source pipes — the foundations, the DAFs, the fiscal-sponsorship architectures. This section documents the flow into the integrated network whose lattice and litigation arm Parts III and IV established.

The Southern Poverty Law Center, the institution at the center of the federal indictment that opened this series, reported total assets of $822 million as of its most recent fiscal year. Its endowment — composed primarily of board-designated funds to support future work — stood at $731.9 million. Importantly, SPLC's own published financial-information page states explicitly: "No government funds are received or used for its efforts." The entire SPLC operation, the institution at the center of the integrated fourth-branch apparatus this series has been documenting, runs on private philanthropic contributions.

The SPLC Funding Profile

The SPLC's specific donor disclosures, on its annual Form 990 and in its publicly available impact reports, identify a recurring donor base that includes Open Society Foundations (a substantial multi-year grantmaking relationship through OSF U.S. Programs, the portfolio Beeson oversaw at OSI from 2002 to 2008 before her transition to SPLC in 2021); the Ford Foundation (recurring grants in the multi-million-dollar range across the post-2014 decade); the MacArthur Foundation (recurring grants supporting voting-rights and criminal-justice work); Bain Capital, the private-equity firm whose co-chairman Joshua Bekenstein was vice-chair of the SPLC board through Tchen's tenure and beyond; and major-brokerage donor-advised funds at Fidelity, Schwab, and Vanguard, whose specific original-donor identities are, by the structural design of the DAF infrastructure, not publicly traceable.

The funding base, at the institutional level, is the same institutional base documented in the preceding sections of this part. The personnel routing documented in Part III's lattice runs through the funding routing documented here.

The Litigation-Arm Funding

The litigation arm documented in Part IV runs on parallel funding pipes. Elias Law Group is a private law firm whose billing model is conventional — its clients (the Democratic National Committee, the DSCC, the DCCC, the DGA, the DAGA, individual Democratic candidates and officeholders) pay legal fees through the standard professional-services billing process. But the broader litigation infrastructure that Elias's firm coordinates with — the SPLC's Voting Rights Practice Group, the NAACP Legal Defense Fund, the ACLU Voting Rights Project, and adjacent organizations — is funded through the philanthropic pipes documented above.

The Soros prosecutor network's electoral funding runs through Justice & Public Safety PAC and the affiliated Color of Change PAC. The cumulative outside-spending figure across prosecutor races from 2016 through 2024 — the estimated $40 million-plus documented in Part IV — flowed substantially through this PAC vehicle.

The structural distinction between the prosecutor-funding side and the rest of the network's funding is that PAC vehicles operate under the federal political-disclosure regime, not the philanthropic regime documented in this part. Soros's PAC contributions are publicly visible in FEC filings. His OSF grants to civil-society advocacy organizations are publicly visible (in less granular detail) in OSF's annual reports. What is not publicly visible — and what the architecture of this part is documenting — is the relationship between the OSF philanthropic pipe and the PAC political-finance pipe at the donor level. The two pipes are legally distinct. They serve operationally complementary functions. And they are, at the donor level, the same donor.

That coordination — between philanthropic giving and political-finance contribution, conducted by the same donors at the same time, structured to maintain the legal separation between (c)(3) charitable activity and explicit political activity — is the operational mechanism through which the integrated network is sustained. The pipes are formally distinct. Operationally, they are one pipe.

The Directorate Argument

The structural argument this part has built across Sections III through IX can be stated in compact form.

The integrated fourth-branch network this series has documented — the SPLC and ADL designator layer, the Elias Law Group civil-litigation arm, the Soros-funded prosecutor network, the federal enforcement interface that operationalizes the apparatus's outputs — is sustained by a financial infrastructure that runs through six interlocking pipes:

• The Arabella four-fund cluster (now operating under Sunflower Services after Arabella's November 2025 dissolution): roughly $1.2 billion in 2023 alone, $9.2 billion across 2006–2023, with the New Venture Fund hosting more than 280 fiscally sponsored projects under a single 501(c)(3) determination letter that severs the donor-grantee relationship from public reporting.
• The Open Society Foundations: $25 billion in assets, $24.2 billion in cumulative grants since 1993, $1.3 billion in 2022 grantmaking alone, with operational governance now consolidated in a seven-member board dominated by the Soros family and longtime advisors.
• The legacy progressive foundations — Ford ($17.5 billion in assets, $1.04 billion in 2024 expenditures), Hewlett ($14 billion), MacArthur ($6.3 billion), Rockefeller ($4 billion), Carnegie ($4 billion) — whose institutional grantmaking, particularly Ford's $20-million-per-month pace into progressive-aligned advocacy, sustains the broader civil-society infrastructure on which the integrated network's operational organizations depend.
• The Tides infrastructure: five legally distinct 501(c)(3) entities, $785.6 million in 2024 combined revenue, more than 1,400 fiscally sponsored progressive-aligned organizations across the 1976–2024 period.
• The donor-advised-fund infrastructure at the major commercial brokerages — Fidelity Charitable ($48.3 billion AUM), Schwab Charitable ($26.4 billion AUM), Vanguard Charitable (similar scale): $326 billion in collective assets as of 2024, $64.9 billion in annual disbursements, and an architecture that, by deliberate legal design, severs the relationship between original donor and ultimate grantee at the level of public Form 990 reporting.
• The political-action-committee infrastructure — Justice & Public Safety PAC, Color of Change PAC, and the broader vehicle universe through which the same donors who fund the philanthropic pipes also fund the criminal-prosecution arm documented in Part IV.

What these six pipes produce, in cumulative annual flow, exceeds $10 billion per year into the integrated progressive-civil-society infrastructure — not counting the assets-under-management figures, which exceed $400 billion across the cluster of major foundations and DAFs documented in this part. The flow is sustained, at the donor level, by a relatively small number of identifiable institutional and individual funders whose names recur, in different combinations, across the major-funder lists of every entity in the network. The result is what the structural argument means by directorate: a coordinated institutional class operating through legally distinct but functionally integrated pipes, whose operational effect is to sustain an apparatus of effective governance that the elected branches at the federal and state levels did not, in any direct sense, authorize.

This is the financial answer to the structural problem Part IV identified at the legal-and-political level. The litigation arm is what the lattice does. The pipes are what sustains both. And the pipes, taken together, constitute the largest single concentration of politically directed philanthropic capital in American history.

The Strongest Defenses, Engaged Directly

The structural critique made in this part has obvious vulnerabilities. The strongest defenses available to it deserve direct engagement.

Philanthropic giving is constitutionally protected. True, and the argument here is not that any individual donor's grantmaking decision, or any individual foundation's institutional grantmaking, is unlawful or improper. The argument is that the systematic deployment of philanthropic capital across an integrated network of pipes — fiscal-sponsorship architectures, donor-advised funds, 501(c)(4) social-welfare organizations, and political action committees — by a substantially overlapping donor class, with operational coordination across the pipes, represents a different phenomenon from the historical model of American philanthropy. And that the difference matters constitutionally because the operational effect of the coordination is the financial sustenance of an apparatus that produces effective state action without electoral accountability.

Donor anonymity is a long-standing feature of American philanthropy and serves legitimate purposes. True, in many cases. Donors give anonymously for reasons including religious conviction, personal humility, and the desire to avoid harassment of family members or business associates. The argument is not that anonymity per se is improper. The argument is that when anonymity is combined with operational coordination across legally distinct pipes, with substantial political and policy effect, the cumulative result is a system in which the public and the elected branches cannot, as a matter of practical political accountability, identify who is funding the apparatus that is producing effective state action. The legitimate-anonymity argument applies to individual donors. It does not adequately address the structural-coordination problem.

Conservative-aligned philanthropy operates through analogous structures. True, and acknowledged. DonorsTrust on the conservative side, the Charles Koch Foundation, the Mercer-affiliated philanthropic infrastructure, the State Policy Network of conservative state-level think tanks — each has its own dark-money architecture, its own fiscal-sponsorship pipes, its own DAF-routing patterns. The DeSmog investigation documenting the three commercial DAFs' $171 million flow to Project 2025-affiliated organizations is one documented example. The structural critique made in this series does not require that the fourth-branch phenomenon exist only on one side of the American political spectrum. It requires that the phenomenon exist, that it be documentable, and that it warrant scrutiny. The reader who concludes from this series that an analogous investigation of the conservative-aligned philanthropic-political infrastructure would also warrant publication has, in this author's view, drawn a defensible conclusion.

The Arabella dissolution proves that the regulatory system is working. Possibly true, in a partial sense. The November 2025 dissolution of Arabella Advisors, conducted under the regulatory pressure of the IRS complaint, the District of Columbia Attorney General investigation, and the broader political environment, does represent a meaningful regulatory response to one specific structural feature of the dark-money architecture. The dissolution does not, however, constitute a structural reform of the underlying fiscal-sponsorship-and-DAF architecture, which continues to operate. Sunflower Services has acquired the fiscal-sponsorship business. The four primary nonprofits continue to exist. The architecture survived; the for-profit consulting firm at its center did not. The structural problem the architecture produces remains.

The integrated network's grantmaking supports legitimate civil-society work. Possibly true, in many specific instances. The grants supporting voting-rights litigation under the Voting Rights Act, the grants supporting criminal-justice-reform research, the grants supporting environmental-policy advocacy, the grants supporting educational and journalistic work — each of these, taken individually, may represent legitimate philanthropic support for legitimate civil-society activity. The argument is not that any individual grant is improper. The argument is structural: that the cumulative effect of the integrated network's grantmaking, operating through pipes that obscure the donor-grantee relationship at scale, produces a system of effective governance through private philanthropic-and-political coordination rather than through the constitutional accountability mechanisms of the elected branches. Both questions — whether individual grants serve legitimate purposes, and whether the cumulative architecture produces a structural problem — can be asked. Both deserve clear-eyed examination. This part is asking the second.

Where This Part Ends

The object of this part has been to establish, with the documentary record, that the integrated fourth-branch network documented in Parts I through IV is sustained by a financial infrastructure of identifiable scale, structure, and donor base — and that the infrastructure is designed, in its key architectural features, to obscure the relationship between original donors and ultimate grantees from the public record.

A few facts should now be present in the mind simultaneously.

• November 17, 2025: Arabella Advisors, the Washington for-profit consulting firm founded by Eric Kessler in 2005, dissolved. Its fiscal-sponsorship business was acquired by Sunflower Services. The firm's cumulative revenue across the 2006–2023 period totaled approximately $9.2 billion, with $200 million-plus in management fees paid to Arabella by the affiliated nonprofits.
• September 2023: The District of Columbia Attorney General opened an investigation into Arabella Advisors and six of the affiliated nonprofits. August 15, 2023: Americans for Public Trust filed a formal complaint with the IRS against Arabella's founder Eric Kessler personally.
• December 2022: Alex Soros was elected chair of the Open Society Foundations board, succeeding his father George Soros. The reconstituted seven-member board included three Soros family members and four longtime Soros-network advisors.
• June 2023: The OSF board approved layoffs of at least 40 percent of the institution's 800 international staff, along with multiple regional office closures.
• June 1, 2024: Binaifer Nowrojee, a Kenyan-Indian human-rights lawyer who had served at OSF for twenty years, succeeded Mark Malloch-Brown as OSF president. She is the first woman from the global South to lead OSF.
• As of 2024: The Open Society Foundations reported total assets of $25 billion and cumulative grants since 1993 exceeding $24.2 billion. OSF's grantmaking flowed, across the 2018–2022 reporting window, to the Arabella four-fund cluster ($153.5 million), the Tides Foundation ($17.8 million in 2022–23), and dozens of additional integrated-network organizations including the Southern Poverty Law Center.
• As of fiscal year 2024: The Ford Foundation reported assets of $17.5 billion and expenses of $1.04 billion. Ford's grantmaking ran at approximately $20 million per month into progressive-aligned advocacy organizations.
• The legacy progressive foundations together — Ford ($17.5B), Hewlett ($14B), MacArthur ($6.3B), Rockefeller ($4B), Carnegie ($4B) — controlled assets exceeding $45 billion.
• As of 2024: The Tides Network's six combined 501(c)(3) entities reported $785.6 million in revenue and $905.7 million in expenses. The Tides Foundation made $442.5 million in grants — $395 million to domestic recipients and $47 million to undisclosed foreign recipients. The Tides Center hosted approximately 90 fiscally sponsored projects, including Black Lives Matter Global Network Foundation, Palestine Legal, Fair and Just Prosecution, and the Kairos Center.
• As of 2024: Total American donor-advised-fund assets reached $326 billion, with $64.9 billion in annual disbursements. Fidelity Charitable, the largest single American grantmaker, granted $14.9 billion in 2024 and a record $18.3 billion in 2025. The three largest commercial DAFs together — Fidelity, Schwab/DAFgiving360, and Vanguard — disbursed an estimated $50 billion or more annually.
• The DAF-to-DAF transfer phenomenon: $4.4 billion moved from one DAF provider to another in 2023, up from $1 billion in 2019 — an architectural feature that further obscures the relationship between original donor and ultimate grantee.
• October 2024: The DeSmog investigation documented that across 2020–2024, the three largest commercial DAFs collectively channeled $171 million to 68 nonprofits affiliated with Project 2025 — Fidelity $82 million, Schwab $54.1 million, Vanguard $28.8 million.
• The Southern Poverty Law Center reported total assets of $822 million as of its most recent fiscal year, with an endowment of $731.9 million. SPLC's own published financial information states that "no government funds are received or used for its efforts." The institution at the center of the integrated fourth-branch apparatus this series has documented runs entirely on private philanthropic infrastructure.
• The pipes documented in this part — Arabella, Open Society, the legacy foundations, Tides, the donor-advised funds, and the political-action-committee infrastructure — operate through legally distinct but functionally integrated structures, sustained by a substantially overlapping donor base, producing in cumulative annual flow more than $10 billion per year into the integrated progressive-civil-society infrastructure.
• The structural problem the architecture produces is not the unlawfulness of any individual entity or transaction. The structural problem is the cumulative effect: a system of effective governance sustained through private philanthropic-and-political coordination, operating outside the constitutional accountability mechanisms of the elected branches, with the relationship between original donor and ultimate grantee severed from the public record by the deliberate legal design of the architecture.

The pipes are the financial spine of the fourth branch. They sustain the lattice. They sustain the litigation arm. They have, across the past two decades, enabled the construction of the largest single concentration of politically directed philanthropic capital in American history.

But the pipes do not, in the political-finance sense documented in Part IV's prosecutor-funding analysis, directly underwrite the most consequential political-finance flows of the post-Citizens United decade. There is one further mechanism — distinct from the philanthropic pipes documented in this part, operating under different legal regimes and disclosure rules — through which the integrated network's political-finance side has operated at maximum scale.

That mechanism is the conduit. ActBlue. The Joint Committee Part II report. The 146 Fifth Amendments. The Iran, Russia, Venezuela, and China nexus that the November 2024 House Joint Committee report documented. The Wallace-Jones background. Coming next.