The Conduit

The pipes documented in Part V are infrastructure of one specific kind. They are multi-directional, multi-purpose, regulated under the tax-exempt-organization regime, and designed — in their key architectural features — to obscure the relationship between original donor and ultimate grantee at the level of public reporting. The pipes are what sustains the fourth branch.

The conduit is something different. A conduit is a single-purpose funnel, oriented in a single direction, regulated under a different legal regime, and designed to move a single category of dollars — political dollars — from many small contributors to many candidate-and-committee recipients at maximum velocity and minimum friction.

The American conduit, on the progressive side of the political spectrum, is ActBlue. It has been the conduit since its founding in June 2004. It has processed more than $19 billion in political contributions across the twenty-two years between the founding and the most recent reporting period. In the 2024 election cycle alone, it processed approximately $3.82 billion for Democratic candidates and progressive causes. In the first quarter of 2026, it processed an additional $568 million. No comparable infrastructure exists in American political-finance history. ActBlue is, by every available metric, the largest and most consequential online political-fundraising platform ever built.

It is also, as of the April 20, 2026 release of the second House joint interim staff report on the platform, the subject of one of the most concentrated congressional investigations into a single political-finance entity in the post-Watergate era. Five of its own current and former lawyers and compliance officers, when deposed by three House committees between July and December 2025, invoked the Fifth Amendment in response to every substantive question — for a total of one hundred forty-six times. Its own outside counsel, the Washington law firm Covington & Burling, sent the platform two memos in February 2025 warning that its chief executive officer, in a 2023 letter to Congress, may have "misled" the House Administration Committee about the platform's foreign-donor screening procedures. By March 2025, every member of ActBlue's legal and compliance team had resigned, been fired, or been placed on extended leave.

President Trump on April 24, 2025 directed the Department of Justice to investigate the platform for "straw" and foreign contributions. The Texas Attorney General made a criminal referral to the DOJ in January 2026 and filed a Deceptive Trade Practices Act lawsuit against ActBlue in April 2026. The Department of Justice's 180-day reporting deadline came and went on October 21, 2025 — with the government shutdown and subsequent administrative delays leaving the investigation's results unresolved as of the date of this publication.

This is what the conduit looks like when the documentary record catches up to the architecture.

This part documents that record. It also engages, as Part V did, with the strongest counter-defenses available to the architecture — the constitutional-protection argument, the bidirectionality argument, the political-targeting argument, the no-indictment-yet argument. Each is engaged head-on. The structural problem the architecture produces is not the unlawfulness of any particular transaction. The structural problem is the cumulative effect: a single conduit, sustained over two decades, that processed nearly $20 billion in political contributions under deliberately architected anti-fraud standards that the platform's own outside counsel described as creating "substantial risk" of impermissible foreign-national contributions into American elections — and that, when challenged under congressional subpoena, produced 146 invocations of the Fifth Amendment from the people responsible for its operation.

The pipes are what sustains the fourth branch. The conduit is what scales it. This is how.

The Path So Far

Part I established the indictment. April 21, 2026. Eleven federal counts against the Southern Poverty Law Center. Wire fraud, bank fraud, conspiracy to commit concealment money laundering.

Part II established the operator. Tina Tchen. The standard Obama-network institutional fixer template.

Part III established the lattice. Five fourth-branch hires across five years at SPLC. A coordinated designator layer simultaneously severed by FBI Director Patel in October 2025.

Part IV established the litigation arm. Elias Law Group on the civil side. The Soros-funded prosecutor network on the criminal side.

Part V established the pipes. Six interlocking philanthropic-and-foundation pipes — Arabella, Open Society, the legacy progressive foundations, Tides, the donor-advised funds, and the political-action-committee infrastructure — producing in cumulative annual flow more than $10 billion per year into the integrated progressive-civil-society infrastructure, sustained by a substantially overlapping donor class operating under deliberately opacity-producing structures.

Part VI, this part, establishes the conduit. The single largest entity in the political-finance side of the architecture. The platform through which the small-dollar online political contributions of nearly thirty million distinct American donors have flowed across two decades — and the architectural choices, documented in congressional subpoena returns and in the platform's own outside-counsel memos, that left those contributions vulnerable to substantial mixing with impermissible foreign-national money.

What ActBlue Is

ActBlue is structured, in formal legal terms, as a federation of four legally distinct entities operating under shared leadership and shared technical infrastructure.

ActBlue PAC is the original entity. It is a federal political action committee registered with the Federal Election Commission as committee ID C00401224, with a registration date of May 17, 2004. It is classified as a non-connected, non-qualified hybrid PAC with a non-contribution account. Its principal function — for which it has no real analog in American political-finance history — is to act as a conduit committee: a PAC that does not itself make political contributions to candidates, but that processes and forwards individual donor contributions to candidate committees and other PACs at the donor's direction.

ActBlue LLC is the for-profit operating arm. It was incorporated in 2005 in Somerville, Massachusetts, under the names of Benjamin Rahn, Erin Hill, Marc Laitin, and Matthew DeBergalis — the four founding-period operational leaders of the broader ActBlue organization. The entity has been incorporated in fourteen additional states (Maryland, Oregon, California, Texas, Maine, Washington, Montana, Delaware, Florida, Ohio, New Hampshire, Rhode Island, and Virginia) for operating purposes. ActBlue LLC is not, in any of its public materials, prominently disclosed; the for-profit operating arm of the architecture is one of the least publicly visible components.

ActBlue Civics is the 501(c)(4) social-welfare arm. It was founded in 2013, and serves as the pass-through conduit for political-and-policy-advocacy contributions to 501(c)(4) social-welfare organizations.

ActBlue Charities is the 501(c)(3) charitable arm. It was founded in 2015, and serves as the pass-through conduit for tax-deductible charitable contributions to 501(c)(3) public charities.

The four entities, together, form a complete architecture: a federal PAC conduit, a for-profit operating entity that provides the technical infrastructure, a 501(c)(4) social-welfare conduit, and a 501(c)(3) charitable conduit. A single online interface — the donor's experience on the platform — can route contributions through any of the four legal channels, depending on the type of recipient the donor selects. The donor, in operational terms, never has to think about which legal entity is processing the contribution. The platform handles the routing automatically.

The founders are technical, not political. Matthew DeBergalis is a Massachusetts Institute of Technology computer-science graduate who ran unsuccessfully for Cambridge City Council in 2003 and founded ActBlue the following year. Benjamin Rahn is a Harvard University alumnus who left a Caltech doctoral program in quantum physics to co-found the platform. Both founders are presented in the ActBlue public materials as engineers, not as political operatives. The platform's organizational self-description has consistently emphasized its technical character — "a fundraising platform," "a tool for Democratic campaigns," "infrastructure for grassroots giving" — rather than its political character.

The scale, however, is unambiguously political. ActBlue has processed more than $19 billion in contributions since 2004. It is the single largest political-finance entity in American history measured by cumulative volume. In the 2024 election cycle, it raised $3.82 billion for Democratic candidates and progressive committees. In the first quarter of 2025, it raised $400 million, according to a Wallace-Jones email to Democratic clients reported by Punchbowl News. In the third quarter of 2025, despite the heightened scrutiny, it raised "almost half a billion" in donations from 600,000 new donors, with 16,000 campaigns continuing to use the platform. In the first quarter of 2026, it raised $568 million. The platform has approximately 184 employees. It is headquartered in Cambridge, Massachusetts, with registered operations in Somerville.

The CEO, and What She Also Chairs

Regina Wallace-Jones became chief executive officer and president of ActBlue in January 2023, succeeding Erin Hill, who had led the platform for fourteen years.

Wallace-Jones is, in her own public-facing materials and in the materials of the organizations that have profiled her, presented as a technology executive with a parallel career in local Democratic politics. She holds a Bachelor of Science in Electrical Engineering from Stanford University, where she joined the Delta Sigma Theta sorority. She holds a Master of Public Policy from the UCLA Luskin School of Public Affairs, conferred in 1999, with an emphasis in telecommunications and technology policy. She served as a member of the East Palo Alto City Council beginning in 2018, defeating a thirteen-year incumbent, and was appointed Mayor of East Palo Alto by her council colleagues in 2020. She has held executive positions at Yahoo, eBay, Facebook, Mindbody, and Lendstreet — the last as Chief Operating Officer of a company focused on consumer debt restructuring. She is, in the language of ActBlue's own announcement of her hiring, "an accomplished product and security leader" with "20 years in tech." She is the first Black woman to lead ActBlue, and the fourth chief executive in the platform's history.

There is one further line in her public-facing biography that warrants direct attention.

She chairs the board of Sama. Sama is the San Francisco-based "AI training-data company" — formally Samasource Impact Sourcing, Inc., a B Corp — that was the principal outsourcing partner for OpenAI's content-moderation labeling work for ChatGPT. Sama employed approximately three thousand workers in Kenya, paying them a take-home wage of between $1.32 and $2 per hour to label the most graphic and traumatic content on the internet — child sexual abuse, bestiality, murder, suicide, torture, self-harm, incest — so that those categories could be filtered out of ChatGPT's training data. TIME magazine's January 2023 investigation of the Sama-OpenAI relationship documented the conditions of the work in detail. One employee characterized the work as "torture." All four of the Sama employees TIME interviewed described being mentally scarred by the work. The conditions were severe enough that Sama unilaterally cancelled its OpenAI contracts in February 2022, eight months earlier than the contracts called for. In 2023, 184 former Sama content moderators filed a lawsuit in Kenya against Sama and Meta. The case moved to mediation in August 2023. In early 2026, after disclosures that Sama employees had been viewing private content captured by Meta's Ray-Ban smart glasses — including video of users in bathrooms and during sexual activity — Meta terminated the contract. Sama subsequently laid off more than one thousand of its Kenyan employees.

This is the corporate ethics governance record of the chair of Sama's board — the same Regina Wallace-Jones who, on November 27, 2023, less than a year into her tenure as the chief executive of the largest online political-fundraising platform in American history, wrote to the chairman of the House Administration Committee that ActBlue's anti-fraud approach was "multilayered, with checks and confirmations occurring throughout the donation process to verify donors and donor information."

The conduit's most consequential public-facing statement, in other words, was a statement that the conduit's own retained outside counsel determined, on review, to be inaccurate in ways that created "substantial risk" of criminal exposure for the conduit and its leadership.

That is the through-line of the rest of this part.

A Chronology, in Plain Text

The congressional investigation into ActBlue did not begin in 2024. It began in October 2023, with a single letter from a single committee chairman about a single technical issue: the platform's failure to require donors to provide the three-digit card verification value (CVV) printed on the back of credit and debit cards as a condition of donating online.

The CVV is the standard anti-fraud measure used across virtually all of legitimate American e-commerce. It is the single most basic technical control against stolen-card fraud. Its function is to verify that the person making the online purchase physically possesses the card — a control that, by structural design, blocks the most common form of card-not-present fraud. ActBlue did not require it.

October 31, 2023: House Administration Committee Chairman Bryan Steil wrote to ActBlue demanding answers on the platform's CVV practices.

November 27, 2023: ActBlue CEO Regina Wallace-Jones responded. The platform's verification approach, she wrote, was "multilayered, with checks and confirmations occurring throughout the donation process to verify donors and donor information." Specifically, she represented to Congress that if a contribution appeared to be from a foreign address, ActBlue would contact the donor to request U.S. passport information, and would refund the contribution if it could not make contact with the donor.

January 2024: ActBlue began requiring CVVs on credit and debit transactions — fourteen months after the Steil letter, and roughly halfway through what would become the 2024 presidential election cycle. New donor accounts opened after the change were subject to the CVV requirement. Existing accounts, by the platform's own internal-record disclosure to subsequent congressional investigators, were not.

April 2024 and September 2024: ActBlue changed its internal fraud-prevention standards to make them, in the language of the platform's internal communications, "more lenient." The April 2025 first joint interim staff report would later document this — and document, on the basis of subpoenaed internal records, that the changes had the operational effect of permitting between 14 and 28 additional fraudulent contributions per month, and that up to 6.4 percent of total donations that should have been rejected for fraud were instead accepted. The report would also document, citing internal training materials, that the platform's training guide for new fraud-prevention employees instructed them to "look for reasons to accept contributions" rather than to err on the side of flagging suspicious donations. The chief fraud-prevention officer at the platform, according to the report, was willing to accept ten percent more fraud while focusing on diversity, equity, and inclusion initiatives.

September 6, 2024: Steil introduced H.R. 9488, the Secure Handling of Internet Electronic Donations (SHIELD) Act. The bill passed the House Administration Committee five days later by voice vote.

September 18, 2024: Steil sent letters to the attorneys general of Texas, Virginia, Arkansas, Florida, and Missouri. Within a few weeks, state-level investigations expanded to nineteen states.

Between September and October 2024: In a thirty-day window during this period, ActBlue detected 237 separate donations made from foreign IP addresses using domestic prepaid cards — Brazil, Colombia, India, Iraq, the Philippines, Saudi Arabia, and others. The 237 transactions occurred during the peak Harris-campaign fundraising window. Vice President Harris had raised $81 million in the twenty-four hours after President Biden withdrew from the race in July 2024. The campaign reported $361 million raised in August 2024 and over $615 million in total fundraising since Harris had entered the race.

October 28, 2024: Steil wrote directly to Wallace-Jones, demanding documents and information about the potential for foreign actors "primarily from Iran, Russia, Venezuela, and China" to launder illicit money through the platform.

October 30, 2024: Steil issued a formal subpoena to ActBlue.

December 10, 2024: Steil released findings. ActBlue had begun automatically rejecting donations from foreign prepaid and gift cards "as of September 2024" — but the platform had continued accepting such donations through July 2024, during the peak Harris-campaign fundraising surge. Independent investigator Parker Thayer subsequently documented having successfully completed an ActBlue donation on October 23, 2024 using a prepaid gift card purchased with cash — three days after Steil's October subpoena.

January 2025: Texas Attorney General Ken Paxton made a criminal referral to the U.S. Department of Justice.

February–March 2025: At least seven senior ActBlue officials resigned. The chief revenue officer, the vice president for customer service, the assistant research director, a human-resources official, a donation engineer, the associate general counsel, and the platform's former general counsel — Darrin Hurwitz — all departed. Hurwitz had left in November 2024, before the Covington memos, with a $168,000 severance package and a contractual commitment to "cooperate with ActBlue" on future investigations of misconduct at the platform. Aaron Ting had stepped into the role as interim head of legal. After the Covington memos, Ting forwarded the memoranda and related materials to ActBlue's Board of Directors and to other executives. Within a day, Ting went on a "suspicious leave of absence." ActBlue Chief People and Culture Officer Candace King violated internal policy to lock Ting out of his email and other internal accounts — actions that ActBlue staff at the time, in internal Slack communications, said "look[ed] like blatant retaliation." Days later, Zain Ahmad, the last remaining lawyer in the general counsel's office, alleged that he had been retaliated against for blowing the whistle on internal misconduct. By the end of March 2025, every member of ActBlue's legal and compliance team had resigned, been terminated, or been placed on extended leave.

April 2, 2025: The House Administration, Judiciary, and Oversight and Government Reform Committees released the first joint interim staff report. Titled "Fraud on ActBlue: How the Democrats' Top Fundraising Platform Opens the Door for Illegal Election Contributions," the report documented the platform's twice-tightened-then-loosened fraud-prevention rules, the "look for reasons to accept contributions" training, the 237 foreign-IP donations, the 10-percent acceptable-fraud-level policy, and the documentary record establishing that ActBlue's executives were aware of foreign and domestic fraudulent activity on the platform and had attempted to hide the changes to internal policies "to avoid sparking discussions about fraud on the platform."

April 24, 2025: President Trump signed an executive memorandum directing the Department of Justice to investigate ActBlue and other online fundraising platforms for "straw" donor and foreign contributions. The memorandum cited the April 2 Committee report as evidence and gave the DOJ 180 days — until October 21, 2025 — to report findings.

June 25, 2025: The Committees issued subpoenas to two ActBlue employees who had failed to comply with earlier interview requests. July 22, 2025: The Committees issued a subpoena to Wallace-Jones personally. September 4, 2025: The Committees issued subpoenas to three ActBlue lawyers — including Hurwitz, Ting, and Ahmad — to appear for depositions. Hurwitz and Ting had initially agreed to provide voluntary testimony but withdrew the offer after President Trump's executive order, on advice of counsel.

July 23 through December 5, 2025: Five depositions were conducted. Alyssa Twomey (former Vice President of Customer Service, July 23). Hurwitz (former General Counsel, November 19). Ahmad (Legal Counsel, December 5). Ting (former interim General Counsel and Associate General Counsel). An unnamed Senior Workflow Specialist who managed the platform's fraud-prevention operations. In each of the five depositions, the witness invoked the Fifth Amendment in response to every substantive question. The cumulative total across the five depositions, by the Committee's count, was one hundred forty-six invocations of the Fifth Amendment right against self-incrimination.

October 21, 2025: The DOJ's 180-day reporting deadline came and went. The federal government shutdown had begun several weeks earlier and would continue for substantially the entire fall. The DOJ's investigative work was, in significant part, frozen by the shutdown's contingency plan. The investigation's findings were not, and have not been, publicly released as of the date of this publication.

April 2, 2026: The New York Times published the first detailed account of the February 2025 Covington & Burling memoranda, drawing on internal documents the paper had obtained. The Times reported that ActBlue had subsequently terminated Covington & Burling — characterizing the firm's work as having "bordered on malpractice" — and had begun, in the Times' characterization, "all but declaring war on" its former outside counsel. Covington & Burling issued a public statement saying that the firm had "complete confidence in the legal advice our lawyers provided to ActBlue."

April 20, 2026: The three Committees released "Fraud on ActBlue, Part II: Illicit Foreign Donations and a Cover-Up Spur Mass Resignations and Firings on ActBlue's Legal and Compliance Team." The same day, Texas Attorney General Paxton filed a Deceptive Trade Practices Act lawsuit in Tarrant County district court against ActBlue.

May 1, 2026: ActBlue filed a federal countersuit against Paxton in the District of Massachusetts, alleging that Paxton's investigation and lawsuit amount to political retaliation in violation of the First and Fourteenth Amendments. The countersuit notes that Paxton initiated undercover investigations of ActBlue the day after Democratic Senate nominee James Talarico announced he had raised $2.5 million in twenty-four hours through ActBlue, of which $2.2 million had flowed through the platform. The countersuit notes that three attempts by Paxton's investigators to make American Express gift-card donations to ActBlue were automatically rejected by the platform's anti-fraud controls. The countersuit notes that Paxton has never investigated WinRed, ActBlue's Republican counterpart, despite documented refund rates on WinRed of up to twenty percent. The countersuit notes that Paxton's own Senate campaign has been the subject of three FEC inquiries about approximately $883,000 in apparently illegal contributions across less than a year.

That is the documentary chronology, in the most compressed form. The investigation is active. The DOJ probe is procedurally suspended but legally unresolved. The Texas state-court lawsuit and the ActBlue federal countersuit are both pending. The 146 invocations of the Fifth Amendment remain in the congressional record, undisturbed by any subsequent testimony, on the part of the people who built and operated the conduit's anti-fraud controls during the period covered by the investigation.

Iran, Russia, Venezuela, China — and the Long Tail

The most consequential single sentence in the Steil letter of October 28, 2024 is the sentence naming the four countries.

The letter framed the investigation as principally focused on the potential for foreign actors "primarily from Iran, Russia, Venezuela, and China" to use ActBlue as a money-laundering conduit into American political campaigns. The four countries named are, in American foreign-policy terms, the four most consistently identified state-level adversaries of the United States across the post-Cold War period. Iran is subject to comprehensive U.S. sanctions including a near-total prohibition on U.S.-Iran financial transactions. Russia is subject to the broadest American sanctions regime since the Cold War, with the post-2022 expansion covering virtually the entire Russian financial system. Venezuela is subject to sanctions on its government, its oil sector, and a large category of its political and economic elite. China, while not under comprehensive sanctions, is subject to extensive financial-transaction monitoring and is the principal documented state-level actor in American foreign-political-interference cases since the 1996 "Chinagate" scandal.

The selection of those four countries — as the primary concern of the investigation — was not arbitrary. The Committee's case-construction documents, including the comparative analysis of "over 200 million FEC donation records with data on age, party affiliation, number of donations, consumer purchasing power, and net worth," produced specific patterns of donation activity that were consistent with smurfing — the money-laundering technique of breaking a large illicit deposit into many small contributions attributed to the names of unwitting individuals — and that mapped, by geographic and timing characteristics, to the four named adversary states. The Treasury Department's money-laundering-detection system had separately generated, by Steil's October 2024 disclosure, "hundreds of Suspicious Activity Reports" on transactions passing through ActBlue.

The broader documentary record, beyond the four named adversary states, has subsequently expanded the geographic footprint substantially. The April 2025 first interim staff report documented the 237 foreign-IP-based prepaid-card donations across a thirty-day window in late 2024. The list of source countries included Brazil, Colombia, India, Iraq, the Philippines, and Saudi Arabia.

The Iraq disclosure warrants its own attention. Iraq is a country in which the United States has, since 2003, maintained continuous military and intelligence operations. American foreign aid to the Iraqi government has, in the same period, run into the hundreds of billions of dollars. The flow of dollars from Iraqi-IP-address donors back into American political campaigns is a structurally significant feature of the broader political-finance picture — not because it is necessarily large in absolute terms, but because it raises the possibility that some portion of the dollars flowing into the American political system from the conduit are originating, in foreign-policy terms, in jurisdictions that the United States itself is funding. The same observation applies to Colombia, where U.S. aid under Plan Colombia and its successors has totaled tens of billions of dollars over the past two decades.

One additional country, conspicuously absent from the Steil letter's primary list, has been raised in adjacent investigative reporting as a structural concern: Ukraine. Independent investigators including the analysts who have publicly documented the smurfing pattern have argued that the Ukraine question — whether U.S. dollars sent to Ukraine through congressional appropriations and military assistance may have been recycled back into the American political system through dark-money channels including ActBlue — is structurally similar to the Iraq question and warrants the same investigative scrutiny. The Steil letter's primary-four formulation did not address it. The April 2025 report did not address it. The April 2026 Part II report did not address it. Whether the omission reflects an evidentiary judgment, a political-prudence judgment, or some combination of the two is, as of this writing, not publicly clarified.

The Smurfing Pattern

The smurfing pattern itself — the structural mechanic of the alleged money-laundering operation — has been documented in detail by independent investigators including Peter Bernegger, Chris Gleason, Phil Allison, and the team led by James O'Keefe's OMG investigative-journalism operation, going back to March 2023. The pattern is straightforward to describe and operationally hard to defeat: a sophisticated actor takes a large pool of illicit money, breaks it into thousands of small contributions of $5 to $50 each, attributes those contributions to the names of real Americans (typically elderly Americans whose identities and addresses are accessible through publicly available voter-registration and consumer-data sources), and processes the contributions through the conduit at a velocity that evades the FEC's standard reporting thresholds. The contributions appear, in the campaign-finance record, as thousands of legitimate small-dollar donations from American citizens. The actual source of the dollars is, by the structural design of the laundering scheme, untraceable from the public record.

The independent-investigator documentation has identified specific cases. An eighty-eight-year-old retired Yale University professor was credited, in FEC records, with making 7,539 donations totaling $213,163 between 2016 and 2024 through ActBlue. The professor, when contacted by investigators, signed an affidavit stating: "I believe this does not reflect my donation frequency or dollars I have donated." Eighteen registered Democrats in Connecticut, all over the age of seventy, were credited with donating $1.9 million collectively to Democratic causes through ActBlue across the 2016–2024 window — hundreds of thousands of small donations, sometimes multiple in a single day. Several of the supposed donors, when contacted, told Connecticut investigators they had not made any of the reported donations and had no knowledge of how their names were being used. Senator Tammy Baldwin's 2024 reelection campaign in Wisconsin nearly doubled her 2018 fundraising total, with twelve donors identified as responsible for identical contribution patterns totaling more than $2.4 million; Bernegger's team has publicly accused her campaign of benefiting from the smurfing pattern, an allegation Baldwin's campaign has not, on the public record, definitively rebutted. A Republican consultant in Wisconsin filed a lawsuit in Waukesha County Circuit Court in late 2024 alleging that his identity and an old campaign email had been used to make ActBlue donations to political committees opposing his stated political views; a Waukesha County judge allowed limited discovery on the case to proceed.

These are the operational indicators that the architecture of the conduit, regardless of the conduit operators' intent, has produced documented patterns of donor-identity misappropriation at scale. The question of whose money was actually flowing through the apparently fraudulent contributions — whether it was foreign-state money, domestic dark-money, or some combination — is the question the Steil investigation, the Paxton investigation, the DOJ investigation, and the multiple state-level investigations have been working on across more than two and a half years.

What the Depositions Establish

The five depositions conducted by the three House committees between July 23 and December 5, 2025 are the operational core of the Part II report's documentary record.

The depositions were not voluntary. Each of the five witnesses was deposed under subpoena. The witnesses were:

Alyssa Twomey, former Vice President of Customer Service at ActBlue. Twomey had been at ActBlue for more than fourteen years by the time of her July 23, 2025 deposition. She had been the executive responsible for overseeing the fraud-prevention team during the 2024 election cycle.

Darrin Hurwitz, former General Counsel. Hurwitz had left ActBlue in November 2024 with a $168,000 severance package and a contractual commitment to cooperate with the platform on future investigations.

Aaron Ting, former Director and Associate General Counsel, and the interim General Counsel who replaced Hurwitz in November 2024. Ting had resigned shortly after forwarding the Covington & Burling memoranda to ActBlue's Board of Directors.

Zain Ahmad, Legal Counsel. Ahmad had been the last remaining lawyer in the general counsel's office after the cascade of February–March 2025 resignations. He had alleged retaliation for whistleblowing.

An unnamed Senior Workflow Specialist who had managed the platform's day-to-day fraud-prevention operations.

In each of the five depositions, the witness invoked the Fifth Amendment in response to every substantive question. The aggregate count of invocations across the five depositions was 146.

The structural significance of that number is not the number itself. It is what the invocation pattern indicates about the documentary record. The Fifth Amendment to the United States Constitution provides that no person "shall be compelled in any criminal case to be a witness against himself." The invocation of the Fifth Amendment in response to a question is, in formal legal terms, an assertion of the witness's right to refuse to answer on the ground that the answer might tend to incriminate the witness in a criminal proceeding. The invocation is not, by itself, an admission of guilt. It is, in the standard analytical frame of American criminal-procedure law, a refusal to provide testimony that would establish guilt — coupled with a constitutionally protected silence.

When five separate witnesses, all of whom had operational responsibility for the fraud-prevention and legal-compliance functions of the platform at the time of the alleged conduct, invoke the Fifth Amendment in response to every substantive question across five separate depositions — 146 invocations cumulatively — the structural inference the Committee drew is the inference any reasonable investigator would draw. The witnesses were unwilling to provide testimony that would, by their own counsel's assessment, expose them to criminal liability.

The number is 146. The witnesses are five. The documentary record is, by the time of the April 2026 Part II report, very large. The platform's own outside counsel had, more than a year before the depositions, characterized the legal-compliance status of the platform as creating "substantial risk" of "knowing and willful" violations of federal foreign-national-contribution law.

That is the conduit, as of May 2026.

The Strongest Defenses, Engaged Directly

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

Online political fundraising is constitutionally protected speech. True. The Supreme Court has long held that political contributions and political expenditures are forms of speech entitled to First Amendment protection — Buckley v. Valeo, 424 U.S. 1 (1976); Citizens United v. FEC, 558 U.S. 310 (2010); and the subsequent decisions in that line. The right of American citizens to organize online platforms for the aggregation of small-dollar political contributions to candidates of their choice is a paradigmatic First Amendment activity, and the design of platforms like ActBlue to make that activity easier — to reduce the friction between donor and candidate, to enable rapid response to political events, to lower the per-donation transaction cost — is itself a contribution to small-d democratic participation.

The argument in this part is not that platforms like ActBlue are constitutionally suspect. The argument is that the specific architectural choices the platform made between 2004 and 2024 — the failure to require CVVs until January 2024, the acceptance of foreign-IP donations through prepaid and gift cards, the relaxation of fraud-prevention standards twice in 2024, the "look for reasons to accept" training, the documented foreign-IP transactions, and the November 2023 letter to Congress whose accuracy the platform's own outside counsel subsequently questioned — produced an operational profile that the platform's own retained outside counsel determined to create "substantial risk" of impermissible foreign-national contributions into American elections. The First Amendment does not, in any of the Supreme Court's decisions in this area, immunize political committees from compliance with the federal-election-law prohibition on foreign-national contributions (52 U.S.C. § 30121).

The investigation is politically targeted by a Republican White House and Republican attorneys general. This is the strongest single counter-defense available, and it deserves direct engagement.

The April 2025 Trump executive memorandum directing the DOJ to investigate ActBlue is, on its face, an unusual exercise of presidential authority. The traditional norm — the Justice Department's institutional independence from White House direction on specific investigative matters — has been substantially weakened across multiple administrations of both parties over the past two decades. Trump's memorandum is, in this respect, both an extension of an existing trend and an escalation of it. The targeting of a single political-finance entity associated with one political party, by direct presidential memorandum, raises First Amendment and equal-protection concerns that are real and that have been raised by serious constitutional lawyers, including Senator Richard Blumenthal in a June 2025 letter to Attorney General Pam Bondi.

The bidirectionality concern is also real. WinRed, the conservative-aligned online political-fundraising platform, has — by independent documented analysis — its own profile of donor-irregularity complaints. The Idaho Tribune in April 2025 identified dozens to hundreds of retired elderly Idahoans listed as giving hundreds of thousands of dollars to Republican political campaigns through WinRed without any identifiable source of income. The Federal Trade Commission's consumer-complaint data, compiled by CNN, showed 803 complaints filed against WinRed between January 2022 and June 2024, compared to 120 complaints filed against ActBlue in the same period. The refund rates on WinRed contributions, according to ActBlue's federal countersuit against Paxton, run up to twenty percent — substantially higher than the equivalent ActBlue figures. Paxton's own Senate campaign has been the subject of three FEC inquiries about approximately $883,000 in apparently illegal contributions across less than a year. The selective focus on ActBlue, without parallel investigation of WinRed, has a real political-motivation problem.

The structural critique made in this part does not require that the conduit-architecture phenomenon exist only on the progressive 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 part that an analogous investigation of WinRed would also warrant publication has, in this author's view, drawn a defensible conclusion. The position this part is taking is that the documentary record on ActBlue — the 146 invocations of the Fifth Amendment, the February 2025 Covington & Burling memos, the collapse of the platform's legal and compliance team, the April 2026 New York Times reporting — is substantial enough to warrant publication on its own terms, regardless of the political motivations of any particular state actor pursuing the case.

The companion question — what would an equally thorough investigation of WinRed turn up — is a question the documentary record cannot, as of this writing, definitively answer, because no such investigation has been conducted at the federal level. Whether the absence of that investigation reflects the structural fact that WinRed's documented problems are smaller in absolute scale, or whether it reflects political-targeting on the part of the Republican investigative apparatus, is the question that the next phase of the campaign-finance debate is going to have to engage.

No indictment has been issued. The 146 Fifth Amendment invocations are not, by themselves, evidence of criminal conduct. True, and this part's framing is calibrated accordingly. The Department of Justice has not, as of the date of this publication, issued any criminal indictments against ActBlue or any individual associated with ActBlue. The DOJ probe is procedurally suspended but legally unresolved. The Texas state-court lawsuit alleges Deceptive Trade Practices Act violations; it does not allege criminal conduct in the federal-election-law sense. The Fifth Amendment invocations are constitutionally protected silence — not admissions of guilt.

The argument here is structural, not adjudicative. The structural argument is that the documentary record establishes a pattern: (1) the platform's own outside counsel determined, in February 2025, that the platform's foreign-donor screening practices created "substantial risk" of impermissible foreign-national contributions; (2) the platform's chief executive officer's November 2023 letter to Congress — the document whose accuracy was specifically reviewed in the Covington memos — was determined by the platform's own outside counsel to contain representations that were not, in all respects, accurate; (3) every member of the platform's legal and compliance team resigned, was fired, or was placed on extended leave by March 2025; and (4) the five witnesses deposed by the Committees about these issues invoked the Fifth Amendment in response to every substantive question. The cumulative documentary record warrants scrutiny — independent of, and prior to, any final adjudicative determination by the Department of Justice or any other prosecuting authority.

Less than 1 percent of ActBlue donations show signs of foreign sourcing. This is the figure ActBlue Board Chairwoman Kimberly Peeler-Allen cited to the New York Times in April 2026, as the platform's own internal-data characterization of the foreign-donation problem.

One percent of $3.82 billion is $38 million. That is, by any standard, a significant figure. The fundraising threshold for a competitive U.S. Senate race is, in most states, in the $15 to $30 million range. Thirty-eight million dollars is sufficient to fund two competitive Senate campaigns. The framing of "less than one percent" as a downplaying figure is, in structural terms, a framing that the absolute dollar amount substantially undercuts.

The further complication is that the one percent figure is the platform's own internal estimate of donations showing signs of foreign sourcing — not an independently audited determination of donations that actually were foreign-sourced. The Covington & Burling memos, the 237 documented foreign-IP-prepaid-card transactions, the elderly-American smurfing pattern documentation, and the multiple independent investigator findings together suggest that the actual foreign-sourced fraction, in any rigorous audit, could be substantially higher than the platform's internally generated one-percent estimate.

Pipes Plus Conduit

The structural argument this series has built across Parts I through VI can be stated, at the level of architecture, in three propositions.

One. The American post-2020 institutional progressive apparatus operates as an integrated network — the designator layer at SPLC and ADL (Part III), the litigation arm of Elias Law Group and the Soros-funded prosecutor network (Part IV), the philanthropic-and-foundation pipes that finance the civil-society infrastructure (Part V), and the political-finance conduit through which small-dollar political contributions flow to candidate committees (Part VI).

Two. Each component of the network operates under a distinct legal regime — designator activity under 501(c)(3) law, civil litigation under federal civil procedure and state-level civil-procedure analogs, criminal prosecution under federal and state criminal-procedure law, philanthropic giving under tax-exempt-organization law, and political contributions under federal-election-law and state-election-law disclosure rules. The legal-regime separation is what gives the network its formal status as a constellation of independent entities rather than a single integrated operation.

Three. The operational coordination across the components, however, is documented at every level of the network — the personnel circulation between OSF U.S. Programs and SPLC (Beeson), between Obama-network institutions and SPLC (Tchen, Bekenstein, Huang), between OSF and the Arabella four-fund cluster, between Tides and Fair and Just Prosecution, between the philanthropic donor class and the PAC infrastructure that funds the Soros prosecutors, and between the philanthropic-pipe major donors and the small-dollar conduit's principal recipients. The legal-regime separation is formal. The operational integration is functional.

The conduit fits into the architecture in a specific way. The pipes (Part V) sustain the fourth branch — the legal-and-policy advocacy organizations, the civil-litigation operations, the criminal-prosecution-policy organizations, the designator infrastructure. The conduit (Part VI) scales the political-finance side — the small-dollar contributions that fund the candidate campaigns, the campaign committees, the state-and-federal Democratic party committees that the candidates and committees roll up into. The pipes are the philanthropic spine. The conduit is the political-finance vehicle. Together, they constitute the most consequential single concentration of progressive-aligned operational capability in modern American political history.

The architecture is not, in the strict legal sense, illegal. Most of its components are operating well within the formal bounds of American campaign-finance, tax-exempt-organization, and civil-litigation law. Each filing is, so far as is publicly known, an accurate filing. The federal courts and the Department of Justice have not, in their public actions through April 2026, found that any of the network's component entities has committed a crime.

What the architecture is, however, is opaque. The relationship between original donor and ultimate grantee, in the philanthropic-pipe side of the architecture, is severed from the public record by the deliberate legal design of fiscal sponsorship, donor-advised funds, and 501(c)(4) social-welfare organizations. The relationship between actual donor and ostensible donor, in the political-finance-conduit side, has been called into substantial question by the 146 Fifth Amendment invocations and the February 2025 Covington & Burling memos. The accountability mechanism the American constitutional order provides for political action — the electoral mechanism, the regulatory mechanism, the criminal-prosecution mechanism — operates through public information. When the public information is structurally obscured at the level of donor-grantee relationships, and structurally undermined at the level of donor-conduit transparency, the accountability mechanism is structurally weakened.

That is the convergence. The conduit scales what the pipes sustain. The 146 invocations of the Fifth Amendment are the documentary marker of what the scaling has produced.

Where This Part Ends

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

• ActBlue has processed more than $19 billion in political contributions since its June 2004 founding. In the 2024 election cycle alone, it processed approximately $3.82 billion for Democratic candidates and progressive committees. Q1 2026: $568 million.
• ActBlue is organized as four legally distinct entities — ActBlue PAC, ActBlue LLC, ActBlue Civics (501(c)(4)), and ActBlue Charities (501(c)(3)) — operating under shared leadership and shared technical infrastructure. Co-founded by Matthew DeBergalis (MIT) and Benjamin Rahn (Caltech, Harvard). Wallace-Jones CEO since January 2023.
• Wallace-Jones chairs the board of Sama — the AI training-data company that employed approximately 3,000 Kenyan workers at $1.32–$2 per hour to label graphic content for OpenAI's ChatGPT and for Meta's content moderation, with a 2023 lawsuit by 184 former Sama content moderators, and that in early 2026 was disclosed to have been viewing private user content captured by Meta's Ray-Ban smart glasses.
• October 31, 2023: Steil letter to ActBlue on CVV. November 27, 2023: Wallace-Jones response letter claiming "multilayered" verification, including U.S. passport requirement for foreign-address donors.
• January 2024: ActBlue began requiring CVVs on credit and debit transactions — fourteen months after the Steil letter. April and September 2024: Internal fraud-prevention standards relaxed twice. Training materials instructed employees to "look for reasons to accept contributions." Up to 6.4 percent of total donations that should have been rejected for fraud were instead accepted.
• September–October 2024: 237 documented foreign-IP-based prepaid-card donations to ActBlue from Brazil, Colombia, India, Iraq, the Philippines, Saudi Arabia, and other source countries.
• October 28, 2024: Steil names the four principal countries of concern: Iran, Russia, Venezuela, China. The Treasury Department had separately generated "hundreds of Suspicious Activity Reports" on ActBlue-related transactions.
• January 2025: Texas AG Paxton makes criminal referral to DOJ.
• February 2025: Two Covington & Burling memoranda warn that the platform's November 2023 letter to Congress may have been inaccurate; that there is "a substantial risk that some of the funds received" were "impermissible contributions from foreign nationals"; that "it can be alleged" the violations were "knowing and willful"; that "an aggressive prosecutor may view the November 2023 letter not just as a false statement but as an effort to conceal the foreign contributions."
• February–March 2025: At least seven senior ActBlue officials resign. By March 2025, every member of the legal and compliance team has resigned, been fired, or been placed on extended leave.
• April 2, 2025: First joint interim staff report ("Fraud on ActBlue") released. April 24, 2025: Trump executive memorandum directs DOJ to investigate. 180-day deadline: October 21, 2025.
• July 22, 2025: Subpoena to Wallace-Jones personally. September 4, 2025: Subpoenas to Hurwitz, Ting, Ahmad. July 23–December 5, 2025: Five depositions conducted. All five witnesses invoke the Fifth Amendment in response to every substantive question. Total invocations: 146.
• October 21, 2025: DOJ 180-day deadline passes. Government shutdown freezes investigative work. April 2, 2026: New York Times publishes Covington memos story. ActBlue terminates Covington & Burling.
• April 20, 2026: "Fraud on ActBlue, Part II" released. Same day: Texas AG Paxton files Deceptive Trade Practices Act lawsuit in Tarrant County. May 1, 2026: ActBlue files federal countersuit against Paxton in Massachusetts.
• The structural problem the architecture produces is not the unlawfulness of any particular transaction. The structural problem is the cumulative effect: a single conduit, sustained over two decades, that processed nearly $20 billion in political contributions under deliberately architected anti-fraud standards that the platform's own outside counsel determined to create "substantial risk" of impermissible foreign-national contributions into American elections — and that, when challenged under congressional subpoena, produced 146 invocations of the Fifth Amendment from the people responsible for its operation.

The pipes are what sustains the fourth branch. The conduit is what scales it. The 146 invocations of the Fifth Amendment are the documentary marker of what the scaling has produced.

But the documentary record is now substantial. The DOJ probe is procedurally unresolved but legally pending. The Texas state-court lawsuit and the ActBlue federal countersuit are both active. The April 2026 Part II report's 146 invocations remain in the congressional record, undisturbed.

What comes next — the structural conclusion of this series — is the part that will assess where the apparatus stands at the close of the period this series has been documenting. The legal, political, and structural consequences of the disclosure that has occurred between April 2025 and May 2026. The architecture of the fourth branch as it now exists, after the SPLC indictment, the FBI Director Patel designator-network severance, the Trump DOJ posture, the Wallace-Jones depositions, and the broader regulatory environment that has, across the past eighteen months, begun for the first time in two decades to push back against the integrated apparatus the prior parts have documented.

Part VII is the assessment. The unraveling.