Lawyers for the Democrat fundraising organization ActBlue warned that the organization’s CEO may have misled Congress in explaining how her group vetted donations to ensure they did not come from foreign citizens, according to newly released memos.
ActBlue told The Daily Signal that it has “continually worked to comply” with all laws regarding foreign contributions.
The memos warn that ActBlue President and CEO Regina Wallace-Jones’ 2023 letter to the U.S. Committee on House Administration laid out an overly optimistic version of ActBlue’s foreign donation screening. After the organization’s then-law firm Covington & Burling sent the memos in early 2025, many ActBlue senior officials resigned, and the law firm would later separate from ActBlue.
“It can be alleged that ActBlue accepted and/or facilitated the acceptance of foreign-national contributions into American elections,” warns one of the memos, reported by The New York Times.
“In addition, because ActBlue’s staff was aware that its system was not as robust as necessary, it could be alleged that these violations were ‘knowing and willful,’ a standard that both increases the penalties the [Federal Election Commission] might seek and gives the Justice Department jurisdiction for a potential criminal investigation.”
While Wallace-Jones’ letter said the organization processed contributions with foreign mailing addresses only if a donor supplied a U.S. passport number, the Covington memo stated that ActBlue did not always follow that rule.
Wallace-Jones’ letter also claimed that ActBlue would contact donors to request passport information, and refund those who could not be reached. A memo claimed that donors who paid through third-party apps such as Apple Pay, PayPal, or Venmo did not receive these requests for passport information.
The memos did not identify illegal contributions, and suggested the scope of the problems was unclear. Kimberly Peeler-Allen, chairwoman of the ActBlue board of directors, told The New York Times that “less than 1%” of contributions from the 2024 election cycle had signs that they came from foreign countries.
“The November 2023 letter sent to Congress by ActBlue was carefully reviewed by inside and outside counsel and key business leaders prior to submission,” ActBlue told The Daily Signal. “The letter was accurate.”
“The statements in my 2023 letter to the House Administration Committee were accurate in the context in which they were written,” Wallace-Jones told The New York Times. She noted that Covington approved the letter.
Even so, ActBlue took steps to beef up its vetting of foreign donations and outlined the changes in a June 2025 letter to various congressional leaders, including the Committee on House Administration. The letter also suggested Republicans engaged in a “partisan effort” instead of “an exercise of legitimate legislative oversight.”
In her statement to the Times, Wallace-Jones attacked Covington, saying she had “terminated” ActBlue’s relationship with the law firm in March 2025 after “more than a year of navigating tardiness, unpreparedness, and counsel that bordered on malpractice.”
“We have complete confidence in the legal advice our lawyers provided to ActBlue, David Schaefer, senior director of communications at Covington & Burling, told The Daily Signal in a statement Thursday.
ActBlue’s Response
“ActBlue has continually worked to comply with all FEC laws including laws related to appropriately screening for potential foreign contributions, which constitute less than 1% of the total contributions on the ActBlue platform,” ActBlue told The Daily Signal.
“Of those, many come from the 6 million American citizens who live abroad—such as US military personnel.”
“We have continually improved our processes, even while facing repeated partisan attacks from the Trump administration and its allies,” ActBlue stated. “Most importantly, ActBlue is stable and stronger than ever.”
While ActBlue told The Daily Signal that the Times “unfortunately disregarded extensive evidence we made available to them,” it did not contest any of the specific quotes from the memos.
Three Options
One of the Covington 2025 memos outlined “potential legal risks associated with statements to Congress that may be alleged to be false or misleading,” noting that the maximum penalties would be five years in prison and $250,000 in fines.
The memo outlined three options for ActBlue:
- Provide new information “without explicitly stating that ActBlue is correcting the record.”
- “Explicitly correct the record.”
- “Do not provide additional information clarifying the prior statements.”
“An aggressive prosecutor may view the November 2023 letter not just as a false statement but as an effort to conceal the foreign contributions,” the Covington memo reportedly warned.
Three House committees—the Judiciary Committee, the Committee on Oversight and Government Reform, and the Committee on House Administration—are investigating ActBlue, as are the Justice Department and the FBI.
The Justice Department did not respond to The Daily Signal’s request for comment.
