Overview

• ProPublica’s investigation found that Noem’s personal LLC, Ashwood Strategies, received an $80,000 fundraising fee in 2023 for raising $800,000 for American Resolve Policy Fund.
• Ashwood Strategies and the dark-money nonprofit were both incorporated in Delaware within minutes on June 22, 2023, suggesting deliberate coordination.
• Noem did not report the $80,000 fee on her mandatory 2023 federal financial disclosure form submitted during her confirmation as DHS secretary.
• Ethics experts warn that routing campaign fundraising fees through a personal company could violate federal conflict-of-interest rules and state disclosure requirements.
• American Resolve Policy Fund raised $1.1 million in 2023 but is not required to reveal its donors, leaving the original source of its funds unknown.