CfA Files Complaint After Political Nonprofit Fails to Register to Solicit Dark Money


Contact: Michael Clauw,, 202.780.5750

WASHINGTON, D.C. – Campaign for Accountability (CfA) filed a complaint requesting an investigation into the political nonprofit Americans for Public Trust (APT) for illegally soliciting contributions in Virginia. The organization—whose primary activity appears to be partisan attacks on national Democratic political figures—is incorporated in Virginia, which has a law requiring all charities to file a statement of intent to solicit contributions in the state before doing so. APT failed to register with the state’s Office of Charitable and Regulatory Programs, despite its solicitation in Virginia over the past two years, according to online records.

Read the Complaint.

Campaign for Accountability Executive Director Michelle Kuppersmith said, “Given the gray-area where APT operates, it’s no surprise that others already questioned its status as a ‘charitable or educational’ nonprofit. But there’s nothing gray about the fact that APT has been playing fast and loose in its disregard for the laws governing its activities. If the Commonwealth of Virginia finds that APT ran afoul of solicitation laws, we ask that it is appropriately penalized.”

The Virginia Solicitation of Contributions law requires that a “charitable organization . . . which intends to solicit contributions within the Commonwealth […] shall, prior to any solicitation, file an initial registration statement with the Commissioner.” The Office of Charitable and Regulatory Programs Charitable Organization Database contains no record of APT ever filing such a registration statement in the more than two years that it has been in operation.

APT’s 2020 tax return shows that it raised $1,489,000 that year from just two contributions – one for $589,000 and one for $900,000. This latter contribution for $900,000 was made anonymously through a donor advised fund, Donor’s Trust, Inc., which—like APT—is based in Alexandria, Virginia.

Ms. Kuppersmith continued, “APT’s disregard for Virginia law is no minor oversight—it has collected an extremely large amount of money in the state since it apparently began illegally soliciting in 2020. Officials should investigate to determine the number and extent of APT’s violations of the Virginia Solicitation of Contributions law and to seek the maximum penalties permitted by law.”

Campaign for Accountability is a nonpartisan, nonprofit watchdog organization that uses research, litigation, and aggressive communications to expose misconduct and malfeasance in public life and hold those who act at the expense of the public good accountable for their actions.