In late October, a mysterious nonprofit registered with the state of Delaware. Within months, it was funneling millions of dollars to conservative causes.
Last week, the Campaign Legal Center (CLC) filed a complaint with the Federal Election Commission alleging that the new group, Ardleigh Impact Corporation, bears the marks of a shell entity specifically created to pump big donors’ money into politics while masking their identities.
The alleged setup, known as a “straw donor” scheme, would violate federal law, the complaint states.
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It’s no surprise that the entity drew the CLC’s attention. As the complaint notes, Ardleigh does not operate a website or any social media pages, does not appear in various corporate databases, and has no “discernible public footprint.” In fact, at the time of the complaint—before news sites picked up the story—the only publicly available evidence of the nonprofit’s existence were the donations documented in FEC reports and its articles of incorporation, which it had unsurprisingly registered with the notoriously opaque state of Delaware.
However, those incorporation documents, obtained by The Daily Beast, reveal key details not found in the complaint. Ardleigh’s officers, however, refused to provide The Daily Beast with any information about the group’s activities.
First, the incorporation records identify the group’s organizers as experienced political operatives, including, apparently, the professional strategist who ran Dr. Mehmet Oz’s failed Senate campaign in 2022. They also show that Ardleigh Impact Corp. is not organized as a private company, but a 501(c)(4) nonprofit—a “dark money” group. However, additional business filings show that Ardleigh Impact Corp. has an apparent twin entity—a private limited liability corporation called “Ardleigh Impact LLC,” also registered in Delaware.
The new information increases the likelihood that Ardleigh Impact Corp. is, as the complaint alleges, specifically designed to function at least in part as a vehicle for anonymously funding political activity. However, the fact that Ardleigh Impact Corp. is a dark money nonprofit—and therefore permitted to participate in limited election activity—would also seem to rule out claims that it is a “shell company,” potentially deflating one of the complaint’s arguments while simultaneously introducing new questions about transparency.
Tax regulations do not require nonprofits like Ardleigh Impact Corp. to disclose their donors, making it highly unlikely that the public will ever learn who funds the entity. By extension, that means the public will also likely never know the ultimate source of the millions of dollars that Ardleigh has already poured into those GOP groups—hence the “dark” in “dark money.”
Chief among the group’s organizers is Alexander Reid, a partner at BakerHostetler who specializes in tax-exempt organizations. Reid has a history of challenging transparency regulations, including a 2016 Supreme Court brief in support of a nonprofit’s ultimately failed effort to scrap disclosure requirements.
The month before Reid incorporated Ardleigh Impact Corp. as a 501(c)(4), he told Bloomberg that political pressures can make it difficult for the IRS to enforce existing laws regulating 501(c)(4) groups. Such action, Reid said, “always creates a perception of fairness or unfairness,” based on which side of the argument you’re on. (It is difficult to see the downside to a “perception of fairness.”) Reid’s firm, BakerHostetler, promoted his appearance on its website.
Reid, it turns out, is also listed as the authorized representative of the nonprofit’s apparent twin, Ardleigh Impact LLC. The LLC was registered in Delaware just one week after Ardleigh Impact Corp, though its purpose is unclear. Outside of those filings, the LLC does not appear to have any public presence whatsoever. Its registered agent is Registered Agents Inc., a company that Wired reported “enables hundreds of thousands of businesses to operate in near-total secrecy.”
Asked about the arrangement, Reid was light on the details, telling The Daily Beast in a text message, “I’m not sure what else I can say about the 501(c)(4).”
“I’m afraid I don’t have materials to share about all the c4’s activities,” he added. “I’ve asked the client but they are not prepared to share anything at present. Sorry about that!”
However, Reid shed a little more light on the LLC, saying that the company “was formed to hold an asset,” but that the LLC “was never used because it wasn’t needed.” He did not clarify the nature of the asset or whether it was held under any other entity, and did not say whether the LLC would be shut down.
A tax document filed by Ardleigh Impact Corporation also identifies the company’s director as Casey Contres. Public records reveal only three people in the country with that name. The most prominent of them served as Dr. Oz’s campaign manager for his 2022 Pennsylvania Senate bid. Before that, Contres worked as chief of staff for Rep. Tony Gonzales (R-TX), as campaign manager for Sen. Cory Gardner’s (R-CO) 2020 Senate race, and as communications director for Rep. Bill Schuster (R-PA).
The address listed for Contres on the document does not appear to be his own. Instead, it’s the address for a property that belongs to Staci Goede, who is listed as the nonprofit’s treasurer. Goede has also been listed as the treasurer for numerous other groups, for which there is more publicly available information, including Virginia Gov. Glenn Youngkin’s (R) inaugural committee and a super PAC called Empowering Virginia Parents that received the bulk of its money from the governor’s super PAC, for which Goede also served as treasurer.
Contres and Goede did not reply to The Daily Beast’s request for comment.
Saurav Ghosh, director of federal reform at CLC, told The Daily Beast that Ardleigh’s nonprofit status “does not change the fact that it appears to have been used as a straw donor to funnel over $2.5 million to multiple super PACs.”
“As our complaint makes clear,” Ghosh said, “there is no indication that Ardleigh engaged in any activity from which it could finance these contributions without others giving it money for that purpose. And the apparent involvement of a well-known political operative only further supports the conclusion that Ardleigh was unlawfully used to conceal the true contributors’ identities from required public disclosure.”
Even if everything Ardleigh is doing turns out to pass legal muster, experts told The Daily Beast that the steps its creators took to obscure its purposes were all but guaranteed to spark suspicion.
“Everything about how this corporation was organized seems fishy,” Robert Maguire, vice president for research and data at Citizens for Responsibility and Ethics in Washington, told The Daily Beast. “Formed in Delaware, a state where people intentionally incorporate corporations because there is no disclosure requirement for… who is behind it, where the money might be coming from.”
“Then the fact that this corporation apparently, just months after incorporating, had enough money to pour millions into PACs, also raises more red flags,” Maguire continued. “All while it has no apparent public facing materials or business operations. It really checks all the boxes when it comes to the kind of questionable shell companies we have seen in campaign finance data.”
And because Ardleigh is registered as a 501(c)(4) nonprofit, it is tax-exempt with the understanding it is created exclusively to promote social welfare. But that doesn’t always turn out to be the case.
“501(c)(4s) are social welfare organizations that increasingly have been misused to spend money for political purposes,” Aaron Scherb, director of legislative affairs at Common Cause, told The Daily Beast. “Under the IRS tax code, they don't have to disclose their donors. And so that's why they've become a popular vehicle for people who are trying to use dark money to influence political outcomes.”
Technically, the law allows these types of nonprofits to engage in political campaigns, as long as doing so does not constitute their “primary activity.” But it can be tricky to define what is political engagement and what is a primary activity. For instance, a 501(c)(4) may argue that it spends 51 percent of its money on politics but the bulk of its time on other, exempt activities, like issue advocacy or public engagement. Such groups also frequently violate the spirit of the law by masking political advocacy as issue advocacy, for instance, by running ads that tell voters to “call their congressman” about a particular topic, rather than vote against him.
Ardleigh, of course, doesn’t currently seem interested in demonstrating to the public that it really does perform issue advocacy work.
“Just from an optics standpoint, they would need to have public facing websites, information about who's behind the group, who's employed by the group,” Maguire said when asked what would legitimize the group. “Basically make a case for their social welfare function beyond giving to political groups.”
Because nonprofits like Ardleigh are not intended to be used for political purposes, the group is not subject to the frequent filing deadlines that apply to super PACs, which fit neatly into the election cycle. The 501(c)(4) classification means that the group will not have to file a tax return until autumn of 2025, long after this year’s elections.
Thanks to FEC requirements, the public does have transparency around the more than $2.5 million the nonprofit poured into politics in February and March. Six entities have so far benefited from Ardleigh’s largesse. According to FEC records, Ardleigh directed $700,000 to a recently registered super PAC called Defend Ohio Values PAC, whose website features a video praising failed Ohio Senate candidate Matt Dolan; $625,000 to another pro-Dolan super PAC; $500,000 to the Congressional Leadership Fund; $400,000 to Conservatives for American Excellence; $200,000 to a super PAC backing Montana Senate candidate Tim Sheehy, and $150,000 to a super PAC that advocates for school choice at the state level.
Even if Ardleigh is engaged in legitimate nonprofit work, the public is unlikely to learn who furnished its funds.
Watchdog groups have argued for years that the decision of three Republican commissioners to deadlock votes on enforcement have prevented increased transparency. Scherb suggested that the deadlocks “seem to give a green light to straw donor schemes.”
“If they know that there's no action,” he said, “Or if they know that there's, at most, going to be a slap on the wrist, it sends a signal that there can kind of be the Wild West again of campaign finance laws.”
