How PACs Donate Without Disclosing Donors
The FEC allows unlimited contributions to "dark money" groups that don't have to disclose their donors. These seven vehicles make it happen. Here is how each one works.
The Seven Dark Money Vehicles
The DISCLOSE Act: What It Would Do
The DISCLOSE Act — passed by the House in 2022, died in the Senate — would have required organizations spending more than $10,000 on politics to disclose donors above that threshold. It would have closed most of the LLC loophole, required (c)(4) organizations to disclose donors above $10,000, and mandated that Super PACs disclose the original source of any contribution over $10,000.
Every major dark money organization — left and right — lobbied against it. The Koch network alone spent an estimated $12 million opposing the DISCLOSE Act in 2024. The bill has not been reintroduced in the 2025-2026 session.
The LLC Loophole in Practice
In the 2024 cycle, SlushFund identified at least $340M in contributions from LLCs to political organizations where the true beneficial owner was not disclosed. In 23 cases, the LLC was incorporated fewer than 90 days before making a contribution of $1M or more. In 7 cases, the LLC was incorporated after the election and contributed to groups that spent money in that same election.
Why This Persists
The FEC is designed to be evenly split between the two major parties. That split means any enforcement of existing dark money rules requires bipartisan agreement — which has not happened since 2012. The commission has had a deadlocked vacancy since 2023. It cannot enforce its own rules because it cannot achieve the required majority vote.
The gap between what the law says and what the law does is where dark money lives.
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