By Matt Corley
March 1, 2017

A political non-profit that made waves last year by completely funding a super PAC boosting now-Missouri Gov. Eric Greitens (R) may have lied to the Internal Revenue Service on its 2015 tax return. Either that, or another super PAC that reported a contribution from the non-profit listed incorrect information on a 2015 report to the Federal Election Commission (FEC).

Freedom Frontier, a section 501(c)(4) tax-exempt organization, filed a shortened tax return for 2015, known as a 990-N, claiming gross receipts no greater than $50,000. But FEC records say Freedom Frontier contributed $250,000 to a super PAC, Security is Strength PAC, in November 2015. At the time, the super PAC was paying for independent expenditures supporting Sen. Lindsey Graham’s (R-SC) presidential efforts.

It’s theoretically possible, but extremely unlikely, that Freedom Frontier could have made the super PAC contribution while raising no more than $50,000 in 2015. The non-profit has claimed receipts of $50,000 or less every year since 2011, when it first filed with the IRS, suggesting that the organization could only afford the $250,000 contribution if it received exactly $50,000 every one of those years and never spent a penny. Otherwise, the contribution could only have been made if the group raised more than $50,000 in 2015 or one of those years, which would make the information on that tax return false.      

Freedom Frontier, which has also done business as Citizens for a Secure Community, is known to have spent money before, blowing the slim chance that the group’s 2015 super PAC contribution was the sum total of all its previous fundraising. In 2012, Citizens for a Secure Community intervened in the Wilmington, DE mayoral race with direct mail pieces praising one candidate and bashing the other. The mailings would have required the expenditure of some money, though it is not known how much money the group actually spent.  

Another possibility is that the super PAC misreported the contribution as coming from Freedom Frontier rather than another donor. Security is Strength PAC reported the contribution on its 2015 year-end report, which it subsequently amended twice after receiving letters from the FEC’s Reports Analysis Division. The $250,000 contribution from Freedom Frontier, however, remains listed in the most recently filed amendment.  

The new tax return also reveals that Freedom Frontier is now working with a member of an infamous dark money network that has injected anonymous money into elections across the country since at least 2010. Joel Riter, a former aide to Ohio Treasurer Josh Mandel, is now listed as the principal officer of Freedom Frontier, a change from 2014 when John Jude, who has ties to another Greitens-supporting non-profit, was listed.

Freedom Frontier’s seemingly false tax return fits a pattern established by other groups associated with Riter’s network of playing fast and loose with the IRS.

According to the most recent tax documents available, Riter also is the chairman of the Government Integrity Fund and the president of Citizens for a Working America, two dark money non-profits that have spent significant sums on politics while keeping their donors secret. Both of these Riter-led groups contributed to Security is Strength PAC in 2016. CREW filed an IRS complaint against the Government Integrity Fund in October 2016 for not only violating its tax-exempt status by acting primarily as a political group, but also for taking extraordinary steps to avoid disclosure of its political activities.

In 2016, CREW also filed IRS and Justice Department complaints against another group with ties to Riter, the Jobs and Progress Fund, for failing to disclose more than $400,000 it spent on political activity in 2014 to the IRS. Tom Norris, the former president of the Jobs and Progress Fund, hired Riter at his Ohio-focused lobbying firm after he left Treasurer Mandel’s office. Norris, who recently served on the Trump transition team, also used to be listed as the executive director of the Government Integrity Fund. CREW also filed an IRS Complaint in 2016 against Freedom Vote, a political non-profit with past personnel ties to Freedom Frontier, Citizens for a Working America, and the Jobs and Progress Fund.

Norris was also involved with Security is Strength PAC around the time of Freedom Frontier’s contribution. Norris is the president of 406 Enterprises, which was paid $232,396 by Security is Strength PAC in the fall of 2015 for mobile advertising boosting Sen. Graham in the Republican presidential primary.

Security is Strength PAC also paid $77,988 during the 2016 cycle to a law firm called Langdon Law that is associated with the dark money network.  On its website, Langdon Law advertises “expertise regarding the ability of 501(c)(4) social welfare organizations to engage in permitted election activities, and in issues relating to affiliations among tax-exempt entities.” David Langdon, the founder of Langdon Law, was previously the treasurer of the Jobs and Progress Fund and is currently the treasurer of a super PAC with basically the same name as one of the non-profits Riter runs, Citizens for a Working America PAC.

Riter, Norris, and Langdon, along with other political operatives with whom they work, aggressively exploit loopholes in America’s campaign finance system and stretch the law to spend money on politics while keeping donors secret. Sometimes the network spends money directly through its non-profit groups, usually with sham issue ads they pretend aren’t political. At other times, the network engages in dead end disclosure by using its non-profit groups to fund super PACs, obscuring the true source of the money.

According to an analysis by CREW, six non-profits with ties to this dark money network – A Public Voice, the American Policy Coalition, Citizens for a Working America, Freedom Frontier, Freedom Vote, and the Government Integrity Fund – contributed $9,651,625 to 10 super PACs active in the 2016 election cycle. Several of the super PACs, like Fighting for Ohio Fund and Arizona Grassroots Action PAC, only spent money in support of one candidate. In addition, Citizens for a Working America, which contributed $235,000 to the super PAC boosting Sen. John McCain’s (R-AZ) re-election, also spent $144,899 directly on mailings and phone calls boosting the senator. Citizens for a Working America was the only one of the six non-profits to report direct expenditures to the FEC.

If Security is Strength PAC did incorrectly list Freedom Frontier as the $250,000 contributor in November 2015, it wouldn’t be the only time part of this dark money network listed the wrong donor on a campaign finance report. On October 27, 2016, Americans United for Values, as super PAC that also paid Langdon Law during the 2016 cycle, filed a report with the FEC disclosing the receipt of $90,000 from the American Policy Coalition, a non-profit affiliated with Langdon that, like Freedom Frontier, completely funded a super PAC that aided Greitens’ gubernatorial campaign. Four days later, Americans United for Values amended the FEC report, replacing the American Policy Coalition with another Langdon-affiliated non-profit, A Public Voice, Inc.

It looks like keeping track of so many different entities can be difficult. The information on Freedom Frontier’s 2015 tax return and Security is Strength PAC’s 2015 year-end report to the FEC appear to be in direct contradiction of each other. In other words, one of these filings very likely contains false information. Both possibilities raise additional questions. If Freedom Frontier did make the contribution, how much did the organization spend overall in 2015 and was politics its primary purpose? On the other hand, if Freedom Frontier didn’t make the contribution to Security is Strength PAC, then who did?

Dark money network graphic by Maya Gold. Updated for clarity.