In 2024, while Department of Homeland Security Secretary Kristi Noem still served as governor of South Dakota, her personal company, Ashwood Strategies LLC, again received a cut of the money raised for a nonprofit that promotes her interests, according to a tax return obtained by CREW. The payments to Noem’s firm and another tied to her top advisor, Corey Lewandowski, were two of the group’s largest payments in 2024, amounting to a fourth of its overall spending for the year. 

The nonprofit American Resolve Policy Fund reported paying $137,842 to Ashwood Strategies LLC for “fundraising consulting,” a more than 70 percent increase from what the group paid Noem’s company in 2023. Since American Resolve Policy Fund—which claims to have no employees and provides zero information about its mission, operations or leadership on its bare bones website—is not required to disclose its donors and has a stated policy to not voluntarily “disclose any donor to the public,” the original sources of the funds that ultimately flowed to Noem are unknown. 

Last year, ProPublica reported that Noem did not disclose any income from American Resolve Policy Fund on her federal financial disclosure form, despite the nonprofit’s reporting on its 2023 tax return that it paid Ashwood Strategies $80,000 for fundraising services. The $137,842 that American Resolve Policy Fund paid Ashwood Strategies in 2024 is also not disclosed on Noem’s financial disclosure form. 

On her disclosure form, which she signed on December 24, 2024, Noem listed herself as managing member of Ashwood Strategies and described the company as dealing with “personal activities outside my official gubernatorial capacity.” Noem also committed in her signed ethics agreement to resign from her Ashwood position upon confirmation as DHS secretary, but said she would “continue to have a financial interest” in the LLC while not providing “services material to the production of income.”

Ethics experts told ProPublica that Noem’s personal financial connection to a group that supports her politically was “highly unusual” and “troubling,” while raising the possibility that her failure to report income from American Resolve Policy Fund could violate federal ethics requirements. In response to the reporting, Noem’s lawyer told ProPublica she “fully complied with the letter and the spirit of the law” and “fully disclosed all of her income.”

According to its tax return, American Policy Resolve Fund raised $1,435,818 in 2024 and Noem’s Ashwood Strategies was responsible for 99 percent of it. The $137,842 Ashwood Strategies retained amounted to a 9.6% cut of the money raised, a slightly smaller percentage than Noem’s company retained in 2023. ProPublica noted that a professional fundraiser who also raised money for American Policy Resolve Fund in 2023 was paid a lower rate of 7%. That fundraiser, JBest Company, was not listed on the 2024 tax return as providing fundraising services.

In addition to paying Noem’s company in 2024, American Policy Resolve Fund also paid the company of one of her closest advisors, former Trump campaign manager Lewandowski. The nonprofit paid $265,500 to his company, Lewandowski Strategic Advisors LLC, for management and strategic consulting. 

Lewandowski, who was reportedly blocked from becoming Noem’s chief of staff at DHS, has served as her chief advisor and has been described as a powerful gatekeeper for the cabinet secretary. He is a special government employee, which allows him to work for the government on a temporary basis while facing less rigorous ethics and transparency restrictions than full-time government employees. As an unpaid SGE, Lewandowski is not required to make public financial disclosures, so it is not readily knowable whether he reported income from the pro-Noem nonprofit.

American Resolve Policy Fund’s payments to Lewandowski’s company represented one of the nonprofit’s largest expenses in 2024, as did its fundraising payments to Noem’s company. The nonprofit also reported spending $165,500 on polling, $281,425 on advertising and promotion, and $291,741 on travel. 

As ProPublica reported, American Resolve Policy Fund’s $83,712 travel budget represented one of the group’s main areas of spending in 2023, but it was not clear whose travel the group paid for. The 2024 tax return, however, offers a hint about who benefitted from its travel spending as the nonprofit disclosed that it spent $71,371 on “payments of travel or entertainment expenses for any federal, state, or local public officials.” 

American Resolve Policy Fund continued to benefit Noem after she joined the federal government in 2025, using its social media accounts to promote Noem-related content, and even paying for Facebook ads attacking a South Dakota news outlet that reported on her use of state-issued credit cards. Whether the nonprofit was also continuing to pay her company will not be known until the group files its taxes for 2025.

Photo of Kristi Noem by Gage Skidmore under Creative Commons license

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