State of Wisconsin Ethics Commission February 11, 2025
Wisconsin Department of Administration Building
101 E. Wilson Street, Suite 127, Madison, WI 53703
I, Jay Stone, allege that:
The Susan Crawford of Wisconsin (“SCW”) registered campaign committee is using fictitious names to fund its campaign. In this fraudulent scheme, 1,397 real citizens' names are being used without their knowledge or permission. The total amount is $63,903.63 and is comprised of over 2,179 transactions. This allegation is conservative and not exhaustive.
From the Ethics Website: “Any person may file a complaint with the Commission asking that it investigate alleged violations of campaign finance laws under Chapter 11 of the Wisconsin Statutes.” I request a full investigation be conducted on SCW. Several Wisconsin campaign finance statutes have been violated including, but not limited to:
1) 11.1303(1) No disbursement may be made anonymously and no contribution or disbursement may be made in a fictitious name or by one person or organization in the name of another.
2) 11.1204 Unlawful political contributions.
(1) Subject to sub. (2), no person may, directly or indirectly, make any contribution other than from funds or property belonging to the person. No person may, directly or indirectly, give funds or property to another person for the purpose of making a contribution in other than the first person's name.
(3) No person may intentionally receive or accept any contribution made in violation of this chapter.
3) 11.1201 False reports and statements. No person may prepare or submit a false report or statement to a filing officer under this chapter.
There is more than enough reasonable suspicion that justifies Ethics to take action, i.e. opening a full investigation into SCW. Here, my evidence on “Crawford Exhibit A" shows that campaign violations have been committed. The facts show reasonable suspicion that campaign violations are occurring with the use of fictitious donors (using real people’s names and addresses without their knowledge). Part of their scheme is to mix legitimate contributions with fictitious ones. These people are known as Smurfs, and the scheme is known as Smurfing. See https://www.investopedia.com/terms/s/s/smurf.asp for a concise explanation.
Smurfs are a) over the age of 65, b) largely have occupations recorded as: unemployed, not employed, retired, unknown, or none, c) have extraordinarily high number of contributions. These transactions are being electronically executed using computer bots. Bots are a kind of computer algorithm.
Evidence in this complaint strongly shows that the recorded donors may not be the actual sources of these funds. The SCW campaign must ensure that every suspicious donation listed is legitimate and originates from the stated donor. Per Chapter 11 ignorance cannot be a defense for accepting illegal donations. § 11.1400(7),(8).
David J Mahoney, the SCW treasurer listed on the CF-1 form and Park Bank, 33 E Main St., Madison, WI is the financial institution listed under “depository information”. The financial platforms used to deposit funds into the SCW campaign are in question. SCW uses ActBlue Express as a contribution processor, see https://www.crawfordforwi.com/ Another platform SCW is using is also ActBlue but on a different platform:
https://secure.actblue.com/donate/sc-ads-240611search?refcode=SC_ATA_ADS_Search_D2D_240612_Launch_Keywords_Wisconsin_Contextual_Headline_T ext&gad_source=1&gclid=CjwKCAiAm67BhBlEiwAEVftNrnhTkepYmNtWfbV6tMD0_YECOUDQpULsJEQZWpAhjwPFrqBbvkjxoCLL4QAvD_BwE
ActBlue is under investigation by The House Administration Committee headed by US Congressman Brian Steil for not having adequate financial controls. Twenty (20) U.S. Attorneys General are also investigating ActBlue for not verifying that the merchant card(s) used to make donations are legally tracked back to the legal owner of the name and address. ActBlue has only recently required CVV codes, but only for new donors, which is the 3-digit number on the back of the credit or debit card. It is one security measure to prevent fraudulent activity. This leaves the over 300,000 Smurfed names used at the FEC and state levels still unchecked to make sure the names and the addresses used are tied back to legitimate bank accounts.
On Feb 7, 2025, The Last Refuge published an article laying out the current news that Consumer Financial Protection Bureau (CFPB) and United States Agency for International Development (USAID), both government agencies, schemed to manipulate election outcomes thru the U.S. Treasury Department. They stated:
“The Act Blue money laundering operation took the hundreds of millions in funds from sketchy network sources attached to the CFPB/USAID, then assigned those funds to random names in the donor files of the Act Blue system; essentially washing away the fingerprints so the FEC could not identify the larger funding mechanism behind the fraudulently assigned individual donors. This is the trail that James O’Keefe was following.”
I request the following:
- That the Crawford campaign cease and desist using ActBlue and accepting donations from the Democratic Party of Wisconsin who also uses ActBlue for their third-party processor.
- That SCW and CFIS join D.O.G.E., the Attorney Generals, US Congressman Steil, and US Senator Ron Johnson, in investigating these highly suspicious donations where ActBlue is a conduit.
- That CFIS should impose stricter regulations on managing third-party political processors and online recording platforms.
- That the Wisconsin Ethics Commission investigate and confirm that the individuals listed in Crawford Exhibit A are the true sources of the donations attributed to them. By contacting, in addition, Merchant Services who are processing the transactions including Visa and Mastercard.
The data on the attached excel spreadsheet(s) includes information from a) SCW Campaign CFIS download from 6/10/24 to 12/31/24, b) official open sources, c) an FEC export of individual donors. This per an email from Open Secrets who reports heavily on campaign contributions. They found the average number of contributions, for a person making such political contributions, is 4.2 donations per donor per candidate per election cycle (two years). Or thus 2.1 per year. In support, per the FEC contributors who are making political contributions make on average 1.4 contributions per year. This means it is unusual to have 1,397 unique donors contribute to SCW in excess of two times and also contribute to the Federal campaigns more than 1.4 contributions per year. This is one fact showing a reasonable suspicion.
Considerations for Four SCW Donor Profiles
The following are five examples from hundreds of SCW donors that could be included in this complaint. These profiles illustrate typical characteristics of "Smurf" donors used to bolster the SCW campaign's fundraising efforts. The FEC data helps identify Smurfs and Smurfing, but I am not filing anything from the FEC against the SCW campaign. Key points to understand:
1. Unknowing Use of Contributor Identities
The donor ("Smurf") is often unaware that their name is being used. If asked by CFIS, they may confirm they made the contributions, not realizing some donations were legitimate while others were not. This confusion allows for fraudulent reporting to go unnoticed.
2. Tracking Donations Across State and Federal Levels
o Donations to federal candidates are recorded by the FEC, while donations to Wisconsin statelevel candidates are recorded in the Wisconsin Campaign Information Systems (CFIS).
o It is essential to consider both state and federal donation records cumulatively when analyzing the frequency and amounts of contributions attributed to a single donor.
3. FEC Data Export Discrepancies
o The FEC provides two methods for accessing donor transaction information:
▪ Real-time (RT) lookup: Available on the FEC website for public use.
▪ Bulk download: Allows exporting data based on specific criteria.
o Suspiciously, the bulk download data almost always lists fewer transactions per donor than the RT lookup, raising concerns.
o Understanding FEC Transaction Codes
▪ The FEC uses 13 transaction-type codes to classify individual donations.
▪ FEC Bulk download allows only donor transactions with transaction codes. When performing a RT look up and export of the same donors found on the bulk download, the blank transaction lines appear with a description in another column “earmarked”. No code or explanation where the donation was earmarked to. This discrepancy suggests incomplete or inaccurate reporting making auditing impossible and left up to interpretation. Meaning, millions and millions of transactions are missing codes.
o Why Missing Transaction Codes Matter
▪ Bulk downloads are the primary source of FEC-reported data, while real-time lookups provide a complete tally of transactions per donor and has to be accomplished by implementing AI tools. Thus, I am presenting the RT tallies per individual that were obtained from AI or hand FEC RT look ups. The absence of transaction codes in bulk data could indicate irregularities or attempts to conceal fraudulent activity.
4. FEC Reporting Threshold and Underreported Contributions
o According to the FEC:
▪ Candidate committee contributions are included if they exceed $200 per election cycle.
▪ PAC and party committee contributions are reported if they surpass $200 in a calendar year.
o Donations below these thresholds are not included in FEC reports, leaving a gap in the recorded data. This underreporting may enable large-scale fraudulent activity to go undetected.
These profile studies and data discrepancies demonstrate the need for thorough scrutiny to ensure transparency and accountability in campaign donations.
NOTE: SCW has 7,252 unique donors comprised of 10,043 donations. 42% of the unique donors are from out of state. It is common to see Smurfs’ who live in other states being used in local Wisconsin elections as there are 300,000 Smufs to choose from according our estimations. Compare the 42% out of state to her Republican opponent’s 2% out of state donations.
Individual Contributions Between 6/10/24 and 12/31/25
SCW Donor Profile Studies
Key for the following charts. Note the FEC data is always fluid from day to day.
RT Trans: Transaction lines from Real Time FEC individual lookups
RT Blanks: Transaction lines with blank (missing) transaction codes derived from current individual look ups
1) Mark Jennerjohn, Appleton, WI (age 66), shows 17 donations to total $1,535 to SCW between 6/10/24 and 12/27/24.
Current RT Trans Current RT Blanks
-Blank transaction codes are attributed to ActBlue, KRISTIN LYERLY FOR CONGRESS, DSCC, DEMOCRATIC STRATEGY INSTITUTE, WinRed, and various other politicians and PACs.
-Mr. Jennerjohn donated 746 times to various Wisconsin politicians and PACs since 2019 to total $22,046.28. Donations included 29 times to Janet for Justice, also a Supreme Court race in 2024, to total $2,960. 47 donations were made to Josh Kaul in 2018 to total $527.
-2,756 FEC transactions are attributed to Mr. Jennerjohn in 2020 (avg 7.5/day) and 748 in 2024 (avg 2/day).
- On Thursday, April 6, 2023, a Private Investigator was hired by ElectionWatch who visited Mr. Jennerjohn. This is an excerpt from the PI report: “The subject stated he is disabled, not clothed, but would speak to the investigator at the front door. Upon speaking to the subject regarding his political donation history, he denied making 7,878 donations as well as the dollar amount reported, $93,168. The subject scoffed at the amount and stated, “look where I’m living!” The subject referred to the modest, run-down, small apartment on the second floor of a modest converted home. He stated he donates $5 at times but could never afford to donate over $90,000 in the last 7 years.” This report along with recorded video of Mr. Jennerjohn is available.
-Wisconsin 915 donations attributed to Mr. Jennerjohn between 7/14/2016 and 6/30/2023 total $24,714.28. The daily patterns show a computer bot is doing these transactions, not a human being.
-Federal 5,659 transactions (that don’t include blank transaction lines) attributed to Mr. Jennerjohn between 6/3/2017 to 12/30/2022 total $90,772.
2) Trina Westerlund of Bellevue, Washington, is 86 years old. She donated a total of $5 to SCW. The donation amount is secondary to the copious number of unusual transactions recorded at the Federal Election Commission (FEC) and donations to Wisconsin state candidates between 2019 and 2024.
-11,781 FEC transactions attributed to Ms. Westerlund in 2020 (avg 32/day) and 8,198 in 2024 (avg 22/day).
-119 FEC transactions on just one day 10/31/24. 981 FEC transaction in November 2024. -Blank transaction codes are attributed to ActBlue, END CITIZENS UNITED, STOP REPUBLICANS, NATIONAL DEMOCRATIC TRAINING COMMITTEE PAC, and many various other PACs.
-Ms. Westerlund was visited by a Private Investigator on 1/2/2025, who asked her about the 41,542 transactions. She said they seemed correct to her, but as mentioned above, this is part of the fraudulent
scheme. Ms. Westerlund is being used as a fictitious donor and she doesn’t know it. One can truly know only when bank statements are available to compare and confirm. This chart clearly shows computer bots making the transactions. The red line is the number of contributions each day (left side of chart). It shows an 86-year-old woman regularly making 30, 50, 70 contributions in one day, over and over for years. This is not normal human behavior. The dollar amount is shown using the green colored line (right side of chart for $ amounts).
Counts/Amountsin ~4y1m21days - 1/15/2019 -> 3/7/2023 ,1,512 days 21,451 Trxs@ $91,029 in 1,164 Trxdays,AveragingTrxsevery 1.3 days 10/31/2022 :NUMTRX: 74,TRXAMT: $226
3) Harold Copeland, Houston, TX: donated twice to SCW totaling $50.00. And this demonstrates one method of how Smurfing works: using numerous unsuspecting Smurfs from across the nation to contribute small dollar amounts. If you contact Mr. Copeland, it is likely he will say he made or is making contributions to various political campaigns. And some of those will be legitimate. But his credit or debit card statements will not match up with what the state DNC is reporting or what the FEC is reporting. Current
-Blank transaction codes are attributed to ActBlue, Gloria for Tennessee, LET AMERICA VOTE PAC, NATIONAL DEMOCRATIC REDISTRICTING PAC and many other campaigns and PACs.
-8,339 FEC transactions are attributed to Mr. Copeland’s name in 2024 (avg 23/day).
-A street address is needed to verify a credit card payment. (281 SCW donors have PO Boxes)
-Mr. Copeland has also donated 65 times to various politicians since 2019 including 5 times to Janet for Justice, also a Wisconsin Supreme Court race.
4) Lynn Shoemaker, Whitewater, WI (85 years old): donated 5 times to SCW (12/27, 12/28, 12/29 and twice on 12/31) to total $21.
Current RT Trans Current RT Blanks 17,580 9,656
-6,106 FEC transactions are attributed to Mr. Shoemaker in 2020 (avg 17/day) and 1,912 in 2024 (avg 5/day).
-Mr. Shoemaker donated 394 times to various Wisconsin politicians since 2019 including 71 times to Janet for Justice also a Supreme Court race.
-Blank transaction codes are attributed to ActBlue, PROGRESSIVE TAKEOVER, AMY MCGRATH FOR SENATE, INC., ELECT DEMOCRATIC WOMEN and various other PACs.
-On Tuesday, April 4, 2023, a PI hired by ElectionWatch visited Mr. Shoemaker. This is an excerpt from the PI report: “The subject stood near the front door for the interview. Upon speaking to the subject regarding his political donation history, he confirmed that he made 6,706 donations in the last 7-years. The subject however, the investigator stated outright Mr. Shoemaker was not telling the truth, was deceptive in his responses. Later in the in-person interview, Shoemaker stated that his “daughter would help him decide where donations would go.” It was said in a manner to cover what he had told the private investigator earlier.
5) Gloria Page, Los Altos, CA. Donated $1,000 to SCW and $1,393,370 in Wisconsin campaigns and Democratic Party of Wisconsin PAC in 2024.
-Ms. Page’s address is 171 Main St #253, a UPS store https://locations.theupsstore.com/ca/los-altos/171main-st?utm_source=Yext&utm_medium=organic&utm_campaign=Listings
-Other box addresses found at the same UPS store are six non-profit organizations that give out grants, two of which have/are receiving USAID funding. One to China for $241,000 in 2024. Another touted giving out grants to “nurture a spirit of philanthropy among the younger generation of China and of the greater Chinese Diaspora”. These stores with addresses, that look like legitimate locations, are hotbeds for potential money laundering and anti-American propaganda.
- Evidence from 1/15/25 FEC bulk download shows 5,581 transactions attributed to Gloria Page at zip 94022. On 2/11/2025 FEC RT look up shows 3,700 transactions. What happened to the 1,881 difference in transactions? How many other SCW donors that donated at the federal level have a similar history?
Conclusion: I have shown reasonable suspicion these contributions are not being made to SCW by the provided names/addresses but by someone using these names and addresses fictitiously.
Enclosures: Crawford Exhibit A
References: https://www.fec.gov , https://ethics.wi.gov/Pages/CampaignFinance/CampaignFinance.aspx, https://electionwatch.info/