$1.4 Billion. Zero Names. Your Policy.

A VALOR Institute Investigation into the $1.4 Billion Donor-Advised Fund Pipeline

Section 1: The Dark Money Pipeline

Understanding the scale of dark money in policy requires understanding the architecture of the funding network. The pipeline begins with donor-advised funds (DAFs), charitable vehicles that allow high-net-worth individuals to receive immediate tax deductions while maintaining control over where their money ultimately flows.

In 2024, DonorsTrust—the primary vehicle for funneling conservative dark money—distributed $195.3 million to over 300 conservative-aligned organizations.1 The growth is staggering. America First Legal Foundation, a litigation organization without traditional legislative expertise, received $21.3 million in 2024—a jump from $3.2 million in 2023. America First Policy Institute, another policy shop, jumped from $159,000 to $4.4 million in identical funding from donor-advised vehicles.2

This is not unique to DonorsTrust. Fidelity Charitable, Schwab Charitable, and Vanguard Charitable—three of the largest custodians of donor-advised funds—helped channel an estimated $171 million through their platforms to policy organizations in 2024.3 The fundamental structure remains identical: donors are shielded from public view, recipients are classified as tax-exempt policy organizations, and the policy influence is real and measurable.

The core problem is architectural. A tax-deductible donation to a think tank carries no requirement that the donor be disclosed. A corporation or individual can fund a policy position that benefits them financially while remaining completely anonymous. A foreign government can fund a think tank that advocates for military intervention in its region. A defense contractor can fund research promoting military spending. The American public never knows.

Over one-third of America's top foreign policy think tanks disclose little or no information about their funding sources.4 Yet these organizations write the model legislation that congressional offices introduce, conduct the polling that shapes executive branch priorities, and provide expert testimony before committees that authorize military spending and foreign policy decisions affecting millions of Americans.

Senator Grassley's Think Tank Transparency Act addresses this directly by requiring policy organizations to disclose major donors the same way corporations disclose shareholders. The bill is not ideological. It applies equally to organizations across the political spectrum. The principle is straightforward: if you are shaping American policy, Americans deserve to know who is paying you.

Section 2: Case Study—A $206 Million Influence Network

To demonstrate how this pipeline operates in practice, the VALOR Institute investigated one of the most well-documented influence networks in American politics. This network demonstrates the full pipeline: donors remain anonymous, organizations maintain tax-exempt status, policy influence is measurable and consequential, and public accountability is minimal to nonexistent.

Funding Architecture

Between 2017 and 2019, 35 charitable institutions distributed $105.8 million to 26 organizations within this network.5 Looking back further, between 2001 and 2009, seven conservative foundations distributed $42.6 million to these same organizations.6 Total documented network funding: $206 million. Actual funding was almost certainly higher, as donor disclosure varies by organization.

The organizations at the center of this network include:

• Center for Security Policy (CSP), which received funding for research on domestic security issues
• Middle East Forum (MEF), which conducted research and advocacy on Middle Eastern affairs
• Foundation for Defense of Democracies (FDD), which focused on counterterrorism and foreign policy
• David Horowitz Freedom Center, which conducted media and policy analysis

Cross-funding within the network amplified influence. Middle East Forum distributed $1.4 million to the Center for Security Policy and $1.4 million to the Institute for Policy Studies' opposition organization, multiplying the reach of donor funding.7 Donors Capital Fund, itself a pass-through vehicle for right-wing donors, distributed $6.8 million to Middle East Forum alone.8

Defense Contractor Funding

A critical component of this network's funding came from defense contractors. Boeing donated $25,000 to the Center for Security Policy; Raytheon contributed $20,000; Lockheed Martin and General Dynamics each donated $15,000.9 These donations appear modest in isolation but carried strategic significance: they came from corporations with billions of dollars in government contracts, funding organizations whose policy research influenced whether future contracts would be approved.

The conflict of interest is structural. A think tank that receives funding from a defense contractor has a financial incentive to produce research supporting increased military spending, expanded military intervention, or strengthened defense relationships. A donor that funds think tank research supporting military expansion has an incentive to obscure this relationship from public view.

International Funding and Undisclosed Foreign Money

Foundation for Defense of Democracies received $2.5 million wired from the United Arab Emirates through a Canadian intermediary in 2008.10 The organization at the time was claiming that it did not accept foreign government funding. The transaction was documented in public tax filings but received minimal journalistic attention.

This case illustrates a second critical problem: the difficulty of tracking foreign government funding when it flows through intermediaries. A foreign government can fund American think tanks that influence American policy, and American citizens may never know because the money is routed through corporate entities, charitable trusts, or shell organizations.

Section 3: The Policy Impact Machine

Funding matters only if it translates to policy influence. This network demonstrates that it does, consistently and measurably.

The Center for Security Policy, at the center of this network, commissioned polling conducted by Kellyanne Conway's firm. This polling, which shaped CSP's published research, was cited directly by then-candidate Donald Trump in 2015 and later used to justify the 2017 travel ban affecting Muslim-majority nations.11 The polling data itself was funded by anonymous donors. Trump cited it without disclosing that it was commissioned by a think tank funded by conservative foundations and defense contractors.

A 55-member congressional caucus built its legislative platform directly on policy research produced by these organizations.12 Seven federal bills—affecting immigration, national security law, and foreign policy—were introduced to Congress using model legislation drafted by network organizations.13

The influence extended beyond legislation. The Quincy Institute's Think Tank Funding Tracker now monitors 75 foreign policy think tanks and has documented that organizations receiving funding from defense contractors and foreign governments consistently advocate for military intervention and foreign policy positions that benefit their funders.14

Consider the case of Iran policy. Over the past two decades, think tanks receiving funding from defense contractors have been disproportionately represented among public advocates for military escalation with Iran. Those same organizations receive funding from countries in the region that benefit from U.S. military confrontation with Iran. The public sees policy research and expert testimony. What the public does not see is the funding relationship that created the incentive for that research and testimony.

This is the core problem: policy influence without transparency creates democratic accountability deficit. When citizens cannot see who is funding the experts shaping policy, they cannot evaluate whether that expert is giving disinterested advice or advocating for a funded position.

Section 4: A Bipartisan Problem, A Bipartisan Solution

Dark money in policy is not a partisan problem. Both conservative and progressive think tanks have benefited from donor-advised fund flows that obscure the source of their funding. Both have faced criticism for policy advocacy that appears to align with their major donors' interests. Both have resisted transparency about major funding sources.

The solution, however, is bipartisan. Senator Charles Grassley (R-Iowa), who chaired the Senate Finance Committee, has made think tank transparency a signature issue. In 2025 and again in 2026, he reintroduced the Think Tank Transparency Act, which would require policy organizations to disclose major donors using the same Schedule B format that corporations use to disclose shareholders.

Congressman Jack Bergman (R-Michigan) introduced companion legislation in the House. The principle underlying both bills is simple: if you are shaping American policy, Americans deserve to know who is paying you. The legislation does not ban dark money. It does not restrict donations. It requires only that policy organizations answer the same transparency question: Who funds this institution?

Heritage Foundation President Kevin Roberts has stated that conservative think tanks should support this legislation. The progressive Brookings Institution has called for similar transparency standards. The Quincy Institute, which conducts research on foreign policy, has become an advocate for think tank funding transparency after discovering the extent of defense contractor influence in the foreign policy space.

The VALOR Institute's position aligns with this consensus: accountability is not partisan. Every think tank—left or right, defense-funded or foundation-funded—should disclose major funding sources. The American people, not donors, are the constituency for public policy.

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Section 5: Methodology & Sources

Conclusion

The American political system is built on the principle that the people are sovereign. That sovereignty is meaningful only when citizens can see how power operates. When $1.4 billion flows through donor-advised funds to policy organizations, when defense contractors fund think tanks that shape military policy, when foreign governments fund organizations influencing national security decisions, and when American citizens cannot see these relationships, that sovereignty becomes theoretical rather than real.

This is not an argument against think tanks, against policy research, or against private funding of institutional research. It is an argument for transparency. The same conservatives who argue that government spending requires public accountability should support the principle that policy influence requires donor accountability. The same progressives who advocate for corporate transparency should support the principle that think tank influence requires funding transparency.

Senator Grassley's Think Tank Transparency Act represents a straightforward solution: require policy organizations to answer the same question that applies to every other institution seeking to shape American policy. Who is funding you? American voters deserve an answer.