July 16th 2025

End Citizens United Files DOJ and OGE Complaint Calling for Federal Probe into Sec. Kristi Noem’s Undisclosed $80,000 Dark Money Payment  

WASHINGTON, DC — Tiffany Muller, president of anti-corruption group End Citizens United (ECU), this week submitted a formal request to the U.S. Office of Government Ethics and the Department of Justice’s Public Integrity Section, calling for a federal investigation into whether Homeland Security Secretary Kristi Noem violated financial disclosure laws by failing to report an $80,000 personal payment from a dark money group during her tenure as South Dakota governor. The complaint—first reported by the Sioux Falls-based independent newspaper The Dakota Scout—can be read in full here. 

According to the complaint, Ashwood Strategies, LLC was incorporated in Delaware in June 2023, with then-Governor Noem listed as the Managing Member. Later that year, Noem received $80,000 in payments from the American Resolve Policy Fund—a nonprofit led by her former campaign treasurer—funneled through Ashwood Strategies. After her nomination by President Trump to serve as Secretary of Homeland Security, Noem failed to disclose the $80,000 payment on her Executive Branch Personnel Public Financial Disclosure Report filed with the Office of Government Ethics.

“This reeks of a shell game,” said ECU President Tiffany Muller. “Noem—already no stranger to ethics scandals—secretly took an $80,000 payment from a shadowy dark money group and flagrantly broke federal law by hiding it from both the public and government watchdogs. What’s worse: we still have no idea who’s behind this money or what conflicts of interest it has created. It’s deeply unsettling that someone with a record of using public office for personal gain now controls the nation’s most heavily funded federal law enforcement agency.”

The complaint states, in part: “Federal law requires members of the Executive Branch to report ‘all income from whatever source derived.’ The facts in this matter are clear, Secretary Noem failed to disclose an $80,000 payment from American Resolve Policy Fund, a nonprofit managed by Secretary Noem’s former campaign treasurer Staci Goede.”

The complaint goes on to urge the Office of Government Ethics and the Department of Justice to investigate the circumstances surrounding Secretary Noem’s Public Financial Disclosure Form, as well as the activities of Ashwood Strategies, LLC and the American Resolve Policy Fund.

Since its founding a decade ago, ECU has led the fight against dark money and corruption in Washington, filing dozens of complaints exposing violations of campaign finance and ethics laws. Earlier this year, ECU called for a federal probe into whether President Trump’s pardon of former nursing home executive Paul Walczak was an illegal bribery-for-pardon scheme.

ECU President Tiffany Muller is available for interview to discuss the complaint against Secretary Noem and the broader issues of corruption and self-dealing that have characterized the Trump administration’s second term. To request an interview, please contact Kolby Lee (kolbylee@endcitizensunited.org).