While serving as South Dakota’s governor in 2023, Kristi Noem received $80,000 from a dark money nonprofit through a personal company she quietly registered — a payment she failed to report on her federal financial disclosure forms, in what experts say is likely a violation of ethics rules.
According to newly surfaced tax records, the nonprofit group American Resolve Policy Fund, which promotes Noem’s political career, paid her LLC, Ashwood Strategies, a fundraising fee of $80,000. The payment amounted to a 10% cut of the $800,000 Noem helped raise. That income was not listed in her mandatory financial disclosure form filed when President Trump nominated her as Secretary of Homeland Security.
The group, which is not required to disclose its donors, is part of a network boosting Noem’s national profile. Experts say while it’s common for politicians to help raise money for aligned organizations, it is highly unusual — and ethically concerning — for them to personally pocket funds from such efforts.
“If donors to these nonprofits are not just holding the keys to an elected official’s political future but also literally providing them with their income, that’s new and disturbing,” said Daniel Weiner, a former Federal Election Commission attorney and campaign finance expert at the Brennan Center for Justice.
Undisclosed Income Raises Red Flags
Noem’s personal company, Ashwood Strategies, was formed in Delaware on June 22, 2023 — the same day American Resolve was incorporated. The nonprofit reported raising $1.1 million that year and spending just $220,000, more than a third of which went to Noem’s LLC.
Despite federal requirements, Noem failed to report the $80,000 payment on her 2023 disclosure form, filed after Trump nominated her to his Cabinet. Instead, she listed income from her book advance and described Ashwood as related to “personal activities” outside her gubernatorial duties.
In a statement, her attorney, Trevor Stanley, insisted that Noem “fully complied with the letter and the spirit of the law,” and claimed the Office of Government Ethics had cleared her disclosures. But he did not confirm whether the office was made aware of the $80,000 payment.
South Dakota and Federal Ethics Concerns
The payment raises legal concerns beyond federal ethics. According to Lee Schoenbeck, a longtime South Dakota Republican and former state Senate leader, Noem may have violated state law requiring the governor to work full-time in public service.
“There’s no way the governor is supposed to have a private side business that the public doesn’t know about,” Schoenbeck said.
While Noem’s lawyer maintains her actions were permitted under state law, critics argue the secret arrangement — which only came to light during her Cabinet confirmation process — undermines public trust.
Lavish Spending, Low Transparency
Noem has faced scrutiny for her personal spending before. She was photographed wearing a nearly $50,000 Rolex while visiting a prison in El Salvador and was found carrying $3,000 in cash during a D.C. restaurant incident. She also used state funds for trips to Paris, Canada (for bear hunting), and dental work in Houston — all of which sparked controversy.
American Resolve, meanwhile, has minimal public presence and impact. It claims to exist to “preserve America for the next generation,” but has just 100 followers on X (formerly Twitter), and its reported activities include paying Noem, covering travel costs, and running a few online promotions.
The group’s affiliated PAC — American Resolve PAC — has been more visible, funding events where Noem campaigned for GOP candidates in 2023. The PAC’s website features photos of Noem and messages praising her “conservative leadership.”
Despite all this, Noem maintains that she did nothing wrong. Her attorney says she didn’t control American Resolve and merely acted as a vendor. However, her role — and the flow of donor money through a private company she owns — is likely to remain under scrutiny as she takes on her new federal role overseeing immigration and homeland security.
