While serving as South Dakota’s governor in 2023, Kristi Noem quietly accepted $80,000 from a nonprofit that raises money to support her political ambitions — a deal routed through a private company she created and never disclosed on required federal ethics forms, according to tax records reviewed by ProPublica.
The payment, described in the group’s filings as a fundraising fee, went to Noem’s newly formed Delaware-based company, Ashwood Strategies. Ethics experts say this type of undisclosed payment — funded by anonymous political donations and directed to a politician’s personal business — is highly irregular and likely violates federal disclosure rules.
The nonprofit, American Resolve Policy Fund, is classified as a “dark money” group, meaning it does not have to reveal its donors. It reported that Noem raised $800,000 for the organization, keeping 10% for herself through Ashwood Strategies — a firm whose existence was only revealed during her confirmation process for Homeland Security Secretary in the Trump administration.
Experts called the arrangement troubling. “It’s a major red flag when elected officials personally benefit from political donations through backdoor payments,” said Daniel Weiner, a former Federal Election Commission attorney. “That kind of setup undermines transparency and invites corruption.”
A Lucrative Side Deal, Hidden From Public View
At the time of the $80,000 payment, Noem was earning about $130,000 as governor. The additional income significantly boosted her earnings — yet she failed to include it on her 2023 federal financial disclosure form, which she was required to file when nominated to Trump’s cabinet.
Instead, she only disclosed a $140,000 book advance and a general description of her company’s assets. Her company’s registration in Delaware — under the name of one of her horses — happened just minutes before the nonprofit itself was incorporated on June 22, 2023.
A spokesperson for Noem, attorney Trevor Stanley, insisted she complied with “the letter and spirit of the law” and claimed the Office of Government Ethics cleared her filings. But when asked whether that office knew about the $80,000 payment, he declined to answer.
Stanley also stated that Noem “fully disclosed all of her income” on publicly available forms, though her federal filing contains no mention of the payment from American Resolve.
What American Resolve Actually Does Remains Unclear
According to its tax filings, American Resolve raised $1.1 million in 2023 but spent only $220,000 — more than a third of which went to Noem’s company. The rest was allocated to vague administrative costs and roughly $84,000 in travel. The group has no employees and a minimal online presence, with fewer than 150 followers on X (formerly Twitter).
There’s little evidence the group has conducted significant public work, though it did run Facebook ads earlier this year attacking South Dakota reporters who scrutinized Noem’s use of government credit cards.
Noem’s lawyer wouldn’t say if the group has continued paying her since 2023.
Ethics, Disclosure, and Legal Questions Mount
South Dakota has some of the weakest financial disclosure rules in the country, and Noem never reported her side business or the income she received from it during her time as governor. The secretive arrangement only came to light during her nomination to lead the Department of Homeland Security.
“This kind of undisclosed, private side income by a sitting governor raises serious concerns,” said Lee Schoenbeck, a longtime South Dakota Republican and former state Senate leader. “There’s no way the governor is supposed to have a private business the public doesn’t know about. That’s clearly not appropriate.”
Federal law requires Cabinet nominees to disclose all sources of personal income. Ethics experts say Noem’s omission of the $80,000 violates that requirement, and could open her up to legal or administrative consequences if authorities pursue the issue.
Noem’s team maintains that her actions were above board and argues that she simply acted as a private contractor for the nonprofit.
But campaign finance experts say the deeper problem is the precedent such an arrangement sets. “When political donations flow into a nonprofit and then straight into a politician’s pocket,” said Weiner, “it’s not just an ethics problem — it’s a threat to public trust.”
