While serving as governor of South Dakota, Kristi Noem received an $80,000 payment from a dark money nonprofit—money she later failed to disclose, according to a new ProPublica investigation.
The funds were paid in 2023 by the American Resolve Policy Fund, a nonprofit group not legally required to reveal its donors. At the time, Noem was still governor; she now serves as Secretary of Homeland Security in the Trump administration.
Despite being required under federal ethics rules to disclose all significant income, Noem omitted the $80,000 payment from her 2023 financial disclosures—even after filing a detailed report upon joining the Department of Homeland Security.
The Ethics in Government Act mandates that senior federal officials report sources of outside income to help avoid potential conflicts of interest. Ethics experts told ProPublica that Noem’s failure to report the payment likely constitutes a violation of that law.
“This goes beyond campaign influence—this is donors directly supplementing an elected official’s income,” said Daniel Weiner, a former Federal Election Commission attorney.
Records show the money went to Noem’s personal LLC, Ashwood Strategies, registered in Delaware. American Resolve, which raised $1.1 million in 2023, categorized the $80,000 as a payment for “fundraising services,” noting that Noem helped bring in a significant amount of that revenue.
Tax filings reveal that American Resolve paid Noem’s company 10% of the total funds it raised that year. The nonprofit lists no employees and operates with minimal transparency. Its online presence is sparse, with a barebones donation page and a low-traffic X (formerly Twitter) account that mainly amplifies pro-Noem content.
American Resolve describes its mission as “fighting to preserve America for the next generation,” but offers few specifics about its activities beyond supporting Noem.
The Independent reached out to both Noem and DHS for comment but received no response regarding the missing disclosure.
In a statement to ProPublica, Noem’s attorney, Trevor Stanley, said the former governor “fully complied with the letter and the spirit of the law,” adding that the Office of Government Ethics had reviewed and approved her financial disclosures.
However, Stanley declined to say whether the OGE was specifically informed about the $80,000 payment from American Resolve.
Noem has characterized Ashwood Strategies as a vehicle for “personal activities outside my official gubernatorial capacity,” and said the company also received a $140,000 advance for her book No Going Back.
The revelation raises fresh questions about Noem’s financial transparency and the growing role of opaque nonprofit groups in supplementing the incomes of public officials.
