“Dark money” is political spending whose original source cannot be identified from public records. It is not a synonym for illegal money. It describes a chain of ordinary, lawful organisations arranged so that the name attached to a dollar falls off somewhere in the middle — and the rules do not require anyone to pick it back up. The chain below is the general shape. Every document on this site is one worked example of it.
An individual, a family office or a company decides to influence elections. There is no limit on how much a person may give to a group that spends independently of a candidate, and no requirement that the person be a resident of the state where the money is spent.
A 501(c)(4) is a “social welfare” organisation. It may spend on politics so long as politics is not its primary activity. It files an annual Form 990 with the IRS, and that return lists every organisation it gives money to — but since Revenue Procedure 2018-38, it no longer reports the names of the people who give money to it.
This is the single hinge of the whole structure. A 990 is a one-way mirror: every dollar out has a name attached, and no dollar in does.
The first nonprofit grants to a second, which grants to a third. Some of these are ordinary organisations; others are pooled funds that hold dozens of separately branded projects inside one legal entity, each with its own name and website but no separate tax return.
Two things happen at every hop. The money mixes with money from other givers, so no dollar can be traced to a particular source afterwards. And the stated purpose of the grant is usually recorded on the tax return as nothing more specific than “general purpose.”
Eventually the money arrives at a political action committee. PACs do file real disclosure reports, and this is where the trail becomes visible again — but only partly, because committees give to other committees. A state PAC receives from a federal PAC that received from a nonprofit that received from a fund.
Each report names the committee immediately upstream of it. None of them names the person at stage 1, because none of them knows or is required to ask.
The money becomes advertising, mailers, text messages, polling, canvassing, or a direct contribution to a candidate. In a county race, the amounts that reach the candidates themselves can be small — a few thousand dollars — while the amounts spent around the race are not.
A voter sees the advertisement and a committee name at the bottom of it. Following that name back to stage 1 means reading federal filings, state filings, county paper records and IRS returns that appear more than a year after the election — and even then, the first two hops were never written down.
The other documents on this site follow one real example of the pattern above. This is how the generic stages line up with the named entities in that example.
| Stage | In general | In this example |
|---|---|---|
| 1 | A person with money | Hansjörg Wyss, a Swiss citizen who lives in Wilson, Teton County. Also a set of family offices and individual donors in several states. |
| 2 | A nonprofit that never names donors | Berger Action Fund, a 501(c)(4) with $387.6 million in net assets. Its Form 990 lists every grant out and no donor in. |
| 3 | More nonprofits and pooled funds | Sixteen Thirty Fund and the New Venture Fund, which hold many separately branded projects; then Western Futures Fund, a 501(c)(4) filing from a mail drop in Sheridan, Wyoming, which made fifty grants totalling $11.2 million, every one of them described as “general purpose.” |
| 4 | Committees that pass money to each other | Way Back PAC, a federal hybrid committee, and Wyoming Way PAC, a state committee — both funded by Western Futures Fund, and both filing in more than one place. |
| 5 | A local race | The Teton County Commission Democratic primary of 18 August 2026. Way Back PAC moved $6,430,160.86 through that period. $5,500 of it reached three county candidates. |
On 31 August 2026 The New York Times published a review of advertising data, campaign-finance filings and tax records covering the 2026 midterms. Its findings describe the same five-stage structure at national scale. The figures below are the newspaper’s, not this site’s.
The Times describes three methods of concealment, which correspond to stages 2, 3 and 4 of the chain above. First, a nonprofit runs the advertising itself, nominally about issues. Second, the nonprofit donates to an allied super PAC — the super PAC must disclose its donors, but not its donors’ donors, so the trail stops at the nonprofit’s name. Some super PACs, the paper reports, are funded entirely by nonprofits. Third, a “pop-up” committee registers close enough to election day that its first donor disclosure falls after the votes are counted.
On timing, the report notes that lawyers commonly advise nonprofit clients not to file a comprehensive account of this cycle’s activity with the IRS until mid-November 2027 — more than a year after the midterm elections.
“We are on track to have the least transparent midterm at least since Citizens United. We’re almost at the point where anyone who doesn’t want to be disclosed doesn’t have to be disclosed.”
— Dan Weiner, Brennan Center for Justice, quoted in the same report
The report also notes a Wyoming connection unrelated to the documents on this site: a group called Choose Freedom Inc., described as having a paper trail dating only to spring 2026, reserved roughly $22 million in advertising in two dozen battleground House and Senate races in August 2026.
Each row below pairs a pattern described in the national reporting with the corresponding item in the documents on this site. The left column is the newspaper’s finding; the right column is drawn from primary filings.
| The national pattern | The local instance |
|---|---|
| A super PAC funded entirely by nonprofits | Wyoming Way PAC received exactly one contribution in 2022: $110,000 from Western Futures Fund. That is its complete funding history. |
| The nonprofit and the committee run by the same people | Blue Moon Strategies is named on Western Futures Fund’s own Form 990 as the management consultant “responsible for day-to-day operations.” Its principal is simultaneously the assistant treasurer of Way Back PAC, the committee that fund pays. |
| A super PAC discloses its donors but not its donors’ donors | Way Back PAC’s filings name Western Futures Fund as its largest contributor at $1,400,000. Western Futures Fund’s own return names every organisation it gives to and no organisation or person that gives to it. |
| “Pop-up” committees formed close to an election | Montana Freedom PAC registered 17 March 2026, six weeks before its first cheque. Keep Jackson Whole formed 6 August 2026, twelve days before the Teton County primary, and filed with the county clerk after the election. |
| Comprehensive tax disclosure arrives more than a year later | The Forms 990 that document the 2026 grants in these maps are expected in late 2027. The returns currently readable cover 2022, 2023 and 2024. |
| An enforcement vacuum | The Federal Election Commission closed MUR 7904 in August 2022 with the foreign-national counts deadlocked 3–3 — no penalty, no finding, no adjudication. The Commission now lacks a quorum entirely. |
Three days earlier the same newspaper published a ranking of the twenty largest donors of the 2026 cycle. Together they gave $1.2 billion to federal races. The twentieth-largest gave $32.2 million. Five dark-money nonprofits account for $265 million of the total, and of those five the report states: “in each instance, the nonprofit is led by the same people who lead the allied super PACs.”
Set against that, the sums in the Teton County documents are very small.
| Figure | Amount |
|---|---|
| The twenty largest donors of the cycle, combined | $1,200,000,000 |
| The twentieth-largest donor alone | $32,200,000 |
| Way Back PAC, entire 2026 Wyoming primary period | $6,430,160.86 |
| Reaching three Teton County commission candidates | $5,500 |
The national ranking places Richard and Elizabeth Uihlein sixth, at $70 million given to Republican committees. Way Back PAC’s own federal schedule records a contribution of $25,000 from Lynde B. Uihlein of Milwaukee, described on the filing as self-employed, philanthropist.
Lynde Bradley Uihlein is a documented Democratic donor, the granddaughter of Allen-Bradley co-founder Harry Lynde Bradley, and a first cousin of Richard Uihlein. Two members of one family, at opposite ends of the same system, funding opposite parties through structures that work identically.
National figures in this section are from “Meet the Megadonors Who Have Poured $1.2 Billion Into the Midterms,” The New York Times, 28 August 2026. The Uihlein cousin relationship is from published biography rather than a filing. The $25,000 contribution is from the committee’s FEC Schedule A.
National figures and quotations in this section are from “‘The Least Transparent Midterm’: How Dark Money Is Washing Over the 2026 Election,” by Shane Goldmacher and Theodore Schleifer, The New York Times, 31 August 2026. They are reporting, not primary filings, and are attributed as such. Everything in the right-hand column above is drawn from filings cited on the other pages of this site.