The pass-through and the county commission

Every flow on this map

Sorted by amount. Column headers re-sort the table. DOC = read off a primary filing · SEC = from a transcription of a filing not opened directly · INF = a structural relationship with no traceable dollar.

Hansjörg Wyss, a Swiss national, and a Wyoming statute

The capital at the head of this map belongs to Hansjörg Wyss, a Swiss citizen who lives in Wilson, Teton County, Wyoming. His political vehicle is the Berger Action Fund, a 501(c)(4) with $387.6 million in net assets as of FY2024. Berger itemises every organisation it gives money to and no person who gives money to it. Since Rev. Proc. 2018-38, 501(c)(4) organisations no longer report donor names to the IRS at all, so the first link in the chain — Wyss to Berger — leaves no public trace by operation of the rules.

His status is not in dispute, because he conceded it. In FEC MUR 7904, closed in August 2022, Wyss acknowledged that he is a foreign national within the meaning of 52 U.S.C. § 30121(b) — the federal provision barring a foreign national from spending in connection with any federal, state or local election. The Commission dismissed the registration counts 6–0. On the foreign-national and straw-donor counts it deadlocked 3–3 and closed the file. There was no penalty, no finding and no adjudication, which leaves the underlying practice neither approved nor prohibited.

Federal law does not reach ballot measures. The Federal Election Campaign Act applies to candidate elections; the Supreme Court has treated referenda as votes on issues rather than on candidates. Foreign spending on a ballot campaign is therefore governed by state law, and until 2025 Wyoming had no such law.

The point of a pass-through

Way Back PAC gave $43,000 to thirteen Wyoming candidates and moved $6,387,160.86 everywhere else. The Wyoming money is de minimis, and that is not a flaw in the design — it is the design. The committee is a pass-through, and the handful of small Wyoming checks are what make it a Wyoming filer.

The two-report mirror

The committee files in two places, and each report itemizes precisely what the other conceals.

Neither document is false. Neither regulator is being deceived. No rule requires either filing to show both halves — and no voter has ever been shown both at once.

One 501(c)(4) funded every layer of the race

Read off Western Futures Fund’s own Forms 990 for 2022, 2023 and 2024 — fifty grants, $11,229,750, every single one described as “GENERAL PURPOSE.” Its Wyoming portfolio reaches the committee, the state committee, the endorsing organization, the donor network and both arms of the advocacy group.

The four largest grants, for scale: Institute for Responsive Government Action, Chicago — $1,950,000 (2024) · Your Community PAC, Wilmington DE — $1,500,000 (2024) · Keep Country First Policy Action, Washington DC — $1,100,000 (2022) · Retire Career Politicians, Washington DC — $970,000 (2024). Grants by year: 2022, 14 grants, $2,972,750 · 2023, 14 grants, $1,487,000 · 2024, 22 grants, $6,770,000.

Luther Propst has been inside this network for thirty years

Not adjacent to it. Inside it. Four boards, and the money on three of them comes from the two funders on this map.

None of that is improper. Conservation professionals sit on conservation boards, and in the American West these are the boards. What it establishes is proximity — three decades of it, to the same two funders. In 2026 a political committee funded by that network’s 501(c)(4) layer gave him $1,500, thirteen days before his primary.

Two corrections. His campaign biography says “Board Chair, Outdoor Alliance”; the organization’s own page and its Form 990 both name Katherine Tsai as chair, and list Propst as a director. The same page still describes him as seeking re-election in 2022 — it has not been updated in two cycles.

The appointment: Propst and Mike May

Propst sits on the county half of the body that fills the Jackson Hole Travel & Tourism Board’s seats — the same seat held, as Secretary, by the owner of the public-relations firm whose post-office box appears on Western Futures Fund’s 2022 tax return as the address of Wyoming Way PAC.

The mechanism is on the record: the County Commission and the Town Council interview candidates jointly, recess into executive session under the state’s public-officer appointment exception, then return to open session and pass separate motions. Seven seats, six-year terms, a majority reserved for the travel and tourism industry, and a budget drawn from lodging tax — $1.9 million to MMGY Origin Outside and $50,000 to Campstories in the most recent agency round. Neither May nor his firm appears in those contracts.

What this is: a documented appointer-and-appointee relationship between a sitting commissioner and the holder of a post-office box that turns up, once, on a 501(c)(4)’s tax return next to a political committee’s name. What it is not: evidence that either man did anything with the other. The record that bears on it is the Wyoming Secretary of State’s entity record for Wyoming Way PAC — its organizer and registered agent.

Where the two channels meet

The Storer Foundation and the Wyss/Arabella pipeline run separately down most of this map. They touch in three places, and all three are on filings.

• Better Wyoming — the same EIN. This is not a shared brand; it is a shared taxpayer. The Storer Foundation granted $1,231,000 to EIN 47-3490919 across five straight years. Western Futures Fund granted $20,000 to that identical EIN in 2022, then $30,000 to its 501(c)(4) twin, EIN 99-0790892, at the same post-office box in Laramie, in 2024. Liz Storer sits on the board.
• Unite America. The Storer Foundation grants it $50,000. Unite America PAC Inc. of Denver gives Way Back PAC $5,000 on 20 April 2026 — the only federal PAC contribution on the entire Wyoming report. And Claire Shaw, who works in the organization’s investor relations, gives $1,000 personally. Three touches, three separate filings.
• Nikki Kaufman — a person, not a dollar. She chaired Shelter JH’s board in FY2024 while serving as executive director of the Wyoming Donor Alliance, and Western Futures Fund funded both organizations. She is also a Conservation Leadership Institute alumna, class of 2018 — the Storer-funded leadership pipeline run out of the Jackson Hole Conservation Alliance.

The Jackson post-office box on the 2022 return

Western Futures Fund’s 2022 Form 990, Schedule I Part II, gives Wyoming Way PAC’s address as PO Box 4202, Jackson, WY 83001.

That box belongs to Sinclair Communications, a public-relations and marketing consultancy founded by Mike May, which publishes exactly that address on its own contact page along with 307-690-6939 and mike@sinclaircommunications.net. Its described work is outdoor-industry PR — CRKT and WorkSharp Tools currently, Gerber, Old Town Canoe, Timberland and YETI before that. Nothing on its site describes political or campaign work.

The Jackson box appears in one document out of four, and it appears in the year the committee spent $40,298.62 on print, $20,230.25 on Meta advertising and $29,500 on a Jackson political consultant — an advertising operation, run out of a Jackson advertising firm’s mailbox. What the firm’s role was, if any, is settled by no filing yet read.

Who Mike May is in public life

Sinclair’s owner holds public office, and it is relevant for a reason that has nothing to do with the post-office box. Mike May is Secretary of the Jackson Hole Travel & Tourism Joint Powers Board, listed on the board’s own roster as “Mike May (Secretary) — PR Consultant.” The board holds seven seats on six-year terms, a majority of which must represent the travel and tourism industry, and it allocates lodging-tax revenue — $1.9 million to MMGY Origin Outside and $50,000 to Campstories in its most recent agency round.

Those seats are filled by joint vote of the Teton County Board of County Commissioners and the Jackson Town Council, which interview candidates together, recess into executive session under the state’s public-officer appointment exception, and then pass separate motions. Luther Propst sits on the commission half of that vote. It is an appointer-and-appointee relationship, on the record.

Two things searched for and not found: no public source connects Mike May to Skye Schell, and neither May nor Sinclair Communications appears in the tourism board’s own agency contracts — those went to MMGY Origin Outside and Campstories. Nothing places him in a campaign filing, on a Storer, Conservation Alliance or Shelter JH board, or anywhere in the 2022 Wyoming Way expenditure schedule.

A second Jackson box appears on the same fund’s 2024 return, and it is a different one: the Wyoming Donor Alliance at PO Box 3462. Two independent nonprofit directories index that EIN, 88-2031141, under the name Wyoming Investor Network, which the returns themselves do not show.

Who the individual money came from

Across the 2022, 2024 and 2026 cycles the committee's federal schedule names 123 separate givers. Eight individuals or households account for $2,252,450 of it. Six live in California, New York, Texas or New Mexico; none of the eight lives in Wyoming. Employer and occupation are reproduced exactly as filed.

Six Wyoming residents appear anywhere on the schedule. Together they gave $58,250: Annette Cumming of Jackson, $50,000; James Harris of Teton Village, $5,000; Maggie Hunt, Carly Christopher and Annette Osnos of Jackson, $1,000 each; and Anne-Marie Resor of Wilson, $250. That is nine tenths of one percent of what the committee raised.

The third mirror — $738,000 given, $45,000 itemized

A hybrid PAC runs two accounts. The contribution account is capped at $5,000 a person a year and its donors are itemized on FEC Schedule A with employer and occupation attached. The non-contribution account takes unlimited money and lands on Line 17, "Other Receipts," where no individual name is attached in the itemized file. Set the two records side by side and the structure shows up in a single column.

Every one of them lands on exactly $5,000 in the federal individual file, because $5,000 is the annual maximum to a PAC's contribution account. Ninety-four percent of what these nine people gave went to the other wallet. The paired entries on the Wyoming report — $5,000 and $45,000 to Annette Cumming on the same day, $245,000 and $5,000 to Rory Gates on the same day — are the two legs of one gift, and only the small leg carries a donor's name into the federal record.

Six ways the trail goes dark, in order

1. The c4 donor list. A 501(c)(4) itemizes every grant out and no donor in. Since Rev. Proc. 2018-38 most non-c3 exempt organizations no longer report donor names to the IRS at all. Where the money went is generally visible; where it came from generally is not.
2. Commingling. A grant from Berger to Sixteen Thirty is unrestricted general support. Earmarking would create legal exposure. The absence of a traceable dollar is the architecture.
3. FEC Line 29. A federal committee must itemize contributions to federal candidates on Line 23. Contributions to state committees have no line of their own and fall to Line 29, "Other Disbursements." Of 309 itemized rows, 212 rows carrying $3,988,730 name no beneficiary — and every six-figure check to an intermediary state PAC is in that silent group, while every gift to a named human candidate carries a full memo. The opacity tracks the hop.
4. The Wyoming aggregate. Wyoming's report has no equivalent requirement running the other way. $6.39 million, one line, no payee.
5. The amendment. Both committees disclose their most interesting payments by amendment, filed days or weeks later as separate documents. The base report shows only a summary total — no payee, no date, no purpose. Yellow Tree Strategy's $15,000 lives in Amendment 2 to the 2022 primary; $644,390 of Way Back PAC's 2026 spending lives in Amendment 1. A reader who pulls the report and not every amendment sees a hole where the consultant is.
6. The last hop is handwritten. The PAC pays the candidate; the candidate pays the consulting firm; the candidate's report is paper at the Teton County Clerk. Mountain Movement Strategies appears in none of the 309 federal rows — because it was never paid by the PAC.

The consultant chain, three cycles, one funder

Skye Schell founded Yellow Tree Strategy in early 2022, months after leaving the Jackson Hole Conservation Alliance executive directorship, and founded Mountain Movement Strategies in January 2023 with Karyn Chin. He co-founded Shelter JH in 2016 and appears as its treasurer on the FY2022 Form 990. Same funder, same committee, same consultant lineage, three consecutive cycles.

What the record establishes

• The documented facts are about the mechanism, not about any individual. A committee moved $6.4 million from sources no voter can identify, disclosed 99.3% of it as a single unnamed line, and the $5,500 that reached the local race arrived thirteen days before the vote. Nothing in the record shows that any person directed a county election.
• Every relationship shown here appears lawful, and most of it is disclosed somewhere — across the Federal Election Commission, the Wyoming Secretary of State, handwritten paper at the Teton County Clerk, and IRS returns published eighteen months after the fact. The disclosures are scattered across four systems on four different timetables, so no voter could have assembled the picture before casting a ballot.
• One state regulator has already reached a structure of this kind. Montana’s Commissioner of Political Practices found North Fund in violation of that state’s incidental-committee rule in 2020, and has applied the rule to groups on both sides of the aisle since.

Open questions, and the records that bear on them

1. Amendment 1 to Wyoming Way PAC's 2022 Primary Report. The only document in the 2022 series not read. It removes exactly $4,191.36, and which payee line it came out of is the last open question on that cycle.
2. Annette Osnos's $1,000. Now checked against both files and present in neither — not on the Wyoming 2026 Primary Report or its amendment, and not among the 53 rows of the FEC individual schedule for 2025–26. Three places remain: Line 17 receipts to the non-contribution account, which the Schedule A export does not carry; a reporting period outside 2025–26; or a different committee. The Line 17 export is the next pull.
3. Whether the Storer board's Ryan Lance is Way Back PAC's Ryan Lance. Way Back PAC's Form 1 names "Ryan Lance, 30 N Gould St, Suite 4205, Sheridan" as treasurer and custodian of records — a registered-agent mail drop, the same building as Western Futures Fund. FEC Form 1 has no employer field and the foundation publishes no director biographies. A separate Ryan Lance sits on the Wyoming Business Council board: Cheyenne, "Conservation, Law & Land Management," president of Pathfinder Ranches. The FY2025 990-PF resolves it.
4. Where Jonah Meyers appears in Western Futures Fund's own records. The FY2024 Form 990 names only Hennesy, Hirsch and Krones. The Wyoming nonprofit registration, earlier 990s, and any state lobbying registration are unread.
5. Whether Shelter JH is one of WYCEN's twenty-six partners. The roster is published nowhere. One email to the network's executive director.
6. Civitech's $1,000,000. A for-profit vendor made the largest single contribution in the committee's history and received no payment back. Legal after SpeechNow, and entirely unexplained.
7. The $644,390 amendment. Now itemized: $5,000 to Barlow for Wyoming, $2,500 to Reiner for Wyoming, and $636,890 as another NON-WY EXPENDITURES line. The two Miles contributions of $25,000 each arrived 17 August — the day before the primary.
8. What the state PACs did with the money. $750,000 landed at Montana Freedom PAC on 29 June 2026 and $300,000 with Lynne Walz in late June. Their own spending disclosures are not due until October 2026. If a circular vendor-donor loop exists, that is where it appears.
9. The handwritten Teton County filings. Photograph the Chin, Propst and Dunford reports at the Clerk's office to fix the Mountain Movement figures exactly and resolve Dunford's duplicate $2,500 entries.
10. Whether Way Back PAC filed with the Teton County Clerk. Wyo. Stat. §22-25-106(b)(i) requires an out-of-state federal PAC contributing to a Wyoming county candidate to file its own itemized statement with the County Clerk, 7–14 days before the election — the 4–11 August 2026 window. Penalty for failure runs to $200 a day.
11. The empty websites. A list of Storer-adjacent domains that mimic the Arabella pattern is being assembled and has not yet been checked against registrant records.