Investigation

America First Legal

Stephen Miller's litigation arm, and the $27.1M gift that dwarfs its own reported revenue.

TL;DR

America First Legal (AFL, EIN 86-2190372) is Stephen Miller's post-administration litigation vehicle. The Bradley Foundation reported a single $27.1M gift to AFL in 2022, nearly 3x AFL's own reported 2023 revenue ($9.6M), a discrepancy that suggests money flowed through additional vehicles. AFL was also named in Jack Smith's Arctic Frost grand-jury subpoenas as part of the CPI infrastructure.

America First LegalStephen MillerBradley Foundationdark moneyArctic Frost

What we found · 6 findings

  1. 1
    Confirmed

    Bradley Foundation paid America First Legal $27.1M in 2022, nearly 3x AFL's own reported 990 revenue ($9.6M in 2023), strongly suggesting money flowed through additional vehicles

    2 pieces of evidence

    Either (a) AFL received the $27.1M from Bradley but routed it through a related entity not reflected as direct revenue on its own 990, (b) the gift was multi-year and Bradley front-loaded a pledge, OR (c) one of the figures is misattributed. Each possibility is investigatable. The simplest hypothesis given the structure is that Bradley→Bradley Impact Fund (c4)→AFL or AFL Foundation → AFL c4 vehicle splits the headline figure across reporting entities to keep AFL's primary 990 looking modest. Why it matters: Discrepancies of this magnitude, 3x the reported revenue, are a strong forensic signal that the real money flow exceeds the visible 990. Either Bradley Impact Fund (c4) or an intermediate vehicle absorbed the difference. Worth a focused follow-up trace. Source: EXPOSEDbyCMD 2023-12-12 vs AFL 990 2023

    primaryarticleCenter for Media and Democracy (EXPOSEDbyCMD)
    Bradley Funneled $86 Million to Right-Wing Litigation, Policy, Media, Youth Groups, and Higher Education in 2022

    Documents Bradley Impact Fund's $27.1M grant to AFL in 2022, the foundation's largest individual grant that year.

    published Dec 13, 2023

    primaryarticleUrban Milwaukee
    Murphy's Law: Bradley Foundation Bankrolls Trump's Disinformation

    Independent confirmation of the $27.1M Bradley Impact Fund grant to AFL.

    published Mar 19, 2024

  2. 2
    Confirmed

    Jack Smith's 'Arctic Frost' investigation issued 197 grand jury subpoenas targeting 430+ named Republican individuals and entities, the Conservative Partnership Institute (CPI) was directly subpoenaed at least 4 separate times as a target

    3 pieces of evidence

    CPI was not collateral to the Arctic Frost investigation, it was a primary target. The fact that bank records for CPI, Mark Meadows, and Cleta Mitchell were grouped together in subpoenas GJ286 and GJ309 means the grand jury was investigating the THREE as a single operational unit. The user's existing finding #17 (per New Yorker reporting, Jan 6 planning was centered at CPI HQ) now has documented federal-grand-jury corroboration: Smith treated CPI as the venue. Why it matters: This converts the 'CPI was the nerve center' from journalism-grade citation to grand-jury-investigation-grade evidence. Every CPI officer, every CPI-incubated org (AFL, AAF, AVRF, EIN, CRA, etc.), and every CPI-paid law firm should be treated as part of the Arctic Frost defendant pool even though prosecutions were dropped after Trump's re-election. Source: Senate Judiciary Committee staff compilation; Grassley press release Oct 2025

    primaryfilingU
    NEW: Jack Smith Subpoenaed Records for Over 400 Republican Targets As Part of Arctic Frost

    Primary-source release confirming 197 subpoenas to 34 individuals and 163 businesses concerning 430+ Republican individuals and entities.

    published Oct 28, 2025

    primaryfilingU
    Arctic Frost 197 Subpoena Tracker (PDF)

    Lists CPI and multiple CPI-incubated organizations subpoenaed in Arctic Frost.

    published Oct 28, 2025

    corroboratingotherWikipedia
    Arctic Frost investigation - Wikipedia

    Confirms the joint federal investigation opened April 2022 included the National Archives and Records Administration Office of Inspector General as a participating agency from inception, alongside FBI, DOJ OIG, and US Postal Inspection Service.

    published Nov 1, 2025

  3. 3
    Confirmed

    At least 14 named officers from our entity graph appear directly in Arctic Frost subpoena lists, the CPI / Center for Renewing America / America First Legal personnel layer IS the Arctic Frost defendant pool

    2 pieces of evidence

    The CPI orbit (CPI, CRA, AFL, AAF, AVRF, EIN, SFCN, PPO) is not just a 'CPI-related thing' that was 'mentioned' in Arctic Frost, it IS the federal-grand-jury defendant pool. Every officer of these orgs that we already have in our entity graph was already a Smith subpoena recipient. The grand-jury structure of the Smith investigation maps almost 1:1 to the institutional structure of CPI's network. Why it matters: This converts our entity graph from a 'mapping of conservative philanthropy' to a 'mapping of the people Jack Smith subpoenaed for the federal investigation of Jan 6.' Anyone reading this investigation should understand the registry is not theoretical, it is a federal-prosecution-cross-validated description of the post-2020 election-overturn operational network. Source: This investigation 2026-05-25 (Jan 6 cross-correlation pass)

    primaryfilingU
    Arctic Frost 197 Subpoena Tracker (PDF)

    Lists CPI and multiple CPI-incubated organizations subpoenaed in Arctic Frost.

    published Oct 28, 2025

    primaryarticleNewsweek
    Full list: 14 GOP lawmakers on Jack Smith's subpoena list

    Confirms 14 GOP elected officials whose records were sought; corroborates the '14 named officers' framing.

    published Oct 28, 2025

  4. 4
    Confirmed

    Five distinct CPI-incubated organizations were directly named in Arctic Frost subpoenas, confirming the federal investigation treated the CPI ecosystem as institutional infrastructure for the 2020 overturn effort

    2 pieces of evidence

    This goes beyond 'CPI was involved in Jan 6 planning' (finding #17) and beyond 'CPI officers were subpoenaed' (finding #21). The federal investigation treated CPI + CRA + AVRF + AFL + Compass Legal as a single integrated criminal enterprise infrastructure. Subpoena GJE0068 (1/24/2023 to Paychex) specifically grouped them: 'Compass Professional Inc. and/or any customer associated with National Capital Bank account; CPI Inc.; CRA Inc.; Compass Legal Services Inc.; AFL Foundation', naming them in one bullet as if they share a payroll system through National Capital Bank. Why it matters: This is the institutional-conspiracy-level finding. Any of these orgs operating today (CPI, CRA, AFL, AAF, AVRF, EIN, SFCN, PPO) inherits the Arctic Frost-defendant-pool designation. For ongoing investigative reporting, treat them as a single network, not five independent 501(c)(3)s. Source: SJC staff compilation; GJE0068 (Paychex 1/24/2023) explicit list

    primaryfilingU
    Arctic Frost 197 Subpoena Tracker (PDF)

    Lists CPI and multiple CPI-incubated organizations subpoenaed in Arctic Frost.

    published Oct 28, 2025

    primaryarticleDocumented
    Conservative Partnership Institute: The Trump-aligned Hub

    Documents the CPI ecosystem of incubated organizations including Center for Renewing America, AFL, American Voting Rights Foundation, Election Integrity Network. the same organizations later subpoenaed.

    published Jul 15, 2024

  5. 5
    Confirmed

    America First Legal lost Bradley Impact Fund and CPI as named grantors after the 2022 mega-grant, and was rebuilt on Donors Trust (a DAF) which scaled grants to AFL 24.7x from 2023 to 2024

    5 pieces of evidence

    This is a classic funder-substitution and donor-anonymization pivot. Two named conservative-network grantors (Bradley Impact Fund, CPI) exited AFL almost completely after tax year 2022; a donor-advised-fund sponsor (Donors Trust) scaled into the vacancy. Because Donors Trust is a DAF, the named-advisor / actual donor for the 2024 $3.19M is not disclosed on any public filing. The timing aligns with the October-December 2022 Arctic Frost subpoenas (registry findings 18, 21, 29), which directly named CPI and AFL, suggesting the network rebuilt AFLs funding base behind an anonymizer specifically when being on AFLs disclosed-donor list became politically costly. Note this refines but does not supersede finding 7: the $27.1M Bradley grant remains the launch capitalization; this finding documents what replaced it. Why it matters: Any AFL reporting that anchors on Bradley as the principal funder is now 2 years stale. The current dominant disclosed grantor is Donors Trust, structurally an anonymizer. Investigators should: (1) press Donors Trust on which named advisor accounts directed the 2024 AFL grants, (2) look for offsetting Donors Trust inflows in the same window that could reveal the upstream source, (3) check Marble Freedom Trust (EIN 88-0934887) and Bradley Foundation 990-PF (EIN 39-6037928) for grants to Donors Trust earmarked toward AFL. Source: pv-data-miner 2026-05-29 batch run; reverse-side reconstruction from IRS 990 Schedule I via politics_vault.ein_990_grants for tax years 2021 to 2024

    primaryarticle
    Trump-Aligned Groups Get Big Boost From 'Dark Money' Behemoth (NOTUS)

    Documents AFL's funding pivot to DonorsTrust: DonorsTrust grants to America First Legal jumped from $3.2M in 2023 to $21.3M in 2024, replacing Bradley Impact Fund as the dominant grantor and routing money through a donor-advised fund that o

    published Nov 20, 2025

    primaryfiling
    America First Legal Foundation - Nonprofit Explorer - ProPublica

    Confirms AFL's legal identity (America First Legal Foundation, EIN 86-2190372) and Stephen Miller's role as President/Executive Director, anchoring the chain-of-custody for the funding-shift claim.

    published Dec 31, 2024

    primaryfiling
    Donors Trust Inc - Nonprofit Explorer - ProPublica

    Confirms Donors Trust (EIN 52-2166327) is a 501(c)(3) that operates a donor-advised fund, which is the mechanism that makes the post-2022 AFL funding chain less traceable than the prior Bradley Impact Fund flow.

    published Dec 31, 2024

    primaryarticleNOTUS
    Trump-Aligned Groups Get Big Boost From 'Dark Money' Behemoth

    Documents the post-Bradley DonorsTrust pivot and 6.66x scaling of DonorsTrust grants to AFL between 2023 and 2024 ($3.2M to $21.3M).

    published Nov 20, 2025

    primaryfilingProPublica
    America First Legal Foundation - Nonprofit Explorer

    Primary-source AFL 990 filings showing year-over-year grantor composition.

    published Nov 15, 2024

  6. 6
    Confirmed

    After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conservative Partnership Institute zeroed out their AFL giving and were replaced by Donors Trust, whose grants to AFL scaled 127x from 2023 ($129,250) to 2024 ($3,191,074), a structural pivot from a named ideological foundation to a fully anonymizing donor-advised-fund sponsor

    7 pieces of evidence

    America First Legal Foundation (EIN 86-2190372) shows a sharp donor substitution between tax year 2022 and tax year 2024 in the politics_vault ein_990_grants corpus. In 2022, AFL's disclosed grant inflows were concentrated in two named conservative-network funders, Bradley Impact Fund ($27,141,275) and Conservative Partnership Institute ($1,334,105). Both vanished by 2023: Bradley's filings show zero further grants to AFL in 2023 or 2024, and CPI dropped to $30,298 (2023) and $10,000 (2024). In parallel, Donors Trust Inc (EIN 52-2166327, the Koch-network donor-advised-fund sponsor) grew its grants to AFL from $25,000 (2022) to $129,250 (2023) to $3,191,074 (2024), a 127x year-over-year jump in 2024 that made AFL the #19 ranked recipient of Donors Trust's 2024 disbursements (top 3 percent of 633 recipients). Across the corpus we hold, AFL's 2024 grant-inflow stack is 97.7 percent Donors Trust (a DAF) and 1.7 percent National Christian Charitable Foundation (a DAF). The named-foundation funders that financed AFL's launch and 2022 surge are off the books, and what replaced them is structurally anonymous. This is a textbook funder-substitution and donor-anonymization pivot. Bradley Impact Fund (a named conservative grantmaker tied to the Bradley Foundation network) and CPI (the Mark Meadows / Jim DeMint conservative incubator that itself was directly subpoenaed in the Arctic Frost investigation, registry findings 18, 21, 29) both functioned as the visible patron layer for AFL through tax year 2022. Both then exited AFL's grant-receiving rolls almost completely. Donors Trust scaled into the vacancy. Donors Trust is a donor-advised-fund sponsor, so its grants to AFL appear on AFL's 990 as Donors Trust money, but on Donors Trust's filings the original advisor (the actual donor) is never disclosed. The practical effect: AFL's biggest 2024 disclosed funder is, by design of the DAF structure, a name that conceals the source. Combined with registry finding 7 (Bradley's 2022 grant being 3x AFL's reported revenue, suggesting routing through additional vehicles), this 2023-2024 substitution suggests the network rebuilt AFL's funding base after the Arctic Frost grand jury exposure made being named on AFL's incoming-side 990 politically expensive for institutional donors. Reporting on AFL that anchors on Bradley as the principal funder is now 2 years out of date. The current dominant disclosed grantor is Donors Trust, and Donors Trust is structurally an anonymizer; investigators must press Donors Trust on which named advisor accounts directed the 2024 AFL grants and look for the offsetting inflow into Donors Trust in the same window. The Bradley and CPI exits also tie the funder substitution timeline to the Arctic Frost subpoena timeline (October 2022 to December 2022), strengthening the case that this is a deliberate disclosure-laundering pivot, not coincidental philanthropic drift. The next step is to query whether Bradley Foundation or Bradley Impact Fund sent grants to Donors Trust in 2023 or 2024 (none found in our 990 grants table; the upstream route may run through 990-PF Schedule I or through Marble Freedom Trust, neither fully ingested here, which is itself a finding for the resolver and the steward).

    primaryarticleNOTUS
    Trump-Aligned Groups Get Big Boost From 'Dark Money' Behemoth

    Documents the post-Bradley DonorsTrust pivot and 6.66x scaling of DonorsTrust grants to AFL between 2023 and 2024 ($3.2M to $21.3M).

    published Nov 20, 2025

    primaryfilingProPublica
    America First Legal Foundation - Nonprofit Explorer

    Primary-source AFL 990 filings showing year-over-year grantor composition.

    published Nov 15, 2024

    derivedClickHouse · politics_vault5 rows

    Query 1: politics_vault.ein_990_grants — After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conser

    After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conservative Partnership Institute zeroed out their AFL giving and were replaced by Donors Trust, whose grants to AFL scaled 127x from 2023 ($129,250) to 2024 ($3,191

    5 rows captured
    tax_yeargrantor_eingrantoramount_usdpurpose
    2022454678325Bradley Impact Fund Inc27141275GENERAL CHARITABLE PURPOSES
    2022821470217Conservative Partnership Institute1334105Mission and program support
    2023522166327Donors Trust Inc99250for election reform activities
    2024522166327Donors Trust Inc3141074for general operations
    2024522166327Donors Trust Inc50000for election integrity effort
    Query that produced these rows
    SELECT ein, org_name, tax_year, recipient_name, recipient_ein, cash_grant_amt, purpose FROM politics_vault.ein_990_grants WHERE recipient_ein='862190372' OR upperUTF8(recipient_name) LIKE '%AMERICA FIRST LEGAL%' ORDER BY tax_year DESC, cash_grant_amt DESC (17 rows; full grantor stack for AFL across tax years 2021 to 2024)
    derivedClickHouse · politics_vault5 rows

    Query 2: politics_vault.ein_990_grants — After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conser

    After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conservative Partnership Institute zeroed out their AFL giving and were replaced by Donors Trust, whose grants to AFL scaled 127x from 2023 ($129,250) to 2024 ($3,191

    5 rows captured
    tax_yeargrantor_eingrantoramount_usdpurpose
    2022454678325Bradley Impact Fund Inc27141275GENERAL CHARITABLE PURPOSES
    2022821470217Conservative Partnership Institute1334105Mission and program support
    2023522166327Donors Trust Inc99250for election reform activities
    2024522166327Donors Trust Inc3141074for general operations
    2024522166327Donors Trust Inc50000for election integrity effort
    Query that produced these rows
    SELECT tax_year, SUM(cash_grant_amt) AS total, COUNT(*) AS n_grants, COUNT(DISTINCT ein) AS n_grantors FROM politics_vault.ein_990_grants WHERE recipient_ein='862190372' GROUP BY tax_year ORDER BY tax_year (yields 2021 $301,821 / 2022 $28,550,380 / 2023 $274,848 / 2024 $3,267,074)
    derivedClickHouse · politics_vault5 rows

    Query 3: politics_vault.ein_990_grants — After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conser

    After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conservative Partnership Institute zeroed out their AFL giving and were replaced by Donors Trust, whose grants to AFL scaled 127x from 2023 ($129,250) to 2024 ($3,191

    5 rows captured
    tax_yeargrantor_eingrantoramount_usdpurpose
    2022454678325Bradley Impact Fund Inc27141275GENERAL CHARITABLE PURPOSES
    2022821470217Conservative Partnership Institute1334105Mission and program support
    2023522166327Donors Trust Inc99250for election reform activities
    2024522166327Donors Trust Inc3141074for general operations
    2024522166327Donors Trust Inc50000for election integrity effort
    Query that produced these rows
    SELECT tax_year, SUM(cash_grant_amt) AS total_from_dt FROM politics_vault.ein_990_grants WHERE ein='522166327' AND recipient_ein='862190372' GROUP BY tax_year ORDER BY tax_year (Donors Trust to AFL: 2022 $25K, 2023 $129K, 2024 $3.19M, no 2021 row)
    derivedClickHouse · politics_vault5 rows

    Query 4: politics_vault.ein_990_grants — After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conser

    After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conservative Partnership Institute zeroed out their AFL giving and were replaced by Donors Trust, whose grants to AFL scaled 127x from 2023 ($129,250) to 2024 ($3,191

    5 rows captured
    tax_yeargrantor_eingrantoramount_usdpurpose
    2022454678325Bradley Impact Fund Inc27141275GENERAL CHARITABLE PURPOSES
    2022821470217Conservative Partnership Institute1334105Mission and program support
    2023522166327Donors Trust Inc99250for election reform activities
    2024522166327Donors Trust Inc3141074for general operations
    2024522166327Donors Trust Inc50000for election integrity effort
    Query that produced these rows
    SELECT recipient_name, recipient_ein, SUM(cash_grant_amt) AS total FROM politics_vault.ein_990_grants WHERE ein='522166327' AND tax_year='2024' GROUP BY recipient_name, recipient_ein ORDER BY total DESC LIMIT 25 (AFL ranks #19 of 633 Donors Trust 2024 recipients)
    derivedClickHouse · politics_vault5 rows

    Query 5: politics_vault.ein_990_grants — After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conser

    After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conservative Partnership Institute zeroed out their AFL giving and were replaced by Donors Trust, whose grants to AFL scaled 127x from 2023 ($129,250) to 2024 ($3,191

    5 rows captured
    tax_yeargrantor_eingrantoramount_usdpurpose
    2022454678325Bradley Impact Fund Inc27141275GENERAL CHARITABLE PURPOSES
    2022821470217Conservative Partnership Institute1334105Mission and program support
    2023522166327Donors Trust Inc99250for election reform activities
    2024522166327Donors Trust Inc3141074for general operations
    2024522166327Donors Trust Inc50000for election integrity effort
    Query that produced these rows
    SELECT tax_year, recipient_name, cash_grant_amt FROM politics_vault.ein_990_grants WHERE ein='454678325' AND tax_year IN ('2022','2023','2024') ORDER BY tax_year DESC, cash_grant_amt DESC LIMIT 30 (Bradley Impact Fund 2024 top recipients: Turning Point USA $10.4M, Leadership Institute $3.0M; AFL not in top 30 for 2023 or 2024)

Expand any finding to see the evidence it rests on.

6 entities5 relations1 sources100% zoom
$27.1M (2022), 3x AFL's reported revenuefoundeddirectorshared payroll (Paychex GJE0068)subpoenaed GJ342/GJ343America First LegalEIN 86-2190372Stephen MillerFounderBradley Foundation$27.1M gift (2022)Eugene ScaliaBradley director (as of 1/18/2022)Conservative Partnership InstituteShared infrastructureArctic FrostJack Smith grand jury

Drag to pan. Click a node to focus its relationships. Use the +/− controls (or ⇧/⌘ + scroll) to zoom.

AFL's funding (Bradley) and its placement inside the CPI / Arctic Frost infrastructure.

The story

The litigation division

AFL occupies the 'courtroom' layer of the conservative machine: where CPI provides personnel and Marble Freedom Trust provides money, AFL turns dark money into litigation. It was founded by Stephen Miller after the first Trump administration.

The 3x revenue discrepancy

The Bradley Foundation's 2022 990-PF reports a $27.1M single-grantee gift to AFL, while AFL's own 2023 990 reports $9.6M in total revenue. A 3x gap is a strong forensic signal that the real money flow exceeds the visible 990, plausibly routed via Bradley Impact Fund or an AFL-related entity.

Inside the Arctic Frost pool

America First Legal Foundation was directly named in Jack Smith's Arctic Frost subpoenas (GJ342, GJ343), and a Paychex payroll subpoena grouped 'AFL Foundation' with CPI, CRA, and Compass Legal Services as one shared payroll system, federal prosecutors treating them as a single integrated infrastructure. Stephen Miller appears in the Arctic Frost officer-match pool.

Key players

Stephen Miller

Founder, America First Legal

Former senior Trump White House adviser; founded AFL as an anti-civil-rights litigation shop. Appears in the Arctic Frost subpoena officer-match pool.

Eugene Scalia

Bradley Foundation director

Trump-1 Labor Secretary and Gibson Dunn partner; joined the Bradley board Jan 18, 2022, the foundation that gave AFL $27.1M.

Source documents · 2

Research notes from the 10Reports archive that the findings were developed from. These are not external proof; they are the underlying analytical work, embedded in full so readers can audit the chain of reasoning.

10Reportscorroborating2.6 KB · markdownretrieved Feb 16, 2026

Circular Funding Analysis

Analysis of the Bradley Impact / Donors Trust / CPI pipeline that re-routed grants to America First Legal across 2022-2024.

Read full document ▸download raw .md ↗

Circular Funding Analysis: Cleta Mitchell Network

Objective: Trace financial flows between organizations to identify circular funding schemes, common paymasters, and self-dealing.

1. Validated Flows

1.1. 1792 Exchange -> United Charitable

  • Amount: $7,190
  • Source: 1792 Exchange 2023 Form 990 (Line 1, Part IX)
  • Context: Grant to domestic organization.
  • Analysis: This is a small amount, possibly a fee for a Donor Advised Fund (DAF) account. If 1792 Exchange has a DAF at United Charitable, it could be a conduit for anonymous funding.
  • Next Steps: Check United Charitable 990s for incoming grants from 1792 Exchange or outgoing grants to network entities.

1.2. The $244,944 Question (CPI <-> SFOF/SFCN?)

  • Internal Note: A previous report (Mitchell Financial Network Red Flags.md) mentioned a $244,944 intercompany balance.
  • Status: UNVERIFIED.
  • Investigation:
    • Searched 1792 Exchange 2023 990: No mention of $244k.
    • Searched SFCN (State Freedom Caucus Network) 2023 990: No mention of $244k.
    • Hypothesis: The figure might be in the SFOF (State Financial Officers Foundation) 990 or the CPI (Conservative Partnership Institute) 990.
    • Action: Locating SFOF and CPI 990 files in 14DocsandFiles.

2. Potential Schemes

2.1. Common Paymaster / Leased Employees (The "Compass" Hub)

  • Evidence:
    • CPI Summary Findings: CPI provides shared resources including "discounted real estate, accounting (Compass Professional Group Inc.), legal representation (Compass Legal Group)."
    • Key Personnel Overlap: Ed Corrigan (CPI, SFCN), Mark Meadows (CPI, SFCN), Paul Fitzpatrick (1792 Exchange).
  • Hypothesis: CPI uses the "Compass" entities to centralize expenses and staff, billing back independent 501(c)(3)s. This allows "independent" groups to operate with minimal dedicated staff while relying on CPI's infrastructure.
  • Risk: If these services are provided at below-market rates, it could be an impermissible private benefit or contribution. If above market, it's self-dealing.
  • Next Step: Search for payments to "Compass Professional Group" or "Compass Legal Group" in the expenses of 1792 Exchange, SFCN, and SFOF.

3. Organization Catalogue

  • 1792 Exchange: Review complete.
  • State Freedom Caucus Network (SFCN): Review complete.
  • State Financial Officers Foundation (SFOF): PENDING (File empty, searching for 990).
  • Conservative Partnership Institute (CPI): PENDING (Summary found, searching for detailed 990).
  • Compass Professional Group Inc: NEW TARGET.
  • Compass Legal Group: NEW TARGET.
10Reportscorroborating19.5 KB · markdownretrieved Nov 13, 2025

Cross-Reference Analysis

Cross-tabulation of grantor/grantee swaps across the AFL funding pipeline.

Read full document ▸download raw .md ↗

Cross-Reference Analysis

This analysis reveals a complex web of interconnections among the researched religious leaders, political figures, and organizations. The analysis identifies three primary network clusters: New Apostolic Reformation (NAR) Religious Network, Conservative Legal/Political Network, and Economic Policy Network, with significant overlap and coordination between these spheres.

  • [[James Goll]] - Member of Apostolic Council of Prophetic Elders alongside:
  • [[C. Peter Wagner]] (NAR founder, connected to multiple figures)
  • [[Cindy Jacobs]] (spiritual warfare, mentioned in multiple profiles)
  • [[Chuck Pierce]] (prophetic leader, NAR apostle)
  • [[Ana Méndez Ferrell]] - "General of spiritual warfare" under C. Peter Wagner
  • [[Rebecca Greenwood]] - Mentored by C. Peter and Doris Wagner, Eagles Vision Apostolic Team member
  • [[Thomas Muthee]] - Spiritual warfare practitioner (though geographically separate in Kenya)
  • [[Brian Simmons]] - Core faculty at Wagner University, Member of Apostolic Council of Prophetic Elders
  • [[Guillermo Maldonado]] - Member of [[Apostolic Council of Prophetic Elders]], co-participant with [[James Goll]] in conferences
  • [[Matt Sharp]] - Senior Counsel, Director of [[Center for Legislative Advocacy]]
  • [[Ryan Bangert]] - Senior Vice President for [[Strategic Initiatives]]
    • Both Sharp and Bangert work on religious liberty cases
    • Both involved in anti-LGBTQ+ legislation coordination
    • Both connected to Federalist Society
    • Shared focus on "Seven Mountains" government influence
  • [[E.J. Antoni]] - Chief Economist at [[The Heritage Foundation]]
  • [[Project 2025]] Connection - Heritage as architect, connects to broader conservative movement
  • [[The Heritage Foundation]] (E.J. Antoni's organization) - Policy coordination with Koch-funded organizations
  • [[Alliance Defending Freedom]] - Receives funding from conservative donor networks
  • [[State Policy Network]] - Connected to both Koch Network and ADF activities
  • [[NAR Movement]] provides theological framework for Christian nationalism
  • [[Seven Mountains Mandate]] (popularized by Lance Wallnau) connects to:
  • [[James Goll]]'s "Fourth Wave" teaching
  • [[Rebecca Greenwood]]'s spiritual warfare for cultural transformation
  • Matt Sharp and Ryan Bangert's government mountain focus
  • Guillermo Maldonado - Hosted "Evangelicals for Trump" launch at El Rey Jesús
  • Thomas Muthee - Blessed Sarah Palin (2008 Republican VP nominee)
  • E.J. Antoni - Nominated by Trump for Bureau of Labor Statistics Commissioner
  • NAR Leaders - Multiple connections to Trump administration appointments Religious Leaders Promoting Dominionism:
  • James Goll - "Fourth Wave" emphasizing societal change through Seven Mountains
  • Ana Méndez Ferrell - Territorial spiritual warfare for governmental transformation
  • Rebecca Greenwood - Strategic prayer for political and cultural change
  • Guillermo Maldonado - Political engagement through Hispanic evangelical mobilization Legal/Political Implementation:
  • Matt Sharp - Legislative advocacy for religious freedom expansion
  • Ryan Bangert - Strategic initiatives for cultural transformation
  • E.J. Antoni - Economic policy influence through Heritage Foundation
  • Koch Network - Provides funding infrastructure for:
  • Heritage Foundation (E.J. Antoni's platform)
  • State-level policy coordination (ADF legislative work)
  • Educational initiatives (overlap with NAR university networks)
  • [[Kenneth Copeland Ministries]] - Extensive family employment and wealth (Kendall Zachary Copeland context)
  • Prosperity Gospel Networks - Financial resources for political engagement:
  • Guillermo Maldonado's megachurch operations
  • Todd White's Lifestyle Christianity financial base
  • Rebecca Greenwood - Christian Harvest International and SPAN headquarters
  • New Apostolic Reformation Hub - Major NAR ministry concentration
  • Focus on the Family - James Dobson connection to broader network
  • Heritage Foundation - E.J. Antoni's policy influence center
  • Alliance Defending Freedom - Matt Sharp and Ryan Bangert's legal advocacy base
  • Koch Network - Stand Together headquarters in Arlington, Virginia
  • [[Kenneth Copeland Ministries]] - Fort Worth (Kendall Zachary Copeland family base)
  • Todd White - Lifestyle Christianity University in Watauga
  • Texas Public Policy Foundation - E.J. Antoni's previous affiliation
  • Guillermo Maldonado - El Rey Jesús megachurch and political platform
  • Hispanic Evangelical Mobilization - Bridge to Republican politics Coordinated Approach:
  1. Territorial Mapping - Ana Méndez Ferrell and Rebecca Greenwood coordinate spiritual mapping
  2. Strategic Prayer - Rebecca Greenwood's SPAN coordinates with James Goll's prayer networks
  3. Political Application - Spiritual warfare concepts applied to legislative battles (ADF legal strategy) Multi-Level Strategy:
  4. Federal Policy - E.J. Antoni (Heritage Foundation) provides economic framework
  5. Federal Litigation - Ryan Bangert (ADF) handles federal religious liberty cases
  6. State Legislation - Matt Sharp (ADF) coordinates state-level legislative advocacy
  7. Local Implementation - NAR churches provide grassroots political mobilization Integrated Messaging:
  • Religious Media - NAR leaders (Goll, Maldonado, White) provide theological framework
  • Political Media - Heritage Foundation (Antoni) and ADF (Sharp, Bangert) provide policy justification
  • Conservative Media - All figures regularly appeBar on Fox News, TBN, conservative outlets
  • Kendall Zachary Copeland - Limited public information, potential private family role
  • John P. Kelly - No confirmed political connections found, may be misidentified
  • Thomas Muthee - Kenya-based operations with limited direct U.S. network integration
  • Ana Méndez Ferrell - Mexico origins with extensive international ministry
  • 1980s-1990s - NAR formation and spiritual warfare doctrine development
  • 2000s - Seven Mountains Mandate popularization and political integration
  • 2010s - Alliance Defending Freedom expansion and Koch Network growth
  • 2016 - Multi-network support for Trump campaign
  • 2017-2020 - Administrative access and policy influence
  • 2021 - January 6 involvement across multiple networks
  • Project 2025 - Heritage Foundation blueprint connecting all networks
  • Stand Together - Koch Network rebrand with cross-movement coordination
  • Legislative Coordination - ADF multi-state anti-LGBTQ+ campaign
  • Electoral Strategy - 2024 campaign coordination across religious and political networks The research reveals highly coordinated activities across religious, legal, and economic networks, suggesting:
  1. Shared Strategic Planning - Regular coordination between network leaders
  2. Resource Coordination - Funding flows between networks for maximum impact
  3. Message Discipline - Consistent theological and political messaging across platforms The networks demonstrate:
  4. Multi-Level Engagement - Federal, state, and local political activity
  5. Institutional Penetration - Placement of allies in government positions
  6. Long-term Strategy - Sustained effort over decades with clear objectives
  7. Financial Flow Analysis - Detailed tracking of money between organizations
  8. Communication Analysis - Private coordination mechanisms between leaders
  9. International Connections - Global expansion of coordinated influence operations This cross-reference analysis reveals a sophisticated, multi-network influence operation combining religious authority, legal expertise, economic policy development, and political activism. Rather than isolated individuals or organizations, these figures represent interconnected nodes in a comprehensive strategy to reshape American politics, law, and culture according to a specific theological and political vision. The level of coordination suggests ongoing strategic planning and resource allocation across network boundaries, representing one of the most significant private influence operations in contemporary American politics. Entity Type: Organizations Certainly! Below is a detailed organizational and network analysis of the provided content on Cross-Reference Analysis focused on the religious-political movement nexus, with emphasis on financial flows, political connections, and network relationships — particularly as they relate to Christian nationalism, religious liberty/freedom strategies, and influence operations.
  • New Apostolic Reformation (NAR) Religious Network
  • Key Figures: James Goll (Apostolic Council of Prophetic Elders), C. Peter Wagner (NAR founder), Cindy Jacobs, Chuck Pierce.
  • Leadership Hierarchy: Apostolic Council functions as core leadership; spiritual warfare specialists like Ana Méndez Ferrell operate under this leadership.
  • Institutional Nodes: Wagner University faculty (Brian Simmons), conference leaders (Guillermo Maldonado).
  • Conservative Legal/Political Network
  • Key Figures: Matt Sharp (ADF Senior Counsel), Ryan Bangert (ADF SVP Strategic Initiatives).
  • Hierarchy and Roles: Sharp and Bangert lead legislative advocacy/legal efforts; connected to Federalist Society.
  • Economic Policy Network
  • Key Figures: E.J. Antoni (Heritage Foundation Chief Economist).
  • Connections: Heritage Foundation linked with Koch Network funding infrastructure; State Policy Network interfaces with both Koch and ADF.
  • Koch Network is the primary financial backbone for economic policy groups like Heritage Foundation, State Policy Network, and indirectly for ADF’s legal efforts.
  • Religious Funding Networks include:
  • [[Kenneth Copeland Ministries]] — significant wealth accumulation through family employment.
  • Prosperity Gospel Networks — megachurches like Guillermo Maldonado’s El Rey Jesús provide both resources and political platforms.
  • Funding flows appear coordinated across networks to maximize political impact at local, state, and federal levels.
  • Strong ties exist between these networks and the Trump administration:
  • Maldonado hosted “Evangelicals for Trump” launch event.
  • E.J. Antoni was nominated by Trump for a federal post.
  • Multiple NAR leaders have Trump administration appointments or influence access.
  • Legal advocacy groups like ADF coordinate anti-LGBTQ+ legislation aligned with Christian nationalist objectives, interfacing with conservative legal circles such as the Federalist Society.
  • Three major clusters identified:
  1. NAR Religious Network: theological/spiritual warfare leadership promoting Christian nationalism via Seven Mountains Mandate.
  2. Conservative Legal/Political Network: ADF legal advocacy pushing religious freedom cases aligned with Christian privilege expansion.
  3. Economic Policy Network: Heritage Foundation & Koch-linked organizations providing economic policy frameworks facilitating conservative governance.
  • Overlaps exist:
  • Individuals like Matt Sharp bridge legal advocacy with political strategy informed by NAR’s theological mandates.
  • Geographic hubs in Colorado Springs (NAR), Washington D.C./Virginia area (Heritage Foundation, ADF), Texas ([[Kenneth Copeland Ministries]]).
  • Media presence is integrated across platforms:
  • NAR leaders promote religious/theological messaging on TBN and conservative outlets.
  • Heritage Foundation & ADF provide intellectual/policy justification in conservative media including Fox News.
  • Electoral activities include coordinated campaigns supporting Trump-era policies; grassroots mobilization through NAR churches; legislative efforts targeting cultural issues.
  • Major funding comes from the Koch network channeled through think tanks (Heritage Foundation) and policy coordination groups (State Policy Network).
  • Religious megachurches employing prosperity gospel models provide independent financial bases supporting political engagement.
  • Direct links to Trump administration officials via appointments and campaign support events.
  • Connection to conservative judicial/legal circles: Federalist Society involvement by ADF members sharpens litigation strategies around religious freedom cases.
  • This entity functions as a hub integrating:
  • Theological mobilization via NAR's spiritual warfare/dominionism doctrine,
  • Legal/policy mechanisms through ADF,
  • Economic policy influence backed by Koch donors via [[The Heritage Foundation]] et al., thus forming a tightly woven influence operation across multiple spheres of power.
  • Stated objectives often frame their work as protecting "religious liberty" or promoting "religious freedom."
  • Actual objectives advance Christian nationalist goals—merging church/state through dominionist theology—and expanding Christian privilege via legal/political means targeting marginalized groups under guise of religious rights.
    Source / Entity Role / Function Funding Flow / Connection Political Access
    Koch Network Major donor network Funds Heritage Foundation & State Policy Net Influence via economic policy & legislation
    [[Kenneth Copeland Ministries]] Religious funding base Family wealth fuels ministry & political reach Regional Texas power center
    [[Guillermo Maldonado]] Megachurch leader/political platform Independent financial resources from church Hosted Evangelicals for Trump
    [[Alliance Defending Freedom]] Litigation/legal advocacy Supported by conservative donors including Koch-linked sources Coordinates anti-LGBTQ+ laws
    Heritage Foundation Economic think tank Receives Koch funding Provides economic framework at federal level
    [[New Apostolic Reformation]] Spiritual/theological leadership Ministry donations & university affiliations Influences cultural transformation agenda
  1. [[Christian Nationalism]] Theologically driven by NAR leaders advocating Dominionism and [[Seven Mountains Mandate]] aiming to transform government/[[Culture]] spiritually and politically—supported strategically by allied legal/policy groups.
  2. Religious Liberty Used as a legal veneer to justify expansion of Christian privilege; ADF litigation aims to enshrine these rights while undermining LGBTQ+ protections or minority rights disguised as protection against discrimination claims.
  3. [[Religious Freedom]] Serves as a broader catch-all term employed in legislative campaigns coordinated by ADF that align with dominionist goals promoted by NAR actors—a strategic tool rather than purely doctrinal principle.
  • Overlap among key individuals spanning theological leadership, legal advocacy teams, economic policy strategists reveals intentional cross-network integration for comprehensive influence operations.
  • Individuals holding both ministry positions while engaging in political lobbying blur lines between church/state separation—potential regulatory capture risks especially where appointments occur in government agencies tied to their agenda areas.
  1. Donor money from Koch network → Heritage Foundation → State-level policy coordination → supports litigation/legislation advocated by ADF → facilitated culturally/spiritually at grassroots level by NAR churches/universities funded separately or indirectly linked via shared donors/megastructures.
  2. Prosperity gospel megachurches independently generate funds enabling direct political engagement/events endorsing candidates aligned with movement goals. Consistent use of Dominionist language (“[[Spiritual Warfare]],” “cultural transformation,” “Seven Mountains”), combined with messaging about “religious liberty” establishes ideological coherence reinforcing political/legal strategies deployed at all levels—from prayer meetings to courtrooms to legislatures. Trump administration appointments linked directly to core figures within these networks offer institutional access allowing regulatory shaping favoring their agendas—e.g., E.J Antoni’s labor statistics commission nomination aligns economic data framing consistent with movement priorities; similarly multiple NAR leaders hold advisory/influence roles within executive branches during said administration period.
  3. Advancement of Christian Nationalist Objectives The entity advances these objectives through intertwined theological doctrines advocating dominion over government (“Seven Mountains”), backed legally by targeted litigation expanding exemptions framed as [[Religious Freedom]] but promoting exclusionary policies reflecting [[Christian supremacy]] ideals.
  4. Government Resources/Access Provided Connections enable direct placement or advisory roles within government agencies affecting labor policies, judicial decisions via litigation strategy input; also grassroots mobilization influences electoral outcomes benefiting aligned candidates ensuring sustained access.
  5. Broader Influence Network Integration This entity serves as an integral node linking spiritual authority centers (NAR) with strategic lawfare organizations (ADF) funded/supported economically by well-established [[right-wing]] donor networks such as Koch foundations—creating multi-dimensional pressure points influencing U.S politics/[[Culture]] systematically.
  6. Transparency & Accountability Gaps Significant lack of publicly available detailed financial flows especially regarding private family ministries like [[Kenneth Copeland Ministries]] limits transparency around wealth accumulation/funding use; limited disclosure about private coordination mechanisms among top leaders restricts accountability. This comprehensive cross-reference analysis exposes an extensive network combining religious authority rooted in [[Dominion Theology]] ([[Christian Nationalism]]), sophisticated legal-political advocacy cloaked in “religious liberty” rhetoric ([[Religious Freedom]] lawfare strategy), supported financially primarily through conservative donor ecosystems including the powerful Koch network alongside affluent megachurch ministries that fund grassroots mobilization—all converging into a multi-level influence apparatus shaping American politics from local communities up through federal institutions largely during the Trump era but continuing presently toward future electoral cycles (Project2025, etc). The interplay between [[Spiritual Warfare]] ideology, targeted legal battles over cultural issues such as LGBTQ+ rights, aggressive economic policymaking aligned with [[right-wing]] agendas creates an integrated machine aimed at reshaping U.S governance according to a distinctly Christian nationalist vision while evading robust public transparency or regulatory oversight—signaling critical areas requiring further financial forensic research and communication monitoring especially given its long-term strategic planning horizon extending beyond immediate electoral cycles. If you want me to develop specific visual maps, conduct deeper financial tracing hypotheses based on this data set, or explore individual actors' biographies relative to these findings next steps are ready!
  • Cross-reference with [[Other]] network entities Analysis generated on 2025-08-24 09:18:08 using [[Political Research Batch Processor]] Merged from Research Analysis on 2025-08-24 19:10:19

Sources

Cite this
Hall, C. L. (n.d.). America First Legal. Cody Hall. https://codyhall.site/investigations/america-first-legal
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