Kristi Noem's Dark Money Is Much Darker Than You Think
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Kristi Noem’s dark money problem is much bigger than the American people know,and a deep dive exposes a RICO level worthy of investigation that should concern all Americans because this well-oiled machine is disenfranchising all of us. As a service to my fellow Americans I began reporting on the injustices rampant with fraud, corruption, waste and abuse in South Dakota and giving Americans an stark warning that our problem could soon be the country’s.
For those of us in South Dakota, screaming into the void about Kristi Noem’s corruption has become a way of life. So, it’s no surprise that Politico’s latest bombshell is just the tip of the Ice Barbie-berg.
The article exposed that Noem funneled $80,000 directly into a private company she quietly set up in Delaware. Noem failed to disclose the $80,000 payment to the public. After being tapped for a Federal role, Noem she was required to release a detailed accounting of her assets and sources of income since 2023, but she did not include the income from the dark money group on her disclosure form, a major ethics violation.
One name stood out, while dark money groups are notoriously secretive I noticed that Staci Goede was the treasure, a name I remembered from previous deep dives in to Noem’s dark money operations in the state. Her firm has a listed address on Garden Lane in Springfield, Virginia which appears to be a residential building. I searched the firm’s address in court documents to find that Goede was also the treasurer of at least 6 other Dark Money groups and that a legal case has been brought against her for the exact same thing. A Delaware shell company, Ardleigh Impact was created on October 25, 2023 and in a short span of just 2 months, this organization gave $2,5756,000 to the 6 of the organizations Goede was a treasurer of which include the following;
AFC Victory Fund
More Jobs Less Government
Buckeye Leadership
Defend Ohio Values PAC
Conservatives For American Excellence
Congressional Leadership PAC
The Campaign Legal Center has filed a bombshell complaint with the FEC, exposing how a mysterious shell company called Ardleigh Impact funneled nearly $3 million to political groups in just two months — all while never engaging in any real business or commercial activity and having no financial records to speak of. Even more suspicious? Ardleigh Impact is registered to the same address as political operative Staci Goede.
The money trail has sparked an ongoing investigation into a potential straw donor scheme — that’s when someone hides the true source of political money by routing it through another person or company, a clear violation of federal campaign finance laws designed to keep elections transparent.
In short, millions of dollars may have quietly flowed into campaigns from unknown backers. While little is know about the operatives behind Ardleigh, at least one unnamed political strategist associated with Dr. Mehmet Oz is associated.
You can read the shocking details of this case here.
PO BOX 2891
In the same way that secretive company Ardleigh – A Delaware shell company- was quickly set up and then began funneling money to Dark money groups associated with dark money groups associated with Goede’s address, Noem used the same practice setting up Delaware shell company Ashwood at roughly 1pm on June 22, 2023 and approximately 4 minutes later established dark money group American Resolve Policy Fund another dark money group for which Goede was the treasurer. I noticed something interesting about the FEC filings, unlike the other dark money groups these groups used a Post Office Box address
PO BOX 2891
Springfield, VA
22152
An address in the same hometown as Goede and obviously operated by her. The combination of location and treasurer role undoubtedly connects Goede to this PO box. I decided to search the address to see what other dark money groups were associated with this address and what I found was shocking at least 5 other dark money groups were associated with Goede’s PO Box
American Veterans Vote Inc
United 2024
Right America Inc
Kitchen Table Conservatives
The 1776 Project PAC
All of these groups practice activities that severely undermine democracy and the voice of ALL Americans they are highly unethical and in the case of the 1776 Project PAC- illegal. In October 2023, Maryland authorities fined the 1776 Project PAC $20,250, marking the largest "authority‑line" fine in state history. The PAC had sent 13,879 text messages urging voters to support a "pro‑parent" school board slate in Carroll County during the November 2022 election—but failed to include any disclaimers indicating who paid for those messages, violating state election transparency law. 1776 is an organization that seeks to remake education across America by poisoning local school boards with radicals.
You can read more about this case here
Two weeks after the ruling in this case, Ardleigh was created.
This was far from the first time an organization linked to Staci Goede landed in legal trouble. In 2024, Goede was again dragged into court—this time in California—after her campaign distributed political materials promoting candidate Tief Gibbs Jensen without the legally required disclaimers. The door hangers, plastered across voters' homes, conveniently omitted the "Paid for by" information, a clear violation of election transparency laws.
While the judge dismissed the case, citing the small dollar amount—just under $400—the real issue isn't the cost; it's the pattern. Time and again, figures like Goede operate in the shadows, laundering dark money into our elections, sidestepping accountability, and eroding the basic transparency American democracy depends on.
This is not about door hangers—it’s about a network of political operatives who deliberately exploit legal gray areas to hide donors, manipulate campaigns, and keep voters in the dark. The question is no longer if they’ll do it again—but whether we will finally shine enough light to stop them.
Dakota Institute for Legislative Solutions
It is unclear who the mastermind of all of the schemes are, though I speculate it may be Rob Burgess, a seasoned Republican operative, that previously held communications roles in the South Dakota GOP (2014) and worked on several Republican campaigns—including Trump’s, both in 2016 and 2020—as well as U.S. House campaigns. In March 2022, he launched DILS, which he described as a nonprofit “to generate support for Governor Noem’s agenda,” with an initial operating budget of $800,000 and plans for $1.5 million in the following two years. Burgess fake Institute, operated as a bizarre attack as campaign and it mirrors almost identically the operations of American Resolve Policy Fund- the one Noem used Delaware Corporation Ashwood to funnel money from. Additionally, Burgess signed off on campaign messaging with Goede in 2022 indicating he was part of other operations.
Burgess spent $2.5 million on grotesque and divisive advertising throughout the state of South Dakota and vowed to attack anyone that did not give Noem 100% support among the most consequential was propaganda “educating” on the consequences of Critical Race Theory. This talking point links him to the The 1776 Project PAC that uses Goede’s PO BOX and paid the highest FEC violation fine in history.
The problem with dark money is that Americans do not know who is funding our politicians or what they want in return. When it comes to Noem, she has a way of paying up. Rob Burgess registered a Nevada PAC, Take Back the West, which funneled money to the consulting firm McShane LLC, where Burgess was chief of staff. Five days after the 2020 election, McShane LLC received a $50,000 donation from the South Point Hotel and Casino, which also hosted one of Kristi Noem’s three trips to Vegas over the past several months. McShane LLC also worked to rally the Proud Boys to promote Trump’s Big Lie about the 2020 election results. According to reports in The Dakota Free Press.
If we are serious about dismantling the systems propping up this dangerous administration—and figures like Kristi Noem—we cannot just chip away at the surface. We must strike at the very foundation that holds them in place: the dark money networks, the shell corporations, the operatives working in the shadows. Their power does not exist in a vacuum—it’s been carefully constructed through layers of corruption, secrecy, and manipulation. Now is the moment to be relentless. To expose the criminals sabotaging our democracy. To pull their empire apart, piece by piece, until there is nothing left to shield them from accountability. Democracy doesn’t collapse overnight—it erodes when we let these foundations stand unchallenged. It’s time to bring them down.
Previously Reported Criminal Activity From DH-Mess
This story is an update on the “Open Letter” story I Published on 5/19/2025 the following contains the bulk of that piece for those keep track of Noem’s financial activities. Stay Vigilant Sleuths!
Racketeering: After defendant Noem’s, election in 2018 she quickly established multiple enterprises ranging from businesses, to campaigns, and PACs and aligned them with multiple enterprises withing Trump’s orbit. Initially, this alignment was superficial Noem frequenting many conservative events and promoting Trump’s policies. 2019 would serve as tipping point in many ways most notably when late GOP donor Foster Friess invited Noem and Corey Lewandowski on a deep-sea fishing trip with Donald Trump and major political figures and donors in Trump’s circle. Shortly after, Lewandowski would allegedly begin their romantic relationship raising ethical questions and he also became her advisor. While the national news broke from the not-so-reliable Daily Mail, it is something that has been known amongst South Dakotans for some time. South Dakota now had a sitting governor that was almost always absent using state funds to travel the country with and for many enterprises while being advised from by a Trump Campaign advisor. Lewandowki would serve as the chief coordinator between Noem and other enterprises.
As the network began forming, 2019 would also be pivotal due to Covid-19 in part because it allowed Noem and other enterprises to echo Trump’s anti-science policies that were very popular in right-wing circles at the time, but the unprecedented funds with no-strings attached allowed for this network to racketeer copious amounts of money. Most people recall the scandal during the first round of Covid-19 funds when Kristi Noem decided to spend $8 million on ads featuring herself, thinly veiled campaign ads illegally financed by taxpayers. This was controversial for reasons that are obvious, but the real controversy is that this event demonstrates the mechanism by which Noem moves funds between enterprises. She moves money legally to a department, creates an unnecessary project to her benefit, and then awards the contract to a contractor that moves funds between other conservative enterprises or as reimbursement for previous donations. Most Often these enterprises are media companies like film or advertising. In this case, the contract was awarded to Go West Media, an Ohio-based company with direct ties to Corey Lewandowski and Ben Yoho, Vivek Ramaswammy’s previous campaign manager. During the second round of Covid-19 federal funding, Noem got even more aggressive in a scheme to redirect taxpayer money back to herself and associated enterprises this time directing the Covid-19 funds to her Department of Labor and creating the “Freedom Works Here” campaign creating countless advertisements where she cosplayed as different professions, typically blue collar and law-enforcement adjacent. Does this sound familiar? Again, the contract was awarded to Lewandowski and Ben Yoho firm, Go West Media. The project not only diverted taxpayer money to Noem’s benefit, the entire webpage, that claims to find employers employees and help people move to South Dakota- is a scam. There has been no evidence Noem’s administration is willing to furnish that anyone has moved to the state because of it. In addition to a litany of commercials, Noem utilized undisclosed funds to publish two books during this time period through Center Street Publishing, a well-know right wing racket that aids in moving funds while also raising the celebrity of Conservative politicians to connect the dots for you, at the same time this book was published Ramaswamy was also an author at the publisher. After the first book, “Not My First Rodeo” was published, The National Republican Congressional Committee (NRCC)
purchased $122,000 worth of books as well as a few other conservative organizations. After Noem’s “No Going Back The South Dakota GOP spent just under $18,000 on the book in an effort to launch it on to the best seller’s list and move money between enterprises. Multiple enterprises Noem traveled to with taxpayer funds would ultimately purchase large quantities of her book Additionally, Transition Studios, another Ohio-based media firm that focuses on conservative issues, was tapped to produce a documentary about Kristi Noem with a release date of June, 20 2024. Put a pin in that it will be relevant later. The documentary gave exclusive rights to Elon Musk’s X. To ensure clarity, lets’s piece together everything we know about the Meth campaign, the utilization of Go West Media, Center Street Publishing, and Center Street Studios, and see how this pattern has manifested itself in the most horrific ways at a federal level.
Continuing a pattern of using media contracts as a vehicle for corruption, Noem’s administration awarded a $200 million contract to People Who Think LLC to record her trips to ICE detention centers and violent ICE raids around the country as well as to create a plethora of propaganda for the DHS webpage. This little-known media company is owned by Jay Connaughton leader of Republican Party of Louisiana and 2016 Trump media advisor. The contract number 70RDA225FR0000013 Task Order Number: 70RDA225FR000013. Kristi Noem is a known close associate to Louisiana’s Governor, participating in his annual alligator hunt to raise funds for Louisiana GOP.
The network of collusion and fraud entangling this administration is vast with a web of entities all playing a role in siphoning taxpayer dollars and manipulating power the evidence I have already presented is just the beginning there is a staggering wealth of information exposing this corruption now that we have clearly established the pattern mechanism of the scheme it is time to delve deeper into additional crimes that demand your immediate attention what you're about to uncover is not just an ethical failing it's a calculated assault on public trust one that now extends to the very heart of the Department of Homeland security under Kristi Noem’s influence. Circling back to the “Freedom Works Here” campaign, it was not only dubious spending and cronyism- it was a deliberate act of exploitation. Discussions with two out-of-state political firms that were awarded contracts related to Gov. Kristi Noem’s workforce marketing campaign began weeks before the official requests for proposals were published, according to documents obtained by Sioux Falls Live. The documents obtained by Sioux Falls Live indicate the governor’s office developed the plan in consultation with The Strategy Group, an Ohio-based consultant that worked on Noem’s 2022 re-election campaign, and eventually was awarded the $5 million contract.
The documents show that Ben Yoho, the CEO of The Strategy Group, and officials from the political polling firm WPA Intelligence pitched the GOED after the 2022 election on a plan to do market research to guide Freedom Works Here. The language of that proposal is nearly identical to the RFP that was published on Jan. 10, which was awarded to WPA for $100,00.
WPA Intelligence was operated by founder Chris Wilson at the time who was fired on December 5, 2024 after two external audits confirmed he was using the firms money for lavish personal expenses such as vacation and nannies. His firing came months after the company’s CFO was fired and charged with embezzlement. Does this sound familiar?
Not only were Lewandowski and Yoho paid to write the RFP, Not only was it prearranged that they would get the contract, they used the fake bidding process to steal the intellectual property of a local business whose creative vision and original concepts were stripped away and handed to go West media under the guise of a state sponsored initiative. Noem’s administration not only circumvented the legislative process required this is in awarding contracts, she instead did a closed bid Select and broke the most fundamental law of all when it comes to public procurement Noem allowed go West media to see the other bidders Proposals She bypassed local talent she seized their ideas without fair compensation or recognition and gave the lucrative contract to go West media who used the exact creative concepts as the local company (please see exhibit A for a side by side of the local Sioux Falls company and go West media) it is beyond compelling.) There was bipartisan outrage in the legislature because they were snubbed from a process they were elected to participate in, and the process which legally mandates spending funds within the state when possible was completely ignored. The irony over the fact that an ad campaign that’s sole purpose is to convince South Dakota to expand and get to work in South Dakota was orchestrated by yet another Ohio company was lost on no one. Despite complaints and moderate legal push back this case was never investigated appropriately because the region lacks the legal apparatus and talent to do so and Noem’s chokehold on information obstructs access to information to piece the scheme together. I would like to remind you that violating trade secret law is a predicate offense worthy of RICO investigation particularly when it accompanies other such offenses as fraud and refer you to the 2016 Defend Trade Secrets Act (DSTA) which further codifies this law. The local business has clearly suffered damages due to enterprises that deliberately violated their intellectual property rights.
The Office of Tourism and Department of Labor were by no means the only departments she used “the media contracting scheme” to raise her celebrity and divert funds. I cannot list them all but another notable and bizarre example is when in 2021 Noem seized $322,500 that the Legislature intended be used on implementing the marijuana initiatives that voters approved over the Governor’s objection in order to put her face on Television in a series of ads The source of funding for the medical-cannabis ads was Senate Bill 35 the intended version of the legislation appropriated a lump sum of $4,161,502 for implementing the provisions of Constitutional Amendment A, which legalized marijuana for people age 21 and older, and for Initiated Measure 26, which legalized medical-cannabis use, but didn’t provide any specifics. Noem opposed both the proposed medical-cannabis laws and Constitutional Amendment A. The ads provided absolutely no helpful information on the implementation of either amendment they were overt campaign advertisements illegally paid for by taxpayers against the will of the legislature. Noem ultimately sued her own constituents and overturned the will of the voters in lawsuit that cost South Dakota Taxpayers $142,000 that she unsuccessfully tried to make pro-marijuana activist groups pay. These funds came from the Department of Health and Human Services they have not disclosed contractor or vendor number at this time. (Information can be hard to access under Noem’s authoritarian regime).
******The foundational enterprise I will refer to throughout the rest of this document I will refer to as the conglomerate for brevity and simplicity in untangling the web of corruption I am trying to demonstrate. The conglomerate consists of the big players we all know about that have manipulated American politics and destroyed democracy since Regan’s presidency. Think Heritage Foundation, Americans for Prosperity, Hillsdale College etc. and any and all entities involved in Project 2025. As a former right wing operative living in a roll-out state I can tell you they all work in tandem within the smallest governments to place bad actors in the smallest positions and ensure they rise to a federal level. As a creator that has promised my viewers to write Project 2029, the undoing of Project 2025, I can tell you that if Jeffries and others do not begin to understand how this apparatus works and run counter to it there will be no going back. If the pillars of these bad actors are not dismantled on a small scale, this regime will not fall. (Thank you to my supporters that have supported this research, this letter is one of many gifts to you). I have additional documentation explaining how this apparatus moves funds so lets put a pin in that for now.
In another move to divert taxpayer funding to the inner circle and/or conglomerate, Noem dismantles a board of over 40 educators and administrators set to write SD social studies standards and replaced them with a handful of close allies from the conglomerate organizations such as 1776 project, Heritage Foundation, etc. Instead of allowing them to write the standards she took taxpayer funds paying Hillsdale College $200,000 to write them instead and instructed the new board- that had virtually no educational background- to pass them. The standards are horrific, inaccurate and profoundly racist White Christian Nationalism. In a poetic revelation this week, the meeting set to train teachers on said standards was cancelled due to lack of funding due to Noem’s reckless behavior. She is so dumb. So observably and painfully stupid and that is why the conglomerate likes her. They control everything she does. Lewandowski is there for a reason. He would be the DHS Secretary but I don’t think his Temu Derek Chauvin-looking self would fair well in the DHS propaganda campaign.
Money Laundering, Bribery, and Honest Services Fraud via In-kind payments, quid pro qou payments, and barter transaction I appreciate your patience as I connect all of the dots. Noem, Lewandowski, Yoho, and private sector companies involved in a combination of in-kind payments, barter transactions, and quid pro quo corruption. I would like to first, refer those who are unfamiliar with the case to H.J Inc V Northwestern Bell Telephone Co. to understand the implications of such transactions as they pertain to a broader pattern of schemes. These transactions are often difficult to assign monetary value to, however, the best way to determine the value of a good or service is to sell it. As Noem continued to expand her spending on the “Freedom Works Here” campaign using the department of labor to divert taxpayer money to raise her celebrity in thinly veiled campaign ads and enrich Go West Media, her greed continued to grow and she made a decision, unprecedented for even her, she asked private businesses throughout the state to contribute $10,000 to taxpayer-funded “Freedom Works Here" in exchange they would have a chance to be featured on her website, and get shoutouts on social media platforms like Facebook and X.
Noem would accumulate $250,000 from this plea which of course further enriched Go West Media. Noem’s celebrity as currency is not only undeniable but quantifiable. After further investigation I discovered that she is also the face of Go West Media her cosplay commercials are all over the front page and used as advertising, this is not a legal quid pro quo. To further build upon the quantifiable value of Noem’s celebrity and pattern of unethical media abuse I will refer you to the case Travelers United V. Kristi Noem where yet again, Noem finds herself a defendant. This case was filed in the Superior court of the District of Columbia the lawsuit alleges Noem engaged in deceptive advertising practices by promoting Smile Texas, a cosmetic dentistry practice in Sugarland Texas on her personal media pages and refused to disclose financial relationships or compensation received for endorsement. To be clear, a sitting governor to the state of South Dakota was receiving consulting services from Donald Trump’s political consultant at the exact same time, while using taxpayer funds to travel the country to campaign for Trump, while also using taxpayer money and private sector funds obtained through unethical a advertising to funnel money back to said consultant, while also using taxpayer money to travel to Texas to engage in unethical advertising and responded again by failing to disclose finances. The case was dismissed not because of merit but because the group could not serve papers to Noem because she threatened and evaded them.
Lewandowski’s participation in these barter transactions is also easily quantifiable and present themselves as what I believe to be both in-kind payments and quid pro quo transactions. Lewandowski and Noem’s administration allege that he was working for Noem as a consultant for free. Reports indicate he was being paid $20,000 per month by Trump the administration on top of a salary. No reasonable person would believe he is now doing charity work for a sitting governor with unlimited access to funds, especially when countless conduits were forged to direct funds to enterprises by which he is directly associated. To imagine that a sitting governor would receive such a high value favor without a quid pro caveat that would interfere with her policies and gubernatorial duties to her state as they often conflicted with the interests of an ongoing national campaign is asinine. Lewandowski made his career as a policy advisor policy is Lewandowski’s currently.
If it seems personal, it doesn’t begin to get personal until now. It is time to circle back to the 2024 flood that impacted my community that is still suffering immensely from and the previously mentioned Transitions Studio documentary. Prepare to connect the dots in another meandering web of lies and corruption. Operating under the assumption that Lewandowski was offering policy advice and that it was abundantly clear what role Noem would be tapped for given a Trump victory, as evidenced by her fierce campaign against the immigrant population, and her Doug Burgam’s and other far right MAGA politicians in the Midwest coining the phrase “Every state is a border state” in order to be more appealing on the national stage to a voter base that vehemently opposes immigration and positioned it as their number one issue in 2024. This, of course was well orchestrated by Heritage Foundation and other big money lobbyist and architects of Project 2025 that were committed to getting Trump loyalist in to key cabinet positions.
In 2021 Willis and Reba Johnson of Tennessee (note the same state Noem Jet set off to after lying to South Dakotans about flood risk in 2024) gave Noem $1 million to send 50 South Dakota National Guardsmen to the US-Mexico border despite having no jurisdiction or mission. Allowing private citizen to pay for the deployment because they dislike brown people was as highly unethical and faced legal challenges and controversy, of course, in South Dakota there was no accountability. This was nothing more than optics and advertisement for Noem to the rest of country. Like Noem always does when she creates controversy everyone obeys in advance and her tactics become even more overt. In 2023 in a unique one-of-a-kind never-done-before gift to Governor Greg Abott Noem deployed the SD National Guard to the Southern border again This time by transferring funds out of out state’s Natural Disaster and Emergency funding. This meant that there was no National Guard to evacuate and protect South Dakota when two rivers were rapidly cresting at unprecedented levels. For context the National Guard has been deployed in every other major flood with water levels far lower than this. She had knowledge of this devastating event by late June 19 Early June 20, 2024. She continued to downplay the event you cannot convince myself or any other reasonable American that Lewandowski, Transitions Studios, and Musk were not advises her not to How well would their exclusive perform if Noem was facing one of the most colossal government failures of modern time? This community was deprived of their right to honest services. The government must take action investigate to make sure victim’s lives can be restored.
Violation of Stafford Act and Interfering with commerce as a result
While enroute to Tennessee, local authorities quietly constructed a levee designed to shield a wealthier neighborhood and a business district-one where Noem held personal interest in at the expense of displacing homes and properties of those outside the floodplain. Among these properties were vacant plots designated for Noem’s controversial workforce housing project, a venture marred by allegations of misappropriating Covid-19 relief funds infrastructure funds diverting them to certain contractors and neglecting the safety needs of said community which has dangerously poor infrastructure. The devastation to this community and significant loss of homes and property is unimaginable to those that have not seen it in person.
The resulting devastation to this community was catastrophic homes were destroyed families were uprooted and property losses were staggering yet despite the scale of the disaster no National Guard assistance arrived deployed elsewhere they were unavailable and even more damning governor Noem withheld a disaster declaration for two months this delay meant that hundreds of displaced only as many left homeless were denied even the meager emergency payment of $750 until late August or early September state support for basic repairs or even dirt for stabilization never materialized nearly a year later this community remains in crisis the land continues to erode sinking further into a mud pit only last week did officials announced plans to begin clearing toxic lake debris an insufficient response to an ongoing disaster fueled by negligence mismanagement and apparent corruption at the highest levels.
This disaster is a culmination of multiple schemes. Of course, not having the miliary efficiency of the National Guard both before and after the incident was a critical failing that resulted in more loss of property and put lives in danger these consequences were only suffered because Noem needed to funnel public funds to Texas both as a political favor and for optics. Remember at this point in time, she knew what role she would be appointed in Trump’s cabinet with a profoundly inadequate resume to qualify her for DHS Secretary she had to create a project that benefits herself and then use taxpayer funding to execute it. The consequences are more nefarious when you consider the fact that this particular scheme siphoned money from the states emergency funding by having the National Guard in Texas South Dakota also had its only financial apparatus for relief depleted robbing victims of both military efficiency and critical funds they were entitled to. Additionally, as many of you know, The Stafford Act required communities to perpetually uphold FEMA standards and to have the ability to price match in order qualify for federal funding, I suspect that this why Noem waited over 30 days to declare a disaster which not only violates the Stafford Act and obstructed access to funds American taxpayers are entitled to, it also barred virtually any other grants victims may have been eligible for that demand an application 30 days from when the disaster occurred. How the community got any FEMA aid per current laws in the midst of her dereliction of duty is beyond me but it warrants an investigation
In a wild twist to this story, a couple of the businesses in the business district that were protected by they makeshift levee, were currently convicted and currently charged in active RICO cases for traveling to South America and trafficking people to work in their facilities where they were subsequently abused. To be clear a community of homeowners had their homes deliberately taken out by an administration, to protect businesses that had trafficked people from the Southern border, and they were not entitled to legal protection in the Stafford Act or their own National Guard because those resources were allocated to the border because the border was a bigger issue than Noem’s own state.
Additionally, during my investigation, I found evidence of intimidation and bribery of the City Council members and Union County. Community members were becoming increasingly enraged because Noem stated she did not send National Guard or request Fema because the City and County had to request it. The flood town city with hundreds of newly homeless residents could not understand why the City was not helping particularly because the city itself offered zero help. No grants, no clean up, not so much as water bottles or tarps. Making matters worse this particular City is split in half with one side in Iowa. Iowa had National Guard, FEMA, and countless tents from NPOS and other groups that were dispatched to the Iowa Side. The City remained oddly silent. It was the most bizarre thing I have ever witnessed. I did a deep dive of city council minutes from all impacted communities and had a private off-the-record conversation with a City Council member. The truth is that they did request the National Guard and they did request FEMA. However as time went on they felt they needed to portray Noem positively and stay in her good graces in order to get anything from the state. I turned this information over to the Washington Post in an article I contributed attached in this document.
Kristi Noem’s greed became so profound by 2022 that she blatantly asked if she and lawmakers could profit f Covid-19 funds which delayed their disbursement. I also believe this bought time for Lewandowski and others to better plan a scheme that would skirt the law. Noem siphoned so much taxpayer money from critical programs that as I write to you, I know it will seem unbelievable. The brazenness of her fraud is almost genius. Her next scheme was to steal millions in American Rescue Plan funds intended for Covid-19 for critical infrastructure. Much like her scheme to use other funds from other programs to direct funds back to herself, Corey Lewandowski, and others in Trump’s inner circle, it was marred with controversy and corruption yet absent proper accountability. Today I am turning to you. I knew it was bad but after launching a thorough investigation in June, I realized it was much worse.
The concept of workforce housing was proposed under the guise of creating affordable housing for South Dakota’s expanding population and job growth, this is problematic for many reasons most notably that the housing is not affordable the growth does not exist. The more nefarious issue is Noem’s use of statistics to sell this guise. Noem uses data that reflects the proportion of a workforce that is out of town or out of state. The project in North Sioux City, which is tearing a community apart sits in the Sioux City metro area. This means that Sioux City is in Iowa, South Sioux City is in Nebraska, and North Sioux City is in South Dakota. When standing on the plot of land allocated for this grift, you can literally see all three states. I do not mean in the Sarah Palin “ I can see Russia from my house” sense, I mean I could walk to either state in minutes. It is also imperative to understand that South Dakota has no state income tax and serves as a tax shield for many Iowans and Nebraska. Finally, it is also critical to understand that a portion of North Sioux was turned into an incorporated HOA on the river with high-end private Arnold Palmer golf course. It is a super tax shield so to speak. Multiple millionaires and billionaires have property there while their businesses or places of Employment are in Iowa or Nebraska. Why is this information so critical?
One argument for the development is that 60% of work force is from out of state. That makes sense since many places out of state are slower to their places of employment than in state. The HOA for example has about 90% of their workforce working in another state but that certainly does not guarantee
affordable housing units. The next problem is that the calculation for “affordable” is based on county numbers, in a county with significant outliers. The Homes they are proposing as affordable will start at around $400k and they are not capped, they can rise with the market. It is taxpayer funds going to wealthy contractors (aka other enterprises) that are committed to building homes at the worst possible quality imaginable. They do not even hide it, during my investigation while reading the city and county minutes there were multiple times the city engineer brought to issue the flood risk and need for good building code and the contractors argued tooth and nail to not have to meet them. I obtained a letter written to the council by one of the said contractors that argued he would pull out of the project if in addition to the millions he would be receiving these infrastructure funds, he could not also establish a tax district or build to a lower standard.
It is crucial to keep in mind that this very community was hit with a government re-directed flood where hundreds of people were displaced, dozens are still living in severely damaged homes, and a dozens lost everything they ever owned because Noem came to their town and said that everything was going to be fine, ignoring the NOAA and every other government agency. These people do not live in a floodplain their homes would not have been damaged despite what some doctored graphs may say.
Furthermore, the biggest lobbyist pushing for these homes would be the Home Builders Association and National Association of Realtors, the antithesis of FEMA. Part of the reason these homes endured so much damage is because nearly all of the town has failing infrastructure. This town of 5000 people lost two bridges, due to collapse in 6 months. There was as 100 foot drop in the road where it collapsed after the flood, a huge gaping hole. The entire reason this happened is because it was profoundly below standard with an “F”rating by the DOT. The roadway the levee used as a floodway was not to appropriate standard creating even more destruction, because it was not up to code before the disaster it could not be repaired with federal emergency money and because the state’s emergency funding was spent on southern optics, it would
not be fixed by that either.
Lawmakers, what I am telling you is that the current Secretary in charge of FEMA, grifted millions of dollars in federal infrastructure funding preventing infrastructure in her state from being properly maintained. She redirected those funds to contractors that were political allies associated with home builder’s and realtor’s lobbies which continuously lobby to develop land in dangerous regions to the lowest standards, when the land allocated for this development was inevitably going to flood, she redirected the floodwaters to a neighborhood not in a floodplain wiping out everything these people ever owned, the damage was particularly catastrophic because the infrastructure used to redirect floodwaters was failing, but the funds that were intended to fix it were used to buy land to build more homes in a floodplain these victims will be paying for with their tax dollars, while also paying mortgages in homes they cannot live in, while also paying for current living arrangements.
North Sioux City South Dakota has some of the worst infrastructure in the country that is desperately failing and putting countless lives at risk but that’s Another document. Another fraudulent claim pertains to the She uses statistics about how much of the workforce is from out of state. The concept hit a rocky road on day one in the Republican-led legislature.
Additional scheme Pattern- Keeping Money Dark
Noem pushed aggressively to have the funds placed in to the South Dakota GOED fund, it’s a fund that governor’s have virtually free reigns to spend as they wish, the legislature questioned, and rightly so, the legality of this and argued that the funds had to be dispersed in to the SDHD. Noem did not want the funds to go through proper legal channel because the federal regulations attached would make the grift next to impossible and housing would actually have to be affordable and be awarded through proper bidding. Another scheme pattern Noem uses is to ensure the most amount of funds are not subject to any regulation or investigation, and subsequently in the event there is an inquiry use security purposes as a reason not to disclose, then litigate , and in the event they are disclosed lie and use a proxy media group to offer additional protection. This has played out in a few ways the most simple is to reject critical federal funds regardless of the violation to citizen’s rights is causes (DeSantis and Abott do the same thing typically with the same funds because they are involved in the same scheme). It may manifest itself as declaring an emergency in order to circumvent government procurement and contracting laws like we saw with Freedom Works and most recently in DHS when she used “Unusual and Compelling Urgency” clause to pay $200 million to Republicans for her Spirit Halloween ads. Finally, when possible, Noem will just continue to move money until it hits an account she has as close to unilateral control as possible.
The scheme was not lost on lawmakers in the state event the Republican led senate and lifelong loyal public servants resisted the workforce housing scheme. Take this as a sign that the smallest pillars are scare. Lorraine Polak resigned from her position as Executive Director of the South Dakota Housing Authority (SDHDA) after two decades with the agency in part due to delays in properly dispersing funds and over scrutiny over loyalty to Noem’s asinine policy proposals. Steve Westra, head of the Governor’s Office of Economic Development, subsequently resigned on May 22, 2023. Arguments continue to ensure among lawmakers because the language is confusing and legality is questioned which is holding off funds for yet another construction season. What we do know is come hell or high water (literally) those empty lots will be protected at all costs.
Another Scheme: Kleptocracy, Turnover, Deliberate Vacancies and Conglomerate Control
Westra and Polak would hardly be the only resignations due to Noem’s haphazard chaotic antics. Never in my life have a seen leadership with such profound and deliberate turnover. This is not only a symptom but the disease itself and if it manifests itself within the Department of Homeland Security this nation’s security will be jeopardized in likes I have not seen in my lifetime. We know within the fabric of Project 2025 is a kleptocracy meant to allow the conglomerate to control the inept people they put in to place. Noem is a case study in the effects of this poor governance. Noem routinely lost personnel and then allowed for deliberate long-term vacancies in order have unilateral control or to destroy departments should did not like- usually ones that actually help people. Noem went through FIVE Chiefs of Staff in four years before allowing the position to be vacant for the duration of her time in office. Why would she need a Chief of Staff when she has Lewandowski?
For small incite to her short regime her is a long but non-exhaustive list of resignations and terminations
• Herb Jones Chief of Staff January 2019- October 2019
• Josh Sheilds October Chief of Staff October 2019-January 2020
• Tony Venhuizen Chief of Staff March 2020- April 2021
• Aaron Scheibe May 2021- November 2021
• Mark Miller November 2021- June 2023
• Maggie Seidel Senior Policy Advisor Departure 2021
• Scott Amundson Director, Appraiser Certification Departure January 2022
• Jason Ravnsborg Impeached after killing someone and getting away with it June 2022
• Mike Leidholt Secretary Department of Corrections on leave July 2021
• Darin Young South Dakota State Penitentiary Warden terminated July 2021
• Jennifer Driesk Deputy Warden terminated July 2021
FEC and Hatch Act Violations
The Hatch Act does not allow for government employees to campaign for candidates while being paid on the job Because of my strong assertion that Freedom Works Here is a campaign for Kristi Noem ( a function of a system is what that system does and it does nothing else) then I would argue that Department of Labor Employees that were on the clock and forced to work at events such as Sturgis Motorcycle Rally were in violation of the Hatch Act.
Additionally, I believe other FEC laws have been broken through a system of campaign account and Political Action Committees. South Dakota became a unique playground for political collusion where lacks campaign finance laws and unregulated funds enable a complex web of transactions that benefit republican candidates nationwide unlike most states South Dakota places no time limits on when governor's campaign funds must be spent allowing former officials such as Dennis Dugaard and Mike Rounds to maintain and utilize these funds long after leaving office gnomes use of this loophole is especially egregious through her network of accounts including her state level campaign account chaired by Steve Kirby and the federal PAC “Noem Victory Fund” led by Kentucky based treasurer Kevin Broghammer. They orchestrated a network of political action committees that funneled money in strategic ways for example, the “Noem Victory Fund” in exactly five transfers, transferred $1,530,549.15 to her state campaign $502,630.02 to Larry Rhoden's campaign and $492,445.58 to the South Dakota strong leadership PAC also chaired by Kirby. The funds from these PACs were not just for campaign activities but to influence state issues like the “No on G” campaign where her allies weaponized misinformation attorney John Hanson using a misleading “Life Defense Fund”. Noem’s administration helped in this scheme by passing new laws that would change the way issues got onto and stayed on the ballot. Under this new policy, a person could retract their name from a petition to get a measure on the ballot at any time. Can you imagine the intimidation that is coming? Hanson’s group obtained the list of citizens who signed petitions to place abortion on the ballot and orchestrated a campaign of fraudulent phone calls pretending to be the Secretary of State's office. Callers falsely claimed the petitions legalized extreme abortion policies such as allowing the execution of an infant after birth coercing citizens to withdraw their signatures this pattern of financial manipulation deceit and coercion is not just unethical it demands a federal investigation that intricate financial network connecting gnomes PAC the deceptive voter suppression tactics and the transfer of campaign funds across state lines raise serious legal questions including wire fraud honest services fraud and conspiracy. In conclusion, the evidence and testimony presented in this report leave no room for doubt—Kristi Noem has engaged in a deeply troubling pattern of corruption, misconduct, and abuse of power that spans her tenure as Governor of South Dakota and extends into her federal role. This is not a series of isolated incidents but a methodical, calculated network of corruption that has allowed Noem and her closest allies to enrich themselves at the expense of taxpayers while circumventing accountability, silencing dissent, and wielding power without consequence.
The failure of the Senate to properly scrutinize Noem’s background, her actions, and the extensive record of litigation against her has led to an unprecedented breach of public trust. It is a failure of the confirmation process itself, which should serve as a safeguard against the appointment of those who have consistently demonstrated unethical behavior, disregard for the law, and a blatant willingness to use public office for personal gain. This failure has not only emboldened Noem but has allowed her corruption to metastasize into the federal government, where she now occupies a role with sweeping authority and access to vast public funds.
But this report is not just a record of past crimes— it is a warning. The patterns of behavior meticulously documented here are not remnants of a corrupt past but the blueprint of an ongoing and evolving network of exploitation. Noem’s weaponization of media contracts, her use of small and disadvantaged business programs as a cover for self-enrichment, and her manipulation of emergency relief funds are not anomalies. They are the mechanisms of a criminal enterprise that has taken root within public institutions and now threatens the integrity of our federal government.
This is not just a matter of holding one individual accountable; it is a matter of preserving the rule of law and restoring faith in our democratic institutions. Lawmakers cannot afford to ignore this evidence. The time for passive observation has passed. It is imperative that a full and independent investigation be
launched, that the Department of Justice initiate a RICO investigation, and that all federal funding connected to Noem’s administration be subjected to rigorous scrutiny.
The American people deserve leaders who serve the public good, not those who exploit their office for personal profit. They deserve a government that upholds justice and transparency, not one that shields its most corrupt actors. I encourage you to take immediate and decisive action. History will not look kindly on those who stood by while corruption flourished unchecked. It is time to act.
Very interesting not to mention disturbing.
I wish someone had listened to you sooner. I'm so proud of you. You never cease to amaze me. Keep us the excellent work. Alicia (Lilith)