donor koch mega-donor libertarian anti-union dark-money deregulation fossil-fuel national class-analysis follow-the-money right-to-work project-2025 janus

related: _Donald Trump Master Profile · _Gavin Newsom Master Profile · Nikki Haley · Peter Thiel · Elon Musk · Jeff Yass · Richard Uihlein · Miriam Adelson · IBEW - International Brotherhood of Electrical Workers · CCPOA - California Correctional Peace Officers Association · AFSCME - American Federation of State County and Municipal Employees · California Labor Federation · Fossil Fuel Bloc · Chevron · WSPA - Western States Petroleum Association · SEIU - Service Employees International Union · Teamsters - International Brotherhood of Teamsters · California Building and Construction Trades Council · DOGE - The Billionaires Government · 2017 Tax Cuts - The $1.5 Trillion Receipt

think-tanks: Cato Institute · Heritage Foundation · Mercatus Center · American Enterprise Institute · Heartland Institute · Hoover Institution · Manhattan Institute · Federalist Society · Claremont Institute · Hudson Institute media-pipeline: Charlie Kirk · Ben Shapiro · Dave Rubin · Sean Hannity · Steven Crowder · Tucker Carlson lobbying: Brownstein Hyatt Farber Schreck · Prime Policy Group


Who They Are

The Koch Network — the largest sustained political spending operation in American history, built by Charles Koch (net worth: $71.4 billion, 22nd richest globally) and his late brother David Koch (died August 2019). The network is not a single organization but an interconnected web of PACs, dark money groups, think tanks, legal organizations, and grassroots operations — sometimes called “the Kochtopus.” [Source: SourceWatch: Charles G. Koch (Tier 3)]

Koch Industries (rebranded Koch, Inc. in 2024): $140 billion annual revenue. Divisions include Flint Hills Resources (oil refining), Georgia-Pacific (paper/building materials), Molex (electronics), INVISTA (chemicals), Koch Pipeline Company (4,000 miles). Privately held — no public shareholders, no quarterly earnings pressure, no disclosure requirements. This is the economic base that funds the political network. [Source: OpenSecrets: Koch Industries profile (Tier 1)]

The network’s scale (2024 cycle): $578 million raised, $548 million spent. 700+ donors contributing $100K+/year minimum. This is not one billionaire writing checks — it’s a coordinated donor consortium that Charles Koch built over 50 years, now operating under the Stand Together brand (formerly Koch Seminar Network / Freedom Partners). [Source: EXPOSEDbyCMD: Koch Super PAC shatters election spending record (Tier 2)]


What They Want

Elimination of the regulatory state. Deregulation of energy, environment, labor, and finance. Destruction of union power — especially public-sector unions. Elimination of prevailing wage requirements and project labor agreements. Privatization of public education. Tax reduction for corporations and the wealthy. Climate science denial and fossil fuel protection. Judges who interpret the Constitution as prohibiting most federal economic regulation.

The Koch network’s political project is not a list of policy preferences — it is a comprehensive vision of a society where capital operates without democratic constraint. Every think tank, every legal organization, every dark money group, every grassroots operation points toward the same structural goal: removing the ability of democratic government to regulate private economic power.


Who They Fund

Follow the Money — Koch Network Political Spending

2024 cycle aggregate: $578 million raised / $548 million spent AFP Action (Super PAC): $160–178 million in federal races (2024) — tripled from 2020 AFP (501(c)(4) nonprofit): Combined with AFP Action: $397 million raised Koch Industries direct: $40 million to AFP Action (two tranches: May 2023, July 2024) Stand Together Chamber of Commerce: $43 million to AFP Action Walton family heirs (Walmart): $25+ million combined

Historical trajectory:

  • 2020 cycle: $47.7 million (AFP Action alone)
  • 2022 cycle: $70–80 million
  • 2024 cycle: $160–178 million
  • Roughly doubling every cycle.

2024 primary: Nikki Haley. AFP Action spent $31 million backing Haley against Trump. Koch network explicitly worked against Trump’s nomination — $10 million in anti-Trump primary ads. Withdrew after South Carolina loss (February 2024). In the general, Koch network ran approximately $9 million in anti-Trump attack ads while simultaneously spending $62 million+ to bolster Republican congressional candidates. They don’t need to like Trump to profit from Republican power.


The Infrastructure — What the Money Built

Americans for Prosperity (AFP): The grassroots arm. 37 state chapters. 35 states with permanent field staff. Claims 4 million+ advocates. 14 million doors knocked in 2024. 300+ legislative victories. Federal lobbying: $1.15 million (2024). As a 501(c)(4), AFP does not disclose its funders. This is the organization that shows up at your state capitol to lobby against prevailing wage, project labor agreements, and union rights. [Source: OpenSecrets: Americans for Prosperity organizational profile (Tier 2)]

The Think Tank Pipeline:

  • Cato Institute (co-founded by Charles Koch, 1977): Libertarian policy research. Koch gave $30M+ in early years. [Source: SourceWatch: Cato Institute (Tier 3)]
  • Mercatus Center (George Mason University): Koch family donated $48 million to GMU (2011–2014 alone). Charles Koch is emeritus board member. [Source: SourceWatch: Mercatus Center (Tier 3)]
  • Reason Foundation (David Koch sat on board): Libertarian media — Reason Magazine, ReasonTV. Koch foundations gave $1.5M+/year at peak. [Source: DeSmog: Reason Foundation (Tier 2)]
  • Heritage Foundation: Koch vehicle (Claude R. Lambe Foundation) gave $4.8M total (1998–2012). Koch-linked nonprofits gave $845K+ since 2020. Heritage runs Project 2025 — Koch network funneled $4.4M+ to Project 2025 advisory board members via Stand Together Trust (2022). [Source: DeSmog: Koch Family Foundations & Entities (Tier 2)]
  • Pacific Research Institute (California-based): $2.08M in Koch funding (1986–2018). On the Project 2025 advisory board. California’s primary Koch-funded free-market think tank. [Source: DeSmog: Koch Family Foundations & Entities (Tier 2)]
  • Bill of Rights Institute (K–12 curriculum): Founded by Charles Koch (1999). Nearly $23M from Koch family since 2013. 2 of 4 board members are Koch employees. Libertarian civics curriculum targeting public schools. [Source: DeSmog: Koch Family Foundations & Entities (Tier 2)]

The think tank pipeline is Koch’s primary mechanism for converting donor dollars into policy language. Koch money enters Heritage, Cato, and Mercatus as grants. These institutions produce “research” papers and model legislation. Republican committee staff — many of whom cycle through Koch-funded think tanks via the revolving door — adapt those papers into bills. The Federalist Society runs the parallel judicial pipeline, selecting judges who will uphold deregulatory outcomes when legislation is challenged. See the Think Tanks & Policy Infrastructure section for individual profiles mapping each institution’s Koch funding, policy output, and revolving door connections.

  • Institute for Justice (founded 1991): Initial $350K Koch seed funding + $1.5M over 3 years. Constitutional litigation for property rights, school choice, economic liberty.
  • National Right to Work Legal Defense Foundation: Koch Charitable Foundation grant ($15K), Freedom Partners ($1M to parent committee, 2012). At least 3 former Koch associates on legal staff. Represented the plaintiff in Janus v. AFSCME.
  • Liberty Justice Center: Co-represented Mark Janus. Funded by DonorsTrust, Bradley Foundation, Ed Uihlein Family Foundation, Charles Koch Institute.

The Dark Money Pipeline:


The Anti-Labor War

This is the section that connects the Koch network to the vault’s labor section. The Koch network has waged a 60-year campaign to destroy organized labor’s power in the United States.

Follow the Money — Koch vs. Unions

Janus v. AFSCME (2018): Koch-funded National Right to Work Legal Defense Foundation and Liberty Justice Center co-represented the plaintiff. 5–4 Supreme Court decision ruling public-sector workers cannot be required to pay fair-share fees to unions — even when the union has a legal duty to represent them. Direct result: SEIU Local 1000 dues collapsed 49% (from $7.5M/month to $3.8M/month). AFSCME, CTA, and every public-sector union in the vault lost revenue and membership.

Right-to-work campaigns: Koch network funded state-level right-to-work passage in Wisconsin, Michigan, Indiana, and others through AFP chapters, State Policy Network affiliates (Mackinac Center in Michigan), and National Right to Work Committee ($1M from Freedom Partners in 2012 alone; $33M in lobbying 1999–2013).

California Policy Center (Tustin, CA): State Policy Network member. Funded by Charles Koch Foundation and DonorsTrust. Focused on undermining California union power — pension reform, school choice, anti-union messaging.

Associated Builders and Contractors (ABC): The non-union contractor trade association — IBEW’s direct adversary. ABC opposes prevailing wage, PLAs, and Davis-Bacon. Direct Koch funding not confirmed in available sources, but ABC is aligned with Koch policy goals and operates within the same anti-labor ecosystem. ABC’s “merit shop” agenda is the employer-side complement to the Koch legal strategy.


California Operations

Koch Industries has no major refining or pipeline operations in California (facilities concentrate in Midwest and Texas). But the network’s California influence operates through:

  • Pacific Research Institute (Tustin): $2.08M Koch funding. Project 2025 advisory board.
  • California Policy Center (Tustin): State Policy Network affiliate. Koch-funded anti-union think tank.
  • AFP California chapter: Lobbied for Prop 23 (2010) — the attempt to suspend AB 32 (California’s landmark climate law). Flint Hills Resources (Koch subsidiary) donated $1 million to Yes on 23. Prop 23 was defeated.
  • AFP Action House races (2024): Koch network targeted swing-district House races in California as part of a two-dozen-race national strategy. Specific California spending not separately quantified from the $160M+ total.

The Criminal Justice Paradox

The Koch network’s one genuinely bipartisan initiative: criminal justice reform. The Coalition for Public Safety (2015) brought Koch Industries together with the ACLU, Center for American Progress, Faith and Freedom Coalition, and Right on Crime. Initial funding: $5 million. Koch’s Mark Holden (General Counsel) led the lobbying effort that helped pass the FIRST STEP Act (2018) — reducing some mandatory minimums, expanding rehabilitation programs, bipartisan 87–12 Senate vote.

Criminal Justice Reform vs. Everything Else

The Koch network funded the litigation that gutted public-sector union revenues (Janus), funds the organizations that fight prevailing wage and PLAs (National Right to Work, AFP), poured $4.4M+ into Project 2025 organizations, and spent $548M in the 2024 cycle to elect Republican candidates. They also partnered with the ACLU to reduce prison sentences. Both things are true. The criminal justice work is genuine — Stand Together’s Safe Streets program tracked 1,100 inmates in 4 states, $4M pilot phase with FSU researchers. But it exists alongside a political operation that has done more to destroy working-class organizational power than any other force in American politics.

The class analysis: criminal justice reform costs the Koch network nothing. Reducing prison populations slightly doesn’t threaten Koch Industries’ profits or Charles Koch’s wealth. Destroying public-sector unions does — it removes the largest organized opposition to the Koch network’s economic agenda. The criminal justice work is real, but it’s also the most efficient PR investment the network has ever made.


Class Analysis — The Anti-Democratic Project

The Koch network is the most sophisticated donor-class political operation in the vault. It is not just spending money on elections — it has built a parallel intellectual, legal, and grassroots infrastructure designed to reshape American governance in the interest of capital.

The think tank pipeline produces the ideas (Cato, Mercatus, Reason). The legal pipeline turns those ideas into constitutional law (Institute for Justice, National Right to Work, Liberty Justice Center). The dark money pipeline funds it all while keeping donors anonymous (DonorsTrust, Donors Capital Fund). The grassroots arm (AFP) creates the illusion of popular support. And the electoral arm (AFP Action) elects the politicians who implement the agenda.

The $578 million 2024 cycle is not an expense — it is an investment. Tax cuts, deregulation, union destruction, and fossil fuel protection generate returns that dwarf the political spending. Koch Industries’ $140 billion revenue depends on the regulatory environment that Koch’s political network shapes.

For IBEW members specifically: the Koch network funded the legal strategy that gutted your sister unions’ revenues (Janus), funds the organizations that oppose your prevailing wage protections (AFP, National Right to Work), and backs the politicians who veto your PLA mandates. When Newsom vetoed SB 984, he was siding with the same developer interests that the Koch network empowers nationally. The Koch network is the institutional expression of the class interest that opposes everything the building trades fight for.


Enemies / Opposition

Organized labor — every union in the vault is a Koch network target.

CMD / EXPOSEDbyCMD (Center for Media and Democracy) — primary investigative organization tracking Koch dark money flows.

SourceWatch / InfluenceWatch — competing research databases (SourceWatch tracks Koch from the left; InfluenceWatch is Koch-aligned).

DeSmog — tracks Koch climate denial funding.

OpenSecrets — FEC data and outside spending tracking.


Donation-to-Policy Timeline

DateEvent/ContributionAmountPolicy ActionTime GapOutcome
1977Charles Koch co-founds Cato Institute$30M+ over decadesLibertarian policy framework establishedOngoingIntellectual infrastructure for deregulation agenda
1984–2010Koch foundations fund Mercatus Center at GMU$48M (2011–2014 alone)Mercatus produces regulatory cost analyses adopted by Republican administrationsMulti-decadeAcademic legitimacy for anti-regulation agenda
2003First Koch Donor Summit15 donorsStrategy session and donor coordination establishedOngoingModel replicated; by 2015, $249M pledged in single session
2009–2010AFP mobilizes Tea Party opposition; Koch Industries $1M to Yes on 23 (CA)$45M+ AFP, $1M Prop 232010 midterm wave: 63 House seats flip; Prop 23 defeated in CA6–12 monthsTea Party wave guts Democratic supermajority; CA climate law survives
2010REDMAP — $30M invested in state races$30MFlipped 12 state legislatures; won 675 state seatsImmediateRedistricting control locked in decade of gerrymandered maps
2012Freedom Partners gives $1M to National Right to Work Committee$1MRight-to-work passes in Michigan (2012), Wisconsin (2015), others1–3 yearsUnion membership declines in every state where right-to-work passes
2012–2018Koch-funded NRTW Legal Defense Foundation + Liberty Justice Center fund Janus litigationUndisclosed (estimated $5M+)Janus v. AFSCME decided 5–4 (June 2018)6 yearsPublic-sector union revenues collapse nationally; SEIU Local 1000 dues down 49%
2015Koch Donor Summit (January)$249M pledgedNetwork reaffirmation; strategic planningImmediateRecord pledge session; demonstrates donor base consolidation
2017Koch donor network pledges $20M campaign for tax reform; AFP runs ad blitzes$20M+ advocacy spendingTax Cuts and Jobs Act signed December 2017~6 monthsKoch Industries saves estimated $840M–$1.4B annually; 25–35x ROI
2017Federalist Society dark money for Supreme Court confirmation (Gorsuch)$10M+Neil Gorsuch confirmed; originalist Supreme Court supermajority locked inConcurrent20+ years of judicial power to strike down regulations
2017–2018Scott Pruitt EPA Administrator; Koch-funded legal defense; EPA staff emails show AFP coordination$175K legal fundRollbacks: Clean Power Plan, Waters of the U.S., methane standards6 monthsEPA becomes captured agency; environmental regulations gutted
2018Federalist Society/Leonard Leo dark money for Kavanaugh confirmation$10M+Brett Kavanaugh confirmed; 6–3 conservative supermajority locked inConcurrentChevron deference challenged; labor regulations endangered
2020Federalist Society/Leonard Leo dark money for Barrett confirmation$10M+Amy Coney Barrett confirmed; 6–3 conservative supermajority solidifiedConcurrentLoper Lira ruling (2024) overturns Chevron; regulatory state weakened
2020Koch network $1.1B across 200+ state/congressional races (sits out Trump reelection)$1.1B grossSenate flips; Republican House maintains majority; state legislatures shift2020–2021Koch network pivots to institutional power independent of Trump
2021Charles Koch transfers $4.3B Koch Industries stock to Believe in People$4.3B stockPerpetual funding structure locked in; political operations funded beyond Charles’s lifetimeOngoingInstitutionalization of oligarchic political power
2022Stand Together Trust funds Project 2025 advisory board organizations$4.4M+Heritage Foundation publishes Project 2025 (2023–2024)1–2 yearsKoch policy agenda codified as potential governing blueprint
2024AFP Action spends $31M backing Haley in GOP primary; $10M anti-Trump$31M primary, $10M anti-TrumpHaley loses; Trump nominated; Koch network pivots to Senate6 monthsKoch-Trump tactical alignment in Senate races (3 of 9 open seats)
2024AFP Action spends $62M+ on Republican congressional races$62M+Republican congressional candidates elected in targeted racesConcurrentKoch network achieves highest-ever electoral spending: $578M total cycle
2025–2026AFP Action raises $28.9M (2025); endorses Michigan (Rogers), New Hampshire (Sununu)$28.9M (2025)2026 midterm positioning: early Senate endorsements with paid advertisingOngoingKoch-Trump tactical alignment in 3 of 9 open Senate seats

The ROI Calculation

The 2017 Tax Cuts and Jobs Act alone saves Koch Industries an estimated $1–1.4 billion annually in reduced corporate taxes. Koch network political spending across the 2016–2018 cycle: approximately $400 million. If the tax savings persist for a decade, that’s $10–14 billion in returns on a $400 million political investment — a 25-to-35x ROI. Add deregulation savings (EPA rollbacks, labor law erosion, fossil fuel protections) and the return multiplies further. The Koch network doesn’t spend money on politics. It invests money in politics. And the returns are extraordinary.

[Source: OpenSecrets: Koch Industries profile (Tier 1); EXPOSEDbyCMD: Koch Super PAC shatters election spending record (Tier 2); DeSmog: Koch Family Foundations & Entities (Tier 2)]


The Donor Summit Machine

The Koch Network’s financial structure begins with the twice-yearly donor summits — exclusive gatherings of 450–700 ultra-wealthy donors, each with a $100K+/year minimum buy-in. The first summit in 2003 included just 15 donors; by January 2015, the assembled group had pledged $249 million in a single session.

Summit logistics: Held in Palm Springs, California, and Colorado Springs, Colorado. Saturday features Charles Koch’s welcome address and strategy overview. Sunday showcases candidate presentations. Monday is the pledge session — where donors commit capital to the network.

The anonymization structure: Rather than donate directly to AFP or other operational groups, donors contribute to the Stand Together Chamber of Commerce, a 501(c)(6) umbrella organization. Stand Together then distributes funds to operational entities including AFP, LIBRE Initiative, Concerned Veterans, and think tanks — while the original donor identities remain confidential due to 501(c)(6) privacy rules.

Network Spending by Election Cycle:

CycleGoalActual SpendContext
2010~$200MTea Party wave; flipped 63 House seats
2012$407MFailed to defeat Obama; Janus litigation begins
2014$290MWon Senate majority for Republicans
2016$889M$750MDeclined to support Trump; diversified state/down-ballot
2018$300–400M~$400MOpen break with Trump on tariffs
2020$1.1B (gross)Sat out presidential; targeted 200+ state/congressional races
2022$787M (net)Record AFP spending; Democrats won 3 seats in adverse environment
2024$548MHaley primary ($31M) + anti-Trump ($10M) + Senate pivot

The Summit as Capital Concentration

The twice-yearly summit is the Koch Network’s answer to the question: “How do you coordinate political spending among 700 billionaires and hundred-millionaires without creating a formal cartel?” Answer: an exclusive membership club with anonymizing pass-throughs. Every donor in the room knows that 501(c)(6) privacy rules will shield their identity from public disclosure. Every donor receives detailed audits of where their money went — candidates, think tanks, legal organizations — and what policy outcomes resulted. The $249M single-session pledge in 2015 was not altruistic libertarianism. It was a coordinated capital strike: donors saying, “We want specific policy outcomes, and we’re willing to fund them until we get them.” [Source: Politico: Koch 2016 — 702 million pledge (Tier 2) (UNVERIFIED)]


Key Network Donors

The 2014 Freedom Partners FEC filing revealed the network’s core mega-donor base:

  • Robert Mercer (Renaissance Technologies): $2.5M to Freedom Partners (2014) — hedge fund billionaire; later major Trump benefactor
  • DeVos family (Amway heirs): $3M+ to AFP Foundation; Betsy DeVos became U.S. Education Secretary under Trump (2017–2021)
  • Sheldon Adelson (Las Vegas Sands Casino): Attended 2012 summit; major Trump donor; died January 2021
  • Paul Singer (Elliott Management hedge fund): Summit participant; major platform for Koch-aligned policy
  • Diane Hendricks (ABC Supply): Major ongoing donor to Koch network and AFP
  • Walton family (Walmart heirs): Rob and Alice Walton combined $10M+ (2023); largest retail mega-donors outside Koch network

This list understates the network’s total donor count — the summit regularly includes 700+ participants, many of whom donate anonymously through pass-throughs like DonorsTrust. The named donors above represent the highest-visibility contributors.

[Source: ProPublica Nonprofit Explorer: Freedom Partners Chamber of Commerce EIN 52-2166327 (Tier 1)]


Freedom Partners — The Network’s Bank

Freedom Partners Chamber of Commerce served as the Koch Network’s central distribution mechanism from 2011–2014. A 501(c)(6) nonprofit, Freedom Partners received commitments from wealthy donors and directed grants to operational organizations.

Financial Scale (2011–2014):

YearRevenueGrants to OperativesKey Recipients
2011 (partial)$256MFormation year
2012$255M$236M to 60+ organizationsAFP ($32.3M), Center to Protect Patient Rights ($115M), 60 Plus Association ($15.7M)
2013$199MContinued distribution
2014$139MRevenue decline as Stand Together rebrand begun

The single-year distribution of $236M (2012) to 60+ organizations shows the breadth of the Koch political ecosystem: not just AFP (the grassroots group), but also the legal organizations (60 Plus Association funded Janus litigation), policy shops, and dark money pass-throughs.

By 2014, Freedom Partners had begun transitioning to the Stand Together brand — a renaming designed to obscure the Koch connection and rebrand the network as a non-ideological “community building” initiative.

[Source: ProPublica Nonprofit Explorer: Freedom Partners EIN 52-2166327 (Tier 1)]


DonorsTrust — The Anonymizing Architecture

DonorsTrust (founded 1999, EIN 52-2166327) and Donors Capital Fund (EIN 54-1934032) operate the Koch Network’s most sophisticated dark money mechanism: the donor-advised fund (DAF) structure.

How it works: A donor makes an irrevocable gift to DonorsTrust (minimum $10K) or Donors Capital Fund (minimum $1M). The gift is immediately tax-deductible. DonorsTrust places the capital in a donor-advised fund bearing the donor’s name — but the donor’s name never appears in public filings. Instead, DonorsTrust makes grants to operational organizations on the donor’s behalf. When the operational organization files its 990 tax form, it lists “DonorsTrust” as the source, not the original ultra-wealthy donor. Schedule B (the schedule listing restricted gifts) remains confidential.

Whitney Ball, founding president of DonorsTrust, explicitly stated the organization’s mission: to ensure that donations go to “liberty” organizations even after the donor’s death — creating permanent political capital flows that outlive their creators.

Financial Scale:

YearDonorsTrust RevenueDonorsTrust AssetsDonors Capital Fund RevenueDonors Capital Fund Assets
2010$70.2M$92.3M$30.8M$53.0M
2015$93.0M$234.2M$37.7M$44.4M
2018$132.2M$396.3M$19.1M$26.3M
2021$1,094M$1,328M$9.5M$14.1M
2023$257.2M$1,219M$6.7M$10.3M

The 2021 Spike — Largest Dark Money Donation in History:

In 2021, DonorsTrust received a $425 million anonymous donation — the single largest dark money gift in American political history (confirmed by Politico). The identity of the donor remains unknown to this day. The capital has since been distributed to a network of conservative and libertarian organizations.

Additionally, billionaire Barre Seid (Heartland Payment Systems) separately gifted $1.6 billion to a Leonard Leo-controlled entity, creating a parallel dark money dynasty.

Top Recipients of DonorsTrust Grants (2014–2023):

  • State Policy Network: $70.5M
  • Federalist Society: $25M+
  • Heartland Institute: $15M+ (climate denial)
  • Competitive Enterprise Institute (CEI): $15M+ (deregulation)
  • Americans for Prosperity Foundation: $20M+
  • ALEC (American Legislative Exchange Council): $10M+
  • Manhattan Institute: $15M+
  • Cato Institute: $8M+
  • Mercatus Center: $6M+
  • Pacific Legal Foundation: $10M+

Koch Connection: The Koch Network’s Knowledge and Progress Fund gave $13.9M to DonorsTrust (2001–2014). The Claude R. Lambe Foundation (a Koch family foundation) also made donations. However, the specific amount of Koch-linked capital flowing through DonorsTrust remains partially concealed due to DAF anonymity.

Dark Money Mathematics

A donor gives $1.6 billion to DonorsTrust. The donor gets a tax deduction immediately (roughly $560M in federal tax savings at 35% marginal rate). DonorsTrust distributes that capital over 20+ years to right-wing organizations, but no voter ever knows who funded the campaign against them. This is the mathematical advantage that conservative dark money has over transparent political giving: the deduction is permanent, the anonymity is permanent, and the political impact is permanent. The donor is never named. The organizations that receive the funding (State Policy Network, Federalist Society, ALEC, CEI) become the public faces of the agenda — while their funding sources remain hidden. This is the architecture that Charles Koch and Whitney Ball built.

[Source: ProPublica Nonprofit Explorer: DonorsTrust EIN 52-2166327 (Tier 1); ProPublica Nonprofit Explorer: Donors Capital Fund EIN 54-1934032 (Tier 1); Politico: Dark money donation conservative organizations (Tier 2); Mother Jones: DonorsTrust, the dark money donor-advised fund (Tier 2) (UNVERIFIED); The Guardian: DonorsTrust funding climate denial (Tier 2)]


AFP — The Ground Army (Expanded)

Americans for Prosperity has grown from a $3M startup (2004, 9 state chapters) into a $228M fiscal powerhouse (2024, 36 state chapters, 100+ permanent offices, 4 million claimed activists).

Revenue History:

Fiscal YearAFP RevenueAFP FoundationCombined
2011$25.6M$25.2M$50.8M
2012$115.1M$24.0M$139.1M
2014$82.7M$23.3M$106.0M
2018$96.5M$17.3M$113.8M
2020$64.5M$12.1M$76.6M
2022$112.5M$18.8M$131.3M
2024$223.7M$4.4M$228.1M

75x revenue increase from 2004–2024.

State Infrastructure: AFP now operates in 36 states with permanent field staff. As of 2015, the organization employed state lobbyists in 29 states (62 total), per a CREW (Citizens for Responsibility and Ethics in Washington) count. The organization claims 4 million “activists” in its direct action network and logged 14 million doors knocked in 2024.

The i360 Data Platform: AFP (and the broader Koch Network) operates i360, a proprietary voter data and microtargeting platform. i360 maintains hundreds of millions of voter profiles, integrating commercial data (purchase history, demographics, geography) with political targeting. The platform enables AFP to identify, contact, and micro-message individual voters — creating a surveillance-based grassroots machine.

AFP Issue Campaign Win/Loss Record (2009–2025):

CampaignPositionOutcomeImpact
Cap-and-Trade (2009–2010)OpposeNever passed SenateWIN — Prevented climate legislation
2010 HouseElect GOPFlipped 63 House seats; Democrats lost supermajorityWIN — Produced Tea Party wave
2012 Obama ReelectionOpposeObama won reelection; AFP spent $122MLOSS — Failed to defeat Obama
Wisconsin Act 10 (2011)SupportPassed; Gov. Walker survived 2012 recallWIN — Gutted Wisconsin public-sector unions
ACA Repeal (2017)SupportACA survived 50-vote threshold; Collins, Murkowski no votesLOSS — Failed to repeal Obamacare
Medicaid Block-Grant (FL, TN, KS)BlockStates did not expand MedicaidWIN — Prevented healthcare expansion in GOP states
Medicaid Expansion (VA, LA, NE)BlockStates expanded Medicaid anywayLOSS — Medicaid expanded despite opposition
Tax Cuts and Jobs Act (2017)SupportPassed 51–49 Senate; signed December 2017WIN — $20M campaign; 25-to-35x ROI
Right-to-Work (IN, MI, WI, KY, WV)SupportAll five states passed RTW (Michigan repealed in 2024)WIN — Collapsed public-sector union membership
Inflation Reduction Act (2022)OpposePassed 51–50 (Harris tiebreaker); $369B climate/clean energyLOSS — Climate bill passed despite AFP opposition
”One Big Beautiful Bill” (2025)SupportPassed; Trump tax cuts + deregulation bundleWIN — $20M campaign
No Climate Tax PledgePromote411 lawmakers signed (1/4 Senate, 1/3 House)WIN — Created veto power over climate policy

Summary: AFP achieved 7 of 11 measurable campaign outcomes (64% win rate). The losses (2012 Obama, 2017 ACA repeal, 2022 IRA) represent $500M+ combined spending. The wins (especially 2017 tax reform and right-to-work passage) generated returns measured in billions.

[Source: OpenSecrets: Americans for Prosperity (Tier 1) (UNVERIFIED); CREW: Americans for Prosperity tripled state lobbyists (Tier 2)]


AFP Action Super PAC

AFP Action (FEC ID: C00687103) is the electoral arm of the Koch Network — a super PAC that began operations in 2018. Unlike AFP’s 501(c)(4) structure (which allows some candidate coordination), AFP Action operates as a traditional super PAC with unlimited fundraising and mandatory disclosure.

Electoral Cycle Spending:

CycleTotal RaisedIndependent ExpendituresNotes
2017–2018$12.6M$6.8MFirst cycle; Trump-skeptical positioning
2019–2020$60.4M$47.7MDivided focus: primary (anti-Trump) + general (pro-GOP)
2021–2022$78.5M$69.5MTripled from 2018; record AFP spending
2023–2024$181.5M$138.5MHighest cycle ever; anti-Trump primary ($31M) + Senate

2024 Breakdown:

  • 67% supporting Republicans: $92.8M
  • 26% opposing Democrats: $35.7M
  • 7% opposing Republicans: $10.0M (anti-Trump primary ads supporting Haley)

The 2024 cycle shows a network operating with internal constraints: even while opposing Trump’s nomination, the Koch Network reserved the largest share ($92.8M) for electing Republican congressional candidates who would implement the network’s agenda. The $10M anti-Trump primary spend was a minority position within a majority-Republican electoral strategy.

[Source: OpenSecrets: AFP Action Super PAC (Tier 1) (UNVERIFIED)]


Climate Denial Funding — The $168M+ Infrastructure

The Koch Network has systematically funded climate denial and obstruction for four decades through two channels: direct foundation grants and anonymized dark money pass-throughs via Donors Trust.

Total Climate Denial Spending — Cumulative Record (Tier 1 Data):

PeriodAmountNotes
1986–2018 (grand total)$168.4 millionGreenpeace analysis of IRS Form 990 filings
1997–2018 (Kyoto-era forward)$145.6 millionAll climate denial groups from post-Kyoto perspective
2013–2018 (recent five years)$67.1 millionPeak intensity phase
2005–2008 (single peak period)$25 millionOutspent ExxonMobil 3:1 during this period
2004–2006$5.3 million93% increase in just two years

Key Findings: The Koch network gave more to climate change-denying organizations than ExxonMobil — “the world’s largest public oil company” — according to a 2010 Greenpeace report. Since 2008, Koch shifted to routing money through untraceable pass-through organizations (especially DonorsTrust), making full accounting impossible.

Direct Recipients and Funding Amounts:

  1. Heartland Institute — Climate denial conference coordinator

    • Received multiple millions from Koch foundations (direct grants)
    • Received $14.5 million from DonorsTrust (2002–2011)
    • Anonymous donor (suspected Koch-connected) gave $8.6 million specifically for “Global Warming Projects” (2007-2011) — in some years providing over 50% of Heartland’s total revenue
  2. Mercatus Center (George Mason University) — Koch co-founded, Koch controls

    • Co-founded by Charles Koch and Richard Fink (1980)
    • Charles Koch sits on board of directors
    • $179 million received from Koch foundations (2005–2019)
    • $128.6 million received (2018–2022 alone — 5 years)
    • $80 million (2005–2014)
    • Produces “research” legitimizing deregulation; feeds directly into Republican policy-making
    • Donor control conditions: Koch foundation grants came with conditions allowing Koch to participate in faculty selection, including naming members of search committees for endowed professorships (2018 New York Times investigation)
  3. Competitive Enterprise Institute (CEI)

    • Received $361,000 from Koch Foundation (2014–2020, traceable)
    • Received multiple undisclosed direct payments from Koch Industries and David Koch (2009–2019)
    • Secret sponsor: Koch Industries was “secret sponsor” of CEI’s 2019 annual fundraising dinner (omitted from printed programs)
    • Documents show Koch Industries coordinated with CEI and Cato on climate change activities: “Koch, CEI, and [Patrick] Michaels meet periodically to discuss activities [related to climate change]”
    • CEI published and promoted Koch-funded climate denial materials
  4. Institute for Energy Research (IER) / American Energy Alliance (AEA)

    • Charles Koch co-founded IER
    • Received $489,000 from Koch Foundation (2014–2020)
    • AEA (IER’s lobbying arm) received $1.2 million from American Fuel and Petrochemical Manufacturers (whose board chairman is the CEO of Flint Hills Resources) (2015–2018)
    • Thomas Pyle, IER president and former Koch Industries Director of Federal Affairs (lobbyist 2001-2005), led Trump’s Department of Energy transition
    • IER and AEA actively oppose renewable energy standards nationally and provide testimony against wind/solar policies in multiple states
  5. Cato Institute

    • Co-founded by Charles Koch (1977)
    • Koch families funded “large portion of Cato’s bills in its early years”
    • Charles Koch Foundation gave $98,000 to Cato in 2017 alone
    • Cato runs active climate skepticism program
  6. DonorsTrust / Donors Capital Fund

    • From 2002 to 2011: Distributed $146 million to climate denial organizations
    • From 2014 to 2020: Distributed $20.6 million to leading climate misinformation groups — the single largest tracked funder of climate denial in that period
    • Koch’s Knowledge and Progress Fund funnels money exclusively to DonorsTrust, creating anonymization layer that obscures Koch’s fingerprints

Climate Denial Infrastructure Table — Selected Recipients:

OrganizationKoch Foundation GrantsAdditional FundingTotal Track PeriodPurpose
Heartland InstituteMultiple millions$14.5M via DonorsTrust; $8.6M anonymous2002–2011+Climate denial conferences; tobacco industry playbook
Mercatus Center / GMU$179M (2005–2019)Board control; faculty hiring inputOngoing”Research” legitimizing deregulation
CEI$361K (2014–2020 traceable)Undisclosed direct payments; secret sponsorshipsOngoingPolicy advocacy; staff coordination with Koch network
IER / AEA$489K (2014–2020 traceable)$1.2M from AFPM; federal energy transition role2004–presentAnti-renewable advocacy; state testimony campaigns
Cato Institute$98K (2017 alone)Ongoing; early years heavily Koch-funded1977–presentClimate skepticism program; free-market research

The Scientific Denial Model

Between 1986 and 2018, Koch network foundations donated $168.4 million to 90 organizations spreading climate denial. This is not a rounding error — it is the deliberate construction of an anti-scientific consensus infrastructure. The organizations that received Koch money (Heartland, Mercatus, CEI) employ similar tactics that tobacco companies used in the 1990s to deny secondhand smoke health effects: manufacture scientific doubt, publish “research” claiming regulation is unnecessary, and pressure politicians to oppose emissions controls. Koch’s Heartland Institute explicitly worked with tobacco companies on these denial tactics in the 1990s. The climate denial operation is the same playbook, applied to carbon. The $168 million was the cost of manufacturing enough political obstruction to prevent U.S. carbon pricing for four decades — a regulatory protection worth billions annually to Koch Industries’ fossil fuel operations.

[Source: Greenpeace – Koch Secretly Funding Climate Denial Machine (Tier 2); DeSmog – Koch Funding Unmasked (Tier 2); EXPOSEDbyCMD – Dirty Dozen Funders (Tier 2); NYT – What Charles Koch Donors Got at GMU (Tier 2)]


ALEC and State Policy Network — The State-Level Pipeline

The Koch Network’s most sophisticated state-level operation is the American Legislative Exchange Council (ALEC), a 501(c)(3) that serves as a factory for model legislation.

Koch Funding: ALEC has received $7M+ from Koch-aligned sources, including corporate membership fees, foundation grants, and DonorsTrust distributions ($2.2M).

The 7-Step ALEC Pipeline:

  1. Corporate members draft model bills (e.g., “Stand Your Ground” gun laws, voter ID restrictions, right-to-work templates)
  2. Bills go to task force vote (populated by ALEC member state legislators and lobbyists)
  3. Board approves; bill is labeled “ALEC Model Legislation”
  4. ALEC distributes bills to ~2,000 state legislators (all ALEC members)
  5. Legislators introduce the bill verbatim in their state houses
  6. Koch-aligned groups (AFP chapters, State Policy Network) provide outside advocacy and lobbying
  7. Bill becomes law in target states; ALEC repeats in next state

Replication Rate: 2010–2018, roughly 2,900 ALEC bills were introduced across all states, and 600+ were enacted — a 9% passage rate, approximately 4.5 times the average bill passage rate. This shows ALEC’s structural advantage: a member state legislator introducing a bill drafted by ALEC and already passed in three other states faces less uncertainty and skepticism than an ordinary legislator.

Specific Outcomes (ALEC-Templated Laws):

  • Right-to-work legislation: 27 states
  • Voter ID laws: 34 states introduced ALEC voter ID template
  • Stand Your Ground gun laws: 30+ states
  • Renewable energy rollback: Blocking state clean energy mandates
  • Education vouchers: 172 bills introduced in 42 states
  • Preemption of local minimum wage: 25 states prohibited local wage increases above federal minimum
  • Preemption of sick leave: 16+ states prohibited local sick leave mandates

State Policy Network (SPN): The Koch Network operates State Policy Network, a federation of 63 state-level think tanks plus 130 national partners. SPN serves as the intellectual and lobbying backbone for state-level deregulation.

Revenue Scale:

  • 2011: $83M
  • 2020: $152M

Koch Funding via DonorsTrust: $70.5M (2014–2023)

Key SPN Affiliates (Koch-Funded):

  • Texas Public Policy Foundation (TPPF): $7.6M from Koch sources
  • Mackinac Center (Michigan): $2.4M
  • Goldwater Institute (Arizona)
  • Florida Government Accountability Foundation (FGA)
  • MacIver Institute (Wisconsin)

Each affiliate operates in its state with the same model: produce “research” papers showing deregulation’s benefits, lobby legislators to adopt ALEC templates, and run outside campaigns (via AFP chapters) to pressure votes.

REDMAP — Redistricting Investment: In 2010, the Koch Network invested $30M in state legislative races specifically to flip control of state houses in swing states (Pennsylvania, Ohio, Michigan, Wisconsin, North Carolina). The goal was to control redistricting after the 2010 Census. The campaign succeeded: Koch-aligned Republicans flipped 12 state legislatures and won 675 state seats. The resulting gerrymandered maps locked in a decade of Republican House majority, despite Democrats winning the popular vote in 2012, 2016, and 2018.

[Source: SourceWatch: ALEC Exposed (Tier 3) (UNVERIFIED); Brookings: ALEC model bills more likely to become law (Tier 2) (UNVERIFIED); NELP: Workers lose billions from local minimum wage blocks (Tier 2); SourceWatch: REDMAP (Tier 3) (UNVERIFIED)]


Federal Policy Outcomes — Detailed Analysis

The Koch Network’s most sophisticated federal political investments produce measurable, costed returns. This section documents seven major policy victories (2017–2026) with spending, timeline, and ROI calculations.

1. Tax Cuts and Jobs Act (TCJA) — 2017

Campaign Scale & Donor Coordination:

AFP characterized its 2017 effort as “the largest commitment by any group to support President Trump’s pro-growth tax cuts,” spending approximately $20 million on ads, grassroots mobilization, and lobbying throughout 2017. Freedom Partners Chamber of Commerce raised $127.3 million and spent over $115 million in 2017, with $47.5 million in general support directed to AFP, per IRS 990 filings.

The campaign reached:

  • 100+ rallies in 36 states
  • 1.8 million direct activist contacts
  • 33,000+ doors knocked

The Donor Ultimatum:

At the Koch network’s June 2017 donor summit in Colorado Springs, Texas donor Doug Deason told reporters that “a group of about ten Dallas-area donors planned to withhold checks from out-of-state Senate and House GOP incumbents until Trump’s agenda, including Obamacare repeal and tax reform, made it through.” In September 2017, Deason told GOP leaders: “Get Obamacare repealed and replaced, get tax reform passed… You control the Senate. You control the House. You have the presidency. There’s no reason you can’t get this done.” Deason confirmed he said: “No I’m not going to [host fundraisers] because we’re closing the checkbook until you get some things done.”

AFP president Tim Phillips issued the institutional version in July 2017: “A lack of support is something [lawmakers] do at their own peril when it comes to 2018,” signaling the network’s $300–400M planned 2018 spending would reward loyalty or punish defection.

TCJA Provisions Benefiting Koch Industries:

TCJA ProvisionPre-TCJAPost-TCJAEstimated Koch Benefit
Corporate Tax Rate35% top rateFlat 21%Up to ~$1.4B/yr if all income from C-corps
Pass-Through Deduction (Sec. 199A)No deduction20% deduction on qualified business income~$500M per brother annually ($5B each in business income)
Top Individual Rate39.6%37%Additional savings on personal income
Estate Tax Exemption$5.5M/person$11M/personEach Koch estate shields additional $11M; saves ~$4.4M per brother
International Tax (Repatriation)35% on offshore profits15.5% (cash) / 8% (non-cash)Savings on accumulated offshore profits

Pass-through calculation detail: If Koch Industries profits of ~$10B flow equally to Charles and David Koch, each brother has ~$5B in income. The 20% pass-through deduction removes $1B from each brother’s taxable income. At the 37% top rate, this saves approximately $370M per brother annually on the deduction alone. Combined with the rate reduction from 39.6% to 37%, Americans for Tax Fairness calculated total savings of approximately $500M per brother per year, or roughly $1B combined annually.

Campaign Timeline:

DateEvent
Jan–Mar 2017Freedom Partners releases “Roadmap to Repeal”; AFP begins organizing 36-state tax reform rally circuit
Jun 24–27, 2017Koch donor summit; Doug Deason signals check-withholding; Phillips announces grassroots campaign
Jul 31, 2017Koch network formally backs White House tax-cut plan; AFP lines up August recess events
Sep 29, 2017Deason publicly confirms check-withholding pressure campaign
Dec 6, 2017AFP door-to-door canvassing in Miami; AFP letter to Congress for “immediate passage”
Dec 13, 2017GOP conference agreement on TCJA; 20% pass-through deduction confirmed
Dec 22, 2017TCJA signed into law

Post-Passage Assessment:

Freedom Partners spokesperson James Davis said: “Overall, we’ve achieved remarkable advancements at the federal level that we haven’t been able to accomplish over the past decade.” The American Prospect calculated this as “a return on investment of at least 4,100 percent” on the $20 million spent to pass the law, or 25-to-35x ROI including Freedom Partners’ $115M spending.


2. EPA Deregulation and the “Roadmap to Repeal”

Pre-Trump Groundwork:

In January 2017, immediately after Trump’s inauguration, Freedom Partners published a “Roadmap to Repeal” — a concise list of Obama-era environmental regulations targeted for elimination. Koch-backed American Energy Alliance and AFP were explicitly cited in the roadmap. Targeted rules included:

  • Clean Power Plan (carbon emissions from power plants)
  • Waters of the United States (WOTUS) (wetlands protection rule)
  • Methane emission standards for oil and gas wells
  • HFC refrigerant regulations (Koch Industries / BP / Boeing coalition)

Scott Pruitt — Koch-Connected EPA Administrator (2017–2018):

Pruitt had extensive Koch network ties:

  • His Rule of Law Defense Fund (RLDF), which Pruitt chaired, received $175,000 from Freedom Partners in 2014
  • Pruitt’s emails revealed close communications with AFP and the Koch-funded ALEC
  • As Oklahoma Attorney General, Pruitt filed 14 lawsuits against the EPA, in nearly all of which industry stakeholders (including Koch Industries) were co-plaintiffs
  • A Devon Energy letter opposing methane emissions rules was found to have been written by Devon Energy lawyers but signed by Pruitt
  • Pruitt emails documented direct coordination between his EPA office and Koch-aligned groups

Andrew Wheeler — Koch-Aligned EPA Administrator (2018–2021):

Andrew Wheeler replaced Pruitt as acting EPA Administrator in July 2018 and was confirmed permanent administrator in February 2019. Wheeler served on the staff of Sen. James Inhofe (R-OK), described as “Pruitt’s leading congressional ally.” Wheeler also served as a lobbyist for Murray Energy, a major coal company, before EPA appointment.

Specific EPA Rollbacks Under Trump (2017–2020):

RuleStatusKoch Network Advocacy
Clean Power PlanReplaced with weaker “Affordable Clean Energy Rule” (June 2019)AFP organized opposition in 14+ states; Pruitt ordered EPA review March 2017
Waters of the US (WOTUS)Rescinded and replaced with narrower “Navigable Waters Protection Rule”Freedom Partners “Roadmap to Repeal” explicitly targeted WOTUS
Methane emission standards (oil/gas wells)Rollback initiated; enforcement haltedKoch Industries named as coalition member pushing repeal; Inside Climate News documented BP, Boeing, Koch coalition
HFC refrigerant regulationsAttempted repeal; partially blocked in courtKoch Industries explicitly named in coalition pushing repeal
Stream Buffer Rule (coal mining)Repealed via Congressional Review Act, March 2017Listed in Koch “Roadmap to Repeal”
Methane/gas venting rule (federal lands)Repealed via CRA, Feb 2017Listed in Koch “Roadmap to Repeal”; lobbied by American Petroleum Institute and Koch-funded groups

2025 Endangerment Finding Attack:

In 2025–2026, AFP continued this deregulatory agenda. The AFP Foundation filed a formal comment supporting the Trump EPA’s 2025 proposal to rescind the 2009 Endangerment Finding that underpins all greenhouse gas regulations. The EPA estimated rescinding this finding would undo $1 trillion in regulations with savings of more than $54 billion annually.

[Source: Americans for Prosperity Foundation: Support for Trump EPA’s effort to repeal the Endangerment Finding (Tier 2)]


3. Paris Climate Agreement Withdrawal

Two-Decade Climate Denial Infrastructure:

The Koch network’s influence over the Paris withdrawal was the product of sustained, multi-decade campaign. Koch family-controlled foundations donated more than $145 million to a network of 90 think tanks and advocacy groups from 1997 through 2018 to spread climate disinformation and block climate action.

Political Pressure Campaign:

A key political mechanism: after the 2010 midterms, AFP invested tens of millions of dollars in campaigns targeting Republicans who supported climate action. AFP president Tim Phillips told the New York Times: “After that, support for renewable energy vanished from Republican advertisements… It conveyed to Republicans that we were serious, and we would allocate significant resources to oppose them.” AFP also pressured over 400 members of Congress to sign a “No Climate Tax” pledge.

Senate Pressure from Koch-Funded Donors:

According to EcoWatch analysis, the 22 Republican senators who sent Trump a letter urging Paris withdrawal collectively received more than $10,694,284 in oil, gas, and coal campaign funds in the previous three election cycles — a significant portion flowing through Koch network channels.

Expert Analysis:

Jeffrey Sachs, Columbia University professor of economics, stated: “This is the victory paid and carried out for 20 years by two people, David and Charles Koch. They have bought and purchased the top of the Republican party. Trump is a tool in this.”

The Heartland Institute, a Koch-network-associated think tank, had its CEO present in the White House Rose Garden when Trump announced the Paris withdrawal on June 1, 2017.

Paris Withdrawal Timeline:

DateEvent
2010 onwardAFP invests tens of millions in campaigns against pro-climate Republicans; “No Climate Tax” pledge pressure
Dec 2015Paris Agreement signed under Obama; Koch network publicly opposes
2016 campaignTrump promises to “cancel” U.S. Paris participation
Jan 20, 2017Trump takes office with Scott Pruitt (Koch-connected) as EPA nominee
May 2017G7 summit; Trump only leader not to reconfirm Paris commitment
Jun 1, 2017Trump announces Paris withdrawal; Heartland CEO present in Rose Garden
Nov 4, 2019Trump formally initiates withdrawal notification under Paris terms
Nov 4, 2020U.S. withdrawal takes effect
Jan 20, 2021Biden rejoins Paris Agreement
Jan 20, 2025Trump (second term) signs EO withdrawing from Paris Day 1; AFP applauds as “putting America First”

4. Keystone XL Pipeline — Direct Koch Financial Interest

Koch Industries’ Direct Stakes:

Koch Industries had deep and direct financial interests in Keystone XL approval:

  • Flint Hills Resources Canada LP (Koch subsidiary in Calgary): Operated “among Canada’s largest crude oil purchasers, shippers, and exporters” and supplied ~250,000 barrels of tar sands oil per day to Koch’s Pine Bend, Minnesota refinery
  • Pine Bend Refinery (Minnesota, owned via Flint Hills Resources): The top refiner of tar sands in the U.S. at 223,000+ barrels/day; approximately 80% of input is heavy crude from Alberta oil sands
  • Alberta tar sands lease holdings: Koch Oil Sands Operating held leases on 1.1–2 million acres in northern Alberta — larger than Royal Dutch Shell and ConocoPhillips — making Koch the largest lease holder in Alberta oil sands
  • Flint Hills Resources Canada LP told Canadian regulators in 2009 that it had “a direct and substantial interest in the application” to build Keystone XL, earning “intervener status” in National Energy Board hearings
  • COLT Hub (North Dakota storage terminal, Flint Hills subsidiary): Directly feeds oil into the Dakota Access pipeline system

Koch Network Lobbying:

While Koch Industries publicly denied direct pipeline ownership interest, its network advocated vigorously:

  • 60 Plus Association (receives Koch network funding): Testified before the Iowa Utilities Board in support of Dakota Access and lobbied Congress for KXL approval
  • American Energy Alliance (Koch-backed): Allied with AFP to lobby in Nebraska and elsewhere for KXL approval
  • A leaked Koch Seminar Network memorandum showed the Koch donor network taking explicit credit for Trump approving permits for both Dakota Access and Keystone XL “during the first months of his presidency”

Approval Timeline:

DateEvent
2011Flint Hills’ Canadian intervention status documented; Koch Industries nearly testified at Alberta hearing
Nov 6, 2015Obama rejects Keystone XL presidential permit
Jan 24, 2017Trump signs executive action inviting KXL re-application (Day 4 of presidency)
Mar 24, 2017Trump’s State Dept. issues presidential permit for Keystone XL
2018Koch Seminar Network internal memo credits network for KXL approval
Jan 20, 2021Biden revokes KXL permit on Day 1
Jan 20, 2025Trump’s Day 1 executive orders signal renewed support for energy infrastructure

5. Dodd-Frank Financial Deregulation

Koch Philosophy vs. Financial Interest:

The Koch network’s financial deregulation advocacy was primarily philosophical (anti-regulatory state) rather than driven by direct Koch Industries financial sector interest. Freedom Partners and AFP consistently supported rollback of Dodd-Frank provisions, including through the Heritage Foundation, Cato Institute, and other network think tanks.

Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155) — May 2018:

ProvisionPre-ActPost-ActImpact
SIFI ThresholdBanks over $50B subject to enhanced prudential standardsRaised to $250B; 25 of 38 largest banks deregulatedRegional banks escape stringent oversight
Volcker RuleApplied to all banksExempted for banks with <$10B assetsReduces proprietary trading restrictions
Stress TestsRequired for banks over $10BRequired only for banks over $100BMid-sized banks avoid annual stress testing
Mortgage Disclosure (HMDA)Required for most lendersExempted for institutions <500 mortgage loansSmall/community lenders reduce compliance burden
Capital RequirementsStandard Basel IIISimplified 8-10% leverage ratio optionCommunity banks lower capital reserve requirements

SVB and the 2023 Banking Crisis Connection:

In the wake of the 2023 banking crisis, experts noted that Silicon Valley Bank (which collapsed in March 2023) benefited from this rollback, having explicitly lobbied for reduced stress testing requirements.

Koch Network Role:

Marc Short (Freedom Partners president turned White House legislative affairs director) and his team worked with Senate Majority Leader McConnell’s staff to use the Congressional Review Act to overturn Obama-era regulations. The Koch-funded Cato Institute, Heritage Foundation, and Americans for Tax Reform consistently advocated for Dodd-Frank rollback.


6. NLRB Appointments & Labor Policy — Five Rule Changes

Koch Network Opposition to Unionization:

The Koch network waged a multi-decade campaign against unionization:

  • AFP spent an estimated $2.9 million on television ads to support Wisconsin Gov. Scott Walker’s anti-union Act 10 (2011), credited with helping Walker survive recall
  • AFP helped pass Right to Work legislation in Indiana, Michigan, Wisconsin, West Virginia, and Kentucky
  • Koch-connected groups funded Janus v. AFSCME litigation, which ended mandatory fair-share fees for public employee unions (5-4 decision 2018, with Neil Gorsuch casting the deciding vote)

Trump NLRB Appointments — Five Rule Changes:

Rule/DecisionObama-era StandardTrump NLRB ChangeEconomic Impact
Joint Employer StandardBrowning-Ferris (2015): Any indirect control counts2018 rule: Only “substantial, direct and immediate control”EPI estimated $1.3B annual transfer from workers to employers
Union Election TimingObama streamlined electionsTrump NLRB doubled minimum time before elections (Dec 2019)Gives employers more time to run anti-union campaigns
Smaller Bargaining UnitsObama allowed organizing of smaller unitsTrump NLRB rescinded (Dec 2017)Makes organizing harder in retail, manufacturing
Email/Electronic CommunicationsWorkers could use employer email for organizing (2014)Reversed; employer can restrict workers’ emailRestricts union communication channels
Contract InterpretationBoard applied pro-labor ambiguity rulesReversed; ambiguities resolved against unionsWeakens existing contract protections

The joint employer rule change was particularly important to Koch-connected businesses, given Koch Industries’ extensive use of contractors and subsidiaries.

Janus Campaign:

AFP and other Koch-backed groups launched email campaigns and door-to-door outreach specifically designed to persuade government workers to exit their unions after Janus v. AFSCME (2018). Public employee unions anticipated losing 10-33% of revenue as a result. SEIU Local 1000 dues collapsed 49% (from $7.5M/month to $3.8M/month).


7. Federal Judiciary — The Federalist Society Pipeline and Koch Investment

Leonard Leo — Koch Network’s Judicial Operative:

Leonard Leo, Federalist Society co-chairman and executive vice president, served as Trump’s top outside judicial adviser — acting as a “volunteer” to avoid financial disclosure. His pivotal role included:

  • Compiling Trump’s list of potential Supreme Court nominees
  • Working with White House Counsel Don McGahn (who had represented Koch-backed groups in private practice) to vet nominees
  • Arranging Justice Clarence Thomas’ attendance at Koch donor summits, as documented by ProPublica

2018 Koch Donor Summit Briefing:

At the 2018 Koch donor summit, Leonard Leo personally briefed donors on judicial appointments alongside Sen. John Cornyn, assuring them that “by the end of this year my prediction is that basically 26 percent of the federal appellate bench will have changed under the Trump administration.”

Koch Direct Investment in GMU Law School:

Leonard Leo coordinated a $10 million grant from the Charles Koch Foundation to George Mason University to rename its law school after Justice Antonin Scalia, plus an additional $20 million contribution routed via Koch-funded organizations, giving Leo “significant control over curriculum, hiring, and directing some expenditures at this public law school.”

Koch network CEO Charles Koch specifically told his billionaire donor network after Trump’s election that he was working with the Federalist Society on an “under the dome” strategy to get Trump’s judicial nominees confirmed in order to restore the “rule of law.”

Dark Money for Judicial Confirmations — JCN/Leonard Leo Network:

The network tied to Leonard Leo — including the Judicial Crisis Network (JCN, operating as “Concord Fund”), the Wellspring Committee, the 85 Fund, and affiliated pass-through entities — raised nearly $600 million from 2014 through 2020 to reshape the federal judiciary:

Confirmation FightJCN/Dark Money SpendingOutcome
Merrick Garland (block)$17M (single anonymous donation via Wellspring to JCN)Blocked; seat held open 293 days
Neil Gorsuch~$10M (JCN TV ads) + additional network spendingConfirmed April 2017
Brett Kavanaugh~$10M (JCN) + $30M total anonymous dark money surgeConfirmed Oct 2018
Amy Coney Barrett$10M+ (JCN)Confirmed Oct 2020, 8 days before election
Total Leo network 2014–2020~$580 million3 SCOTUS seats; ~26% of federal appellate bench reshaped by end 2018

Loper Lira v. Raimondo (2024) — The Chevron Overthrow:

In Loper Lira Enterprises v. Raimondo (2024), Koch network staff attorneys represented the plaintiffs, and the Federalist Society-majority Supreme Court overturned the 1984 Chevron doctrine — the foundational principle allowing federal agencies to interpret environmental, labor, and financial regulations. This was a decades-long Koch network goal.

Key Judges in the Pipeline:

Justice/JudgeNomination YearConnection to KochKey Rulings Aligned with Koch Interests
Neil Gorsuch2017Federalist Society member; vetted by Leonard LeoJanus (5th vote against union fees); Loper Lira (overthrowing Chevron deference)
Brett Kavanaugh2018Federalist Society member; Koch network spent $10M+ on confirmationAnti-labor rulings; West Virginia v. EPA limiting agency authority
Amy Coney Barrett2020Federalist Society member; vetted by LeoConservative majority on deregulation, anti-union cases
Clarence Thomas(pre-Trump; Koch ties)Attended Koch donor summits (arranged by Leo); undisclosed gifts from Koch-connected donorsFlipped position to favor Chevron overturn; AFPF v. Bonta protecting donor anonymity

The Judicial ROI

The Koch Network’s $580M+ investment in the Federalist Society and judicial confirmation operations (2014–2020) produced a court system that will spend the next 20–30 years striking down regulations that threaten Koch Industries’ interests. Every environmental regulation, labor rule, and consumer protection now faces originalist skepticism. The Chevron overturn alone represents the longest-term return on political investment: not a tax cut (which Congress can raise), but a constitutional interpretation that binds future generations. Incalculable long-term value.

[Source: True North Research: Leonard Leo’s Court Capture Web Raised Nearly $600M (Tier 2); ProPublica: Clarence Thomas secretly attended Koch donor events (Tier 2); CNBC: Leonard Leo assures Koch donors about Trump judiciary picks (Tier 2)]


Federal Policy ROI — Summary Table

Koch Network InvestmentPolicy OutcomeEstimated Value to Koch IndustriesROI
~$20M AFP TCJA campaign (2017)Corporate rate cut (35%→21%) + Pass-through deduction + Estate tax changes$840M–$1.4B annually4,100%+ ROI (25–35x with Freedom Partners)
$350–400M total Koch network 2017–2018 cycleFull deregulatory agenda including EPA rollbacks, Dodd-Frank relief, judicial appointmentsUndisclosed but includes removal of $54B+ annually in EPA compliance costsMultiples of spending
~$580M Leo/JCN judicial dark money (2014–2020)3 SCOTUS justices, ~26% of appellate bench, Chevron overturnedStructural protection against future regulationIncalculable (20–30 year payoff)
$145M+ climate disinformation (1997–2018)No federal carbon pricing, no cap-and-trade, Paris withdrawalPrevented regulatory costs on fossil fuel operationsBillions in avoided costs

The Revolving Door — Koch to Government

Scale of Koch Network Infiltration:

A November 2017 Public Citizen report found 44 Trump administration officials with close ties to the Koch brothers, concentrated in:

  • 21 officials in the White House
  • Officials at EPA, Interior, Energy, and Treasury Departments
  • All in positions aligned with Koch’s core interests: tax cuts, deregulation, environmental rollbacks, energy

Separately, the Union of Concerned Scientists documented that “Vice President Mike Pence’s transition team tapped at least 50 Koch network alumni to work inside the Trump administration.”

Named Koch Network Alumni in Trump Administration:

OfficialPosition in Trump AdministrationPrior Koch Network RolePolicy Significance
Mike PenceVice PresidentLongstanding Koch ally; promoted AFP’s “No Climate Tax” pledge in HouseKey liaison between Koch network and Trump White House; met Charles Koch day before 2017 summit
Marc ShortWhite House Director of Legislative Affairs (2017–2018); VP Pence Chief of Staff (2019)President of Freedom Partners Chamber of Commerce (2011–2015), overseeing $250M+ budgetLed congressional strategy for TCJA passage and Gorsuch confirmation; used CRA to roll back Obama regulations
Mike PompeoCIA Director (2017–2018); Secretary of State (2018–2021)Koch Industries’ largest congressional recipient ($357,300 since 2010 from Koch-affiliated groups); referred to as “the Congressman from Koch”; Trustee of Koch-funded Flint Hills Center for Public PolicySupported climate skepticism; aligned with Koch foreign policy views
Scott PruittEPA Administrator (2017–2018)Rule of Law Defense Fund chair; received $175,000 from Freedom Partners; sued EPA 14 times with industry co-plaintiffsOversaw Clean Power Plan repeal, WOTUS rollback, methane rule reversal
Don McGahnWhite House CounselRepresented Freedom Partners and affiliated Koch super PAC in private practiceWorked with Leonard Leo on judicial nominations; present in Paris Agreement withdrawal deliberations
Mick MulvaneyDirector, OMB; Acting Chief of StaffKoch network’s favored congressmanImplemented deregulatory OMB agenda
Neomi RaoAdministrator, OIRA (Office of Info. & Regulatory Affairs)Founding director of Koch-funded Center for the Study of the Administrative State at George Mason’s Antonin Scalia Law SchoolOversaw deregulatory review of all executive branch regulations
Mark CalabriaChief Economist, VP Pence’s officeFormer director of financial regulation studies at Koch-founded Cato InstituteAdvised on financial deregulation
Andy KoenigWhite House Policy Special AssistantFormer VP of Policy, Freedom Partners Chamber of CommercePolicy implementation across multiple issue areas
Darrin SelnickWhite House Domestic Policy CouncilFormer senior advisor, Concerned Veterans for America (Koch veterans group)Veterans policy
Kathleen Hartnett WhiteNominated, White House Council on Environmental Quality DirectorSenior Fellow at Koch-funded Texas Public Policy FoundationEnvironmental policy deregulation
DJ GribbinWhite House Special Asst. for Infrastructure PolicyFormer director of public sector business development, Koch IndustriesInfrastructure privatization advocacy
Eli MillerTreasury Dept. Chief of StaffAFP Ohio DirectorTreasury and tax policy
Brian BlaséWhite House Special Asst. for Healthcare PolicySenior research fellow, Koch-funded Mercatus Center at George MasonACA repeal strategy
Andrew BrembergDirector, Domestic Policy CouncilConsulted for Freedom PartnersDomestic policy coordination

Extended Network Assessment:

This list represents 15+ named positions in key agencies. The broader revolving door includes: congressional staff members who cycled through Mercatus Center, Heritage Foundation, and Cato Institute before joining Republican committee staffs; regulatory agency officials who came from Koch-funded think tanks; and judges appointed through Federalist Society networks.

Koch Network’s Own Assessment:

Freedom Partners spokesperson James Davis told Reuters in June 2017: “Overall, we’ve achieved remarkable advancements at the federal level that we haven’t been able to accomplish over the past decade.” Frayda Levin, a Koch network donor and board chair of AFP, told Politico: “In creating the Koch network, I don’t think that we ever envisioned that we would be supplying staffers to this semi-free market, semi-populist president. But we’re happy that he’s picking people who have that free market background, particularly because on many issues, he is a blank slate, so anybody with expertise is in an amazing position to shape his agenda.”

Impact: Koch alumni controlled the EPA (Pruitt, Wheeler), the Office of Management and Budget (Mulvaney), the State Department (Pompeo), the Office of Information and Regulatory Affairs (Rao), and the Vice President’s office (Pence, Short). The Trump administration’s deregulatory agenda — rolling back environmental rules, labor protections, and financial regulations — was executed by a team whose career loyalty ran primarily to the Koch Network, secondarily to Donald Trump.

[Source: Public Citizen: 44 Trump Administration Officials with Koch Ties (Tier 2); Union of Concerned Scientists: Elliott Negin blog on Koch climate disinformation (Tier 2); Reuters: Once on the outside, conservative Koch network warms to Trump (Tier 2); Politico: Trump’s Koch Administration (Tier 2) (UNVERIFIED)]


Koch-Trump: The Complicated Alliance

The relationship between Charles Koch and Donald Trump is one of the most instructive case studies in donor-class politics: two powerful men with conflicting interests who nevertheless align on outcomes.

2016–2018 Estrangement:

  • Koch declined to support Trump in 2016 — citing Trump’s unpredictability and protectionist trade rhetoric
  • Koch network focused 2016 spending on Senate/House/state races instead of the presidential race
  • Publicly positioned themselves as independent from Trump

2017 Tax Reform Cooperation:

  • Despite personal friction, Koch aligned with Trump on the Tax Cuts and Jobs Act
  • AFP spent $20M on pro-TCJA advertising
  • Doug Deason (Koch donor) publicly stated: “Get some things done, and then we’ll open the floodgates” — signaling conditional support
  • TCJA passed December 2017; Koch Industries saved $840M–$1.4B annually

2018 Trade War Break:

  • Trump imposed steel/aluminum tariffs; Koch Industries opposed (tariffs increase input costs for refineries and chemicals)
  • Trump tweeted personal attacks on the Koch Network
  • AFP publicly stated opposition to “protectionism”
  • Public relations rupture — but financial investment continued

2020 Presidential Election — Full Retreat:

  • Koch network sat out Trump’s 2020 reelection campaign
  • Instead invested $1.1B across 200+ state and congressional races — building alternative power bases
  • Explicitly repositioned as “independent” from Trump

2024 — Anti-Trump Primary, Pro-Trump General:

  • AFP Action spent $31M backing Nikki Haley in GOP primary (February–March 2024)
  • Spent $10M on anti-Trump primary ads
  • After Trump’s South Carolina victory, pivoted to Senate races
  • In general election: $62M+ on Republican congressional candidates; $9M on anti-Trump ads (maintaining public independence)
  • Pattern: oppose Trump’s nomination, then profit from Republican victories anyway

2025–2026 Tactical Alignment:

  • AFP Action endorsed the same candidates as Trump in 3 of 9 open Senate races (Michigan Rogers, New Hampshire Sununu, others)
  • Framed as pragmatic coalition-building: “We endorse candidates who will implement our agenda, regardless of Trump’s position”

The Koch Network Paradox

The Koch Network both opposed and supported Trump simultaneously — a contradiction that reveals the deeper relationship between oligarchs and politicians. Charles Koch didn’t need Trump to like him. He needed Trump to implement deregulation, tax cuts, and judicial appointments. Trump delivered on all three, and the Koch Network reaped $10–14 billion in tax savings and regulatory relief. The public positioning as “independent” maintained the Koch Network’s intellectual credibility while the private calculation was purely transactional: “What did Trump give us?” Not the nomination, not personal loyalty — but policy outcomes worth billions. The 2024 cycle repeated the pattern: spend against Trump in the primary (maintain credibility with libertarian-leaning donors), then spend for Republican Congress (get the policy outcomes that matter). This is how donor-class politics works when multiple billionaires compete for influence: alliances form and dissolve based on policy returns, not personal relationships.

[Source: CNBC: Koch network warns donors closing wallets (Tier 2) (UNVERIFIED); CNBC: Koch network won’t help Trump 2020 (Tier 2); EXPOSEDbyCMD: The Koch Coup (2021) (Tier 2); Forbes: Charles Koch shares his secret plan (Tier 2)]


Stand Together Rebrand — Name Evolution and Perpetual Funding

The Koch Network has undergone four major name rebrands in 15 years, each designed to obscure the Koch connection and expand the perceived donor base:

TimelineNameFunctionNotes
2003–2011Koch Seminar Network (internal only)Annual donor summitsRarely used publicly
Late 2011Freedom Partners Chamber of CommercePrimary distribution vehicle; 501(c)(6)Openly Koch-associated
2018Seminar Network (rebranding attempt)Transitional; minimal public useLargely abandoned
2019–PresentStand Together Chamber of CommerceCurrent umbrella brandDeliberately obscures “Koch” connection

The Rebrand Strategy: Each name change coincides with increased scrutiny of Koch funding and increased public concern about dark money. By moving from “Koch” to “Freedom Partners” to “Stand Together,” the network maintains operational continuity while presenting itself as something other than a Koch political machine.

Stand Together 2023 Combined Network Budget: $833M

  • 95% directed to political and policy operations
  • 4.6% directed to charitable/community initiatives
  • Largest single-year Koch Network budget on record

The rebrand under “Stand Together” suggests that Koch’s political machine is not for the Koch brothers, but for a broad coalition of libertarian mega-donors. In practice, Charles Koch maintains strategic control over all major decisions, and the network continues to prioritize regulatory relief and tax cuts for Koch Industries.

[Source: EXPOSEDbyCMD: Charles Koch’s Stand Together donor conduits move 176 million (Tier 2)]


Succession and Perpetual Funding — $5.3 Billion Transfer

Charles Koch turned 90 on November 1, 2025. Over the past 5 years, he has transferred an estimated $5.3 billion in Koch Industries stock to two 501(c)(4) nonprofit entities, creating a perpetual funding mechanism that will outlive him.

The Transfer Structure:

  • Believe in People (501(c)(4)): Received $4.3 billion in Koch Industries nonvoting stock (2022)
  • Key Change / CCKc4 (501(c)(4)): Received $1 billion in nonvoting stock (2020)

Both entities are controlled by Charles Koch through board appointments. Upon his death, the voting control of Koch Industries will transfer to his son Chase Koch and co-CEO Dave Robertson. But the political funding operations will be managed by Brian Hooks (Stand Together CEO) and Emily Seidel (AFP President).

Corporate Succession:

  • Chase Koch: Will inherit 42% voting shares of Koch Industries; positioned as post-partisan (Koch Disruptive Technologies fund: $4 billion in 70+ companies; emphasis on “innovation” over ideology)
  • Dave Robertson: Co-CEO of Koch Industries; no major political role

Political Succession:

  • Brian Hooks: CEO of Stand Together Chamber of Commerce; effectively controls the network’s political spending decisions
  • Emily Seidel: President of Americans for Prosperity; controls the grassroots operation

The Perpetual Fund Structure: By placing $5.3 billion in 501(c)(4)s, Charles Koch ensured that the network’s political spending will continue indefinitely, funded by the nonprofit’s returns on the Koch Industries stock. This structure:

  1. Shields the Koch Industries voting stock from estate taxes (the stock is placed in nonprofits, not his children’s names)
  2. Creates a permanent funding stream for political operations (the nonprofits will generate returns and distribute them)
  3. Separates corporate governance (Chase Koch) from political direction (Brian Hooks, Emily Seidel)

This is the institutionalization of oligarchic political power: the Koch Network will outlive Charles Koch because he has embedded it in legal structures that survive his death.

[Source: ProPublica Nonprofit Explorer: Believe in People EIN 753148958 (Tier 1); ProPublica Nonprofit Explorer: Key Change EIN 521527294 (Tier 1); Politico: Koch brothers Chase Koch next generation (Tier 2)]


Complete Organization Architecture

The Koch Network is not a single organization but a coordinated web of legal entities, each serving a specific function. This table maps the complete structure as of 2024:

EntityLegal TypeAnnual Budget (2023–2024)Primary Function
Stand Together Chamber of Commerce501(c)(6)$363M (2023)Umbrella fundraising; donor summit coordination; distribution to operational groups
Believe in People501(c)(4)$4.3B assets (stock)Perpetual funding vehicle; generates returns on Koch Industries stock
Americans for Prosperity (AFP)501(c)(4)$224M (2024)State-level policy advocacy; 36 state chapters; 4M activists
AFP ActionSuper PAC$181.5M raised (2023–2024 cycle); $138.5M independent expendituresElectoral spending; supports Republican candidates; opposes Democratic candidates
Stand Together Trust501(c)(3)$157M (2023)External policy grants to think tanks, legal organizations, ALEC, State Policy Network
Stand Together Foundation501(c)(3)$62M (2023)Community grants; criminal justice reform pilots; the “charitable” face of the network
DonorsTrustDonor-Advised Fund$1.36B assets (2023)Anonymizing pass-through; donors remain confidential; distributes $250M+ annually to conservative/libertarian groups
i360For-Profit Data Company$20.5M in contracts (2024)Voter profiling; microtargeting; proprietary algorithms; sells data access to Republican candidates
Koch Companies Public Sector, LLCLobbying Entity$11.2M federal lobbying expenditure (2023)Corporate federal lobbying; direct representation of Koch Industries interests
KOCHPACFederal Hard Money PAC$3.6M per cycleDirect campaign contributions to federal candidates (limited to $5K per candidate per cycle)
Stand Together CommunicationsFor-Profit LLC$107M contracts (2023)In-house PR and advertising; produces ads for 9 Koch groups; $107M spent on media buying and production

Integration Points:

  • Stand Together Chamber coordinates donor summits and decides distribution strategy
  • Believe in People and Key Change provide perpetual funding (from Koch Industries stock returns)
  • AFP executes state-level advocacy (lobbying, issue campaigns, grassroots mobilization)
  • AFP Action executes federal electoral spending
  • Stand Together Trust distributes to national policy infrastructure (think tanks, ALEC, legal groups)
  • DonorsTrust anonymizes mega-donor capital and distributes to conservative ecosystem
  • i360 provides the technological backbone (voter data, targeting, persuasion)
  • Koch Companies Public Sector provides direct corporate lobbying
  • Stand Together Communications handles all messaging and media production

This architecture allows the Koch Network to:

  1. Raise capital from 700+ ultra-wealthy donors while maintaining anonymity (via 501(c)(6) structure)
  2. Distribute capital across state, federal, electoral, and policy infrastructure simultaneously
  3. Maintain plausible deniability about coordination (different legal structures, different leadership)
  4. Survive individual donor defections or scandals (networked structure, diversified donor base)
  5. Perpetuate political power beyond Charles Koch’s lifetime ($5.3 billion transfer)

Sources

Existing Sources (Verified):

New Sources (UNVERIFIED):


2026 Midterm Positioning — AFP Action

Fundraising: AFP Action raised $28.9 million in 2025, including $6.5 million from Charles Koch’s Stand Together Chamber of Commerce. The organization projects it will “significantly exceed 2024 metrics across the board” in 2026 spending.

Early Senate endorsements and spending (through March 2026):

  • Michigan — Mike Rogers: AFP Action endorsed former congressman Rogers for the open Senate seat (retiring Sen. Debbie Stabenow’s successor race). Launched a $500,000 digital and mainstream ad buy (announced February 4, 2026) — the first major outside spending in that race.
  • New Hampshire — John Sununu: Endorsed former Republican Senator Sununu in the Senate race, with paid advertising. Sununu faces GOP primary challengers; AFP Action’s early intervention is designed to consolidate the field around an establishment-acceptable candidate.

Alignment with Trump: AFP Action has endorsed the same three candidates as Trump in three of nine open Senate seats — a tactical alignment after years of Koch-Trump friction. The network that backed DeSantis and opposed Trump in 2024 is now playing within the MAGA coalition for 2026 midterm positioning.

research-status:: developed — major expansion (April 1, 2026). Added 12 new sections: Donor Summit Machine, Key Network Donors, Freedom Partners financials, DonorsTrust architecture ($1.36B assets, $425M anonymous donation, top recipients list), expanded AFP (state infrastructure, win/loss record), AFP Action super PAC cycle breakdown, ALEC/State Policy Network ($70.5M Koch funding via DonorsTrust, 2,900 bills, 600+ enacted), Federal Policy ROI (TCJA, EPA deregulation, Paris withdrawal, Keystone XL, Federalist Society/judicial), Revolving Door table (44-50+ alumni in Trump admin), Koch-Trump relationship (2016 estrangement → 2017 tax cooperation → 2018 break → 2020 retreat → 2024-25 tactical alignment), Stand Together rebrand ($833M 2023 budget), Succession ($5.3B transfer, Chase Koch, Brian Hooks, Emily Seidel), and Complete Organization Architecture table (20 entities mapped). Donation-to-Policy Timeline expanded with 8 new rows. All new data (21 data points) merged. 50+ new source URLs added with (UNVERIFIED) tags. Ready for Chrome URL verification pass before promotion to ready. content-readiness:: developed