The dark money conglomerate that routed nearly $1.5 billion in anonymous contributions through the 2024 election cycle did not shut down in November. It simply changed its name — twice.
Arabella Advisors, the for-profit consultancy that built and managed what watchdogs have called the largest dark money network in American politics, formally ceased operations on November 17, 2025, according to Virginia State Corporation Commission records showing the LLC filed “Articles of Amendment” to change its corporate name to Vital Impact, LLC. One day later, a new public benefit corporation called Sunflower Services announced it had acquired Arabella’s fiscal sponsorship business — the organizational scaffolding that housed hundreds of activist projects under the umbrella of four IRS-approved nonprofits.
The reorganization arrived as the network absorbed a string of setbacks: a $450 million withdrawal by the Gates Foundation, a congressional oversight inquiry, a federal executive memorandum instructing agencies to examine politically active nonprofits, and years of complaints filed with the Internal Revenue Service and the District of Columbia attorney general. But an examination of the new entities, their leadership, and the network’s freshly filed 2024 Form 990 disclosures indicates that the money, the staff, and the political operation remain substantially intact.
A $1.5 Billion Year, Quietly Booked
Tax filings posted in November 2025 show that the four principal nonprofits historically managed by Arabella Advisors — the New Venture Fund, the Sixteen Thirty Fund, the Windward Fund, and the Hopewell Fund — collectively raised approximately $1.5 billion in 2024, an election-cycle high for the network.
The Sixteen Thirty Fund’s 2024 Form 990, posted to ProPublica’s Nonprofit Explorer on November 11, 2025, reports total revenue of $282,241,759 against total expenses of $310,782,035, leaving the 501(c)(4) operating at a $28.5 million deficit on net assets of $88.4 million. The filing lists Amy Kurtz as president, with reported compensation of $251,500, and discloses $236.5 million in grants distributed across 318 awards — a grant-making pace that exceeds the annual disbursements of all but a handful of private foundations nationwide.
The New Venture Fund, the network’s 501(c)(3) flagship, reported $662 million in 2024 revenue, according to published summaries of its Form 990. The Windward Fund reported roughly $308 million and the Hopewell Fund reported approximately $208 million. Arabella’s own for-profit consulting arm historically collected management fees from each of these entities; Capital Research Center previously reported that the four funds paid Arabella $76 million in management fees between 2007 and 2017.
- Sixteen Thirty Fund (501(c)(4)): $282.2 million in 2024 revenue; $236.5 million in grants disbursed
- New Venture Fund (501(c)(3)): approximately $662 million in 2024 revenue
- Windward Fund (501(c)(3)): approximately $308 million
- Hopewell Fund (501(c)(3)): approximately $208 million
- Network total: approximately $1.5 billion in 2024 receipts
Reporting compiled by CampaignNow traces specific 2024 outlays to high-profile ballot initiatives and political infrastructure: $23.5 million toward Florida’s Amendment 4 abortion measure (with $14 million confirmed from the Sixteen Thirty Fund), $4.5 million toward Missouri’s Amendment 3, roughly $3 million into Montana’s CI-128, and $1.25 million toward Arizona’s Proposition 139. The Sixteen Thirty Fund also directed $27.85 million of the $40.5 million raised by America Votes, $16 million to the Institute for Responsive Government, and a reported $6 million to an Ohio redistricting effort.
The Corporate Shuffle
The restructuring announced in November 2025 divides Arabella’s former business into two successors.
Sunflower Services, a Delaware public benefit corporation, announced on November 17, 2025 that it had purchased Arabella’s fiscal sponsorship operation. The press release identifies the New Venture Fund as the “lead investor,” with the Windward Fund and the Hopewell Fund listed as co-founding owners. Sunflower’s inaugural chief executive is Allan Williams, previously senior vice president for partner solutions at Arabella Advisors. Lee Bodner, the longtime president of the New Venture Fund, is named as a founding board member.
The remaining human-resources, payroll, and accounting services continue to operate under Arabella’s original corporate shell, now renamed Vital Impact, LLC. Himesh Bhise, who had served as Arabella’s chief executive, is listed as Vital Impact’s CEO. Virginia corporate records list the filing as entity number S1572793.
Notably absent from both the Sunflower Services launch announcement and the Vital Impact transition is the Sixteen Thirty Fund — the network’s most politically active entity and the engine of the bulk of its election-year lobbying and grantmaking. Neither press release identifies the Sixteen Thirty Fund as a client or owner of either successor organization, and the fund has declined public comment on whether it will continue to rely on Sunflower’s fiscal sponsorship infrastructure.
“Why do you rebrand? To make yourself less toxic,” Scott Walter, president of the Capital Research Center, told the Washington Free Beacon. Caitlin Sutherland, executive director of Americans for Public Trust, which filed a 2023 IRS complaint against the network, said the new structure was “a thinly veiled attempt to continue operating in the shadows.”
Why the Rebrand Now
Filings and public statements point to three proximate pressures on the network.
The first is the June 2025 decision by the Bill & Melinda Gates Foundation to end its grantmaking to Arabella-managed entities. The foundation had disbursed or pledged approximately $450 million to the network’s funds since 2008, making it one of the largest institutional donors to Arabella’s orbit. The decision was communicated internally on June 24, 2025 and first reported publicly in late August, according to Philanthropy News Digest. The Gates Foundation’s CEO, Mark Suzman, framed the move in an internal memo as a preference for “programmatic partners — organizations that are deeply embedded in the communities we serve and closely aligned with our mission.”
The second is a November 2025 inquiry opened by the U.S. House Committee on Oversight and Accountability regarding the Sixteen Thirty Fund’s grantmaking and political activity, one in a series of letters the committee has sent to politically active nonprofits since the start of the current Congress.
The third is a September 2025 presidential memorandum directing federal agencies to examine the activities of tax-exempt organizations alleged to be involved in political violence or the coordination of unlawful activity. While the memorandum did not name Arabella or any of its managed funds, the language effectively widened the aperture for review by the Internal Revenue Service, the Department of the Treasury, and the Department of Justice.
The District of Columbia attorney general had previously opened an investigation into the network in September 2023 following a complaint by Americans for Public Trust. That inquiry was closed in 2024 without a finding of legal violations, according to the attorney general’s office.
The Transparency Gap That Survived
The structural features that made Arabella’s model controversial are unchanged by the rebrand.
Under current Internal Revenue Service rules, a 501(c)(4) social welfare organization such as the Sixteen Thirty Fund is not required to disclose the identities of its donors on its public Form 990 filings. The fund’s 2024 return lists contributions only in aggregate, itemizing neither individual nor institutional sources. The same is true of the network’s 501(c)(3) entities. Further, projects housed under a fiscal sponsorship arrangement are not themselves required to file separate Form 990 returns, because the sponsoring nonprofit absorbs their financial activity into its consolidated filing. This is the mechanism that, according to InfluenceWatch, has allowed the network to incubate more than 340 separately branded projects and “pop-up” advocacy campaigns without triggering their own disclosure obligations.
Transferring the fiscal sponsorship business from a for-profit consulting firm to a public benefit corporation does not alter those tax rules. Sunflower Services, like its predecessor operation, will sit atop the New Venture, Windward, and Hopewell Funds, which in turn host the individual projects. The 501(c)(4) political activity of the Sixteen Thirty Fund — the portion of the network most frequently cited in lobbying and election-adjacent expenditures — remains organized under the same taxpayer identification number (EIN 26-4486735), with the same headquarters at 1201 Connecticut Avenue NW in Washington, and, as of the most recent filing, with the same president.
Filings indicate that the interlocking directorates that linked Arabella, the four nonprofits, and the projects they hosted have been reassembled rather than dismantled. Lee Bodner remains president of the New Venture Fund and sits on the board of Sunflower Services. Allan Williams moves from Arabella to run Sunflower. Himesh Bhise moves from running Arabella to running Vital Impact. Eric Kessler, the former Clinton administration official who founded Arabella Advisors in 2005, has not publicly announced any change in his role within the network’s orbit.
What to Watch
Several questions will determine whether the November restructuring represents a meaningful change or a rebranding exercise.
The first is the Sixteen Thirty Fund’s fiscal sponsorship arrangements going forward. If the fund continues to house its pass-through grantmaking under Sunflower Services, the political arm of the network will remain structurally tied to the same infrastructure, merely under new ownership. If it relocates, the fund will need to disclose the replacement arrangement in its 2025 Form 990, which will not be publicly available until late 2026.
The second is the trajectory of Gates Foundation alumni — dozens of Arabella-sponsored projects received Gates grants over the past decade — and whether other institutional donors follow the foundation’s lead. A cascade of institutional withdrawals would narrow the network’s revenue base even if its legal structure persists.
The third is the outcome of the House Oversight Committee inquiry and any parallel review at the IRS or the Treasury Department. None of these processes has produced a public finding, and the Sixteen Thirty Fund has not been accused of violating federal tax law. Records suggest, however, that the network’s leadership anticipated tighter regulatory scrutiny well before the November announcement: the Sunflower Services transaction was reportedly negotiated throughout the summer of 2025, in parallel with the Gates withdrawal and the escalating complaints filed by outside watchdogs.
For now, the $1.5 billion machine operates under different letterhead. The Form 990s filed a year from now will show whether anything else has changed.