WASHINGTON — August closed the 2026 midterm cycle’s summer stretch with a pattern that filings increasingly make hard to miss: the largest and fastest-moving money in American politics is arriving through vehicles that disclose the least, and it is doing so while the agency charged with policing federal campaign finance remains unable to act.
Three developments during the month, each documented in public records, define the picture. A network of politically active nonprofits has routed more than $33.1 million into federal super PACs this cycle without disclosing its donors. A pro-Israel super PAC became the cycle’s single largest independent spender. And a watchdog group asked the Federal Election Commission to investigate an alleged straw-donor scheme in Colorado — a request that, as a practical matter, the Commission currently lacks the votes to act on.
The regulator is still dark
The FEC has operated without a policymaking quorum since April 30, 2025, according to a notice posted by the Commission itself. Audits, civil penalties, rulemakings, binding advisory opinions and the authorization of new investigations each require the affirmative vote of four commissioners. Two seats are filled.
President Trump nominated Ashley Stow and Andrew Woodson to the Commission in February 2026, a step that election-law practitioners noted would restore quorum if the Senate confirms them. Reporting by NOTUS indicates the enforcement docket has continued to accumulate in the interim, with pending matters numbering in the high 190s and some files dating to 2022 and 2023. Because the statute of limitations for FEC enforcement runs five years, the oldest of those matters face expiration on the calendar rather than on the merits.
The Commission has not gone entirely quiet. Its weekly digest for August 10–14 records an advisory opinion request from the Cascade Party of Washington, active litigation in DCCC v. FEC, and a Sixth Circuit remand in the NRSC coordinated-spending case following the Supreme Court’s June 30, 2026 opinion. Disclosure processing, filing calendars and data publication have continued. What has not continued is enforcement.
A dark money network at record volume
On August 11, Citizens for Responsibility and Ethics in Washington published an analysis finding that thirteen nonprofits organized under section 501(c)(4) of the tax code have directed more than $33.1 million to 31 federally registered super PACs this cycle. CREW’s comparison to prior cycles is the more striking number: FEC receipt records the group cites show roughly $14.6 million from network nonprofits in 2024 and about $22 million in the 2022 midterms.
The single largest concentration went to Kentucky’s Republican Senate primary, where CREW’s analysis attributes more than $14.5 million to five network nonprofits. FEC records show Keep America Great PAC, Inc. raised more than $16 million through June 30, 2026, with $10.64 million of that traced to three of the nonprofits. The Texas Senate race drew the second-largest share, with America Works Fund contributing $8.9 million to a super PAC backing Sen. John Cornyn in his unsuccessful primary campaign.
CREW identifies network membership on the basis of financial connections, shared vendors and a shared tax preparer, not formal corporate affiliation. The organizations named have not, so far as public records show, been found by any adjudicative body to have violated federal law; CREW’s characterization is an analytical judgment by an advocacy organization, and the entities involved are entitled to respond. TIJ has not received a response from any of them.
The corporate sectors buying access
The disclosed side of the ledger is setting records of its own. A Public Citizen analysis of FEC data reports that corporations have contributed $517 million to influence the 2026 midterms — a 12 percent increase over the $461 million recorded across the entire 2024 cycle, and nearly triple the $184.1 million logged in 2022.
Four sectors account for $294 million of that, or 57 percent. Cryptocurrency firms lead at $189 million, followed by Big Tech and artificial intelligence at $60 million and online betting at $46 million. The money is concentrated in a small number of sector-specific vehicles: FEC records show Fairshake at roughly $135 million in cycle receipts, Leading the Future at $75.1 million, and Win for America funded entirely by corporate contributions. MAGA Inc. has reported $342 million in cycle receipts, roughly 35 percent of it corporate.
What distinguishes these committees from traditional party-aligned super PACs is that they are organized around a policy interest rather than a party, and their operators say so openly. Public Citizen quotes Leading the Future’s stated purpose as “identifying, maintaining, and growing pro-AI candidates” at both the state and federal level — a mandate that by design cuts across primaries in both parties.
Individual giving has followed a similar arc. Reporting compiled from FEC disclosures indicates the twenty largest individual donors have put roughly $1.2 billion into federal races this cycle, with Marc Andreessen and Ben Horowitz at approximately $115 million to Republican- and corporate-aligned committees and George and Alex Soros at roughly $103 million to Democratic-aligned vehicles. The concentration, not the partisan direction, is the story: a room of twenty people now accounts for a sum comparable to the total disclosed corporate spending of an entire prior cycle.
August’s top outside spender
OpenSecrets reported in late August that the United Democracy Project, the super PAC affiliated with the American Israel Public Affairs Committee, had spent $53.6 million on independent expenditures through August 21, making it the cycle’s largest single outside spender. The committee’s filings are available on FEC.gov. OpenSecrets places pro-Israel independent expenditures at $70.8 million overall, second to the crypto sector’s $77.1 million.
Also in August, a Wyoming entity called Choose Freedom Inc. — with a paper trail that reporting indicates dates only to spring 2026 — reserved approximately $22 million in advertising across roughly two dozen battleground House and Senate races. Under current disclosure rules, groups that form late in a cycle can spend heavily in the closing weeks and report their funders only after votes are cast.
An enforcement complaint with nowhere to go
On August 17, the Campaign Legal Center filed a supplemental complaint with the FEC alleging that an entity called U.S. Accountability Project, Inc. served as a corporate shell to move $470,000 to Mile High Accountability Project, a pop-up super PAC that spent $485,000 supporting a Democratic primary candidate in Colorado’s 1st congressional district. CLC alleges the arrangement concealed the true contributors’ identities in violation of federal law.
These are allegations in a pending complaint. No finding has been made, and the entities named have not been adjudicated to have violated any statute. The practical significance is procedural: a complaint filed with a commission that cannot muster four votes has no near-term path to a reason-to-believe finding, an investigation, or a penalty.
State-level movement
States have continued to legislate where Congress has not. California’s Fair Political Practices Commission approved enforcement actions in the first quarter of 2026 covering campaign reporting, advertising disclosure and misuse of campaign funds, and legislators are weighing a measure that would let the agency fine paid political content creators who fail to disclose sponsorship, with penalties reported at up to $5,000 per violation. In Texas, Houston officials advanced an ethics proposal in late August targeting candidates who file campaign finance reports late or not at all — a category that has reportedly included up to a quarter of local candidates in recent cycles.
What warrants a closer look
Three threads merit sustained reporting. The first is the disregarded-entity structure CREW describes, in which 501(c)(4) organizations report controlling subsidiary LLCs that spend on advocacy under unrelated names — a layer that sits beneath even the limited disclosure nonprofits provide. The second is the pop-up committee timing gap: entities like Choose Freedom Inc. and Mile High Accountability Project exploit a reporting calendar that lets late-forming groups spend first and disclose after. The third is the corporate sector PAC as a durable institution rather than a cycle-specific tactic, and what a committee organized around one industry’s regulatory interest does to primary competition in both parties.
Every figure above traces to a filing, an analysis of filings, or contemporaneous reporting citing filings. Where a claim is an allegation, it is identified as one. Parties named in this report are invited to respond, and TIJ will publish substantive replies.