A new Delaware nonprofit recognized by the IRS only seven months ago has already become one of the largest single funders of a Democratic-aligned hybrid political committee underwriting key 2026 Senate races — including the Nebraska contest where independent Dan Osborn is challenging Republican Sen. Pete Ricketts. Public records show the new entity’s lone listed officer previously ran the fiscal-sponsorship arm of Arabella Advisors, the consulting firm whose dark-money network is now operating under a new name.
The pipeline raises an uncomfortable question for Democratic leaders who have spent two election cycles excoriating outside political spending: when Arabella Advisors rebranded last November under pressure from federal investigators and departing donors, did its top operatives simply spin up a fresh set of opaque entities to keep the money flowing into the midterms?
According to filings reviewed by The Investigative Journal, Contours Inc., a 501(c)(4) social welfare organization registered in Delaware and recognized by the IRS in October 2025, has already routed at least $3.85 million into political committees ahead of the November election. It is publicly led by a single officer — Sarah Stremlau, a longtime Arabella executive — has filed only a minimal IRS e-Postcard, and operates from a one-page website containing a single sentence about voter education. Under the rules governing 501(c)(4)s, it will never be required to disclose its donors.
The $3 Million Pass-Through
The reporting that surfaced Contours’ role was first broken on April 30 by the investigative outlet Sludge, which traced the entity’s outbound payments through Federal Election Commission records. The numbers are striking for an organization with a public footprint of roughly 90 words.
FEC records cited in that reporting show:
- At least $2.9 million from Contours to Government That Works PAC, a hybrid political action committee registered in August 2025.
- At least $800,000 to Independent Candidates Action, a PAC supporting independent and unaffiliated candidates.
- At least $150,000 to the Working Class Heroes Fund, the hybrid PAC founded by Osborn after his 2024 loss to Sen. Deb Fischer.
Government That Works PAC has, in turn, raised roughly $7.6 million for the cycle — most of it from nonprofits that do not disclose their funders — and has spent $5.5 million on independent expenditures and direct contributions across competitive contests, with about $2 million still on hand. Contours is the second-largest funder of that committee. The largest is the Sixteen Thirty Fund, which according to Sludge transferred $4 million to Government That Works in January 2026.
The Sixteen Thirty Fund is the principal 501(c)(4) historically administered by Arabella Advisors. Records compiled by Americans for Public Trust and summarized in independent press accounts indicate the fund raised roughly $282 million and spent approximately $311 million during 2024. It is one of the largest single conduits of undisclosed political money in the country.
Who Is Sarah Stremlau?
The Sludge investigation identifies Stremlau as the only individual named in Contours’ IRS application. Her professional history is documented in Arabella’s own materials and in subsequent reporting: she previously led fiscal-sponsorship operations at Arabella Advisors, the unit responsible for housing the firm’s portfolio of advocacy nonprofits — including Sixteen Thirty, the New Venture Fund, the Hopewell Fund and the Windward Fund — under a single corporate roof.
Fiscal sponsorship is a regulatory device that allows a single tax-exempt entity to incubate dozens of “projects” without each project filing its own Form 990 or registering as a separate corporation. For more than a decade, Arabella’s sponsorship architecture has been the structural backbone of progressive issue advocacy in Washington — a system that watchdog groups across the political spectrum, including the left-leaning Center for Public Integrity, have flagged as unusually opaque relative to comparable conservative networks.
Stremlau did not respond to requests for comment about Contours.
Arabella’s Rebrand — and What Came After
The launch of Contours in late 2025 cannot be understood in isolation from what was happening at Arabella Advisors in the same period. According to a November 17, 2025 announcement, Arabella sold off its fiscal-sponsorship business to a newly formed Public Benefit Corporation called Sunflower Services. The deal was financed by the very pooled funds Arabella had managed — the New Venture Fund, the Windward Fund and the Hopewell Fund — which were named as Sunflower’s “founding owners.”
Allan Williams, Arabella’s former senior vice president for partner solutions, took over as CEO of Sunflower. The remainder of Arabella’s business — its conventional nonprofit accounting and human-resources work — was renamed Vital Impact. Reporting at the time of the split, including by the Chronicle of Philanthropy, noted that the restructuring followed a sustained period of congressional scrutiny, regulatory attention, and the high-profile decision by the Bill & Melinda Gates Foundation to wind down a longstanding partnership with the firm.
The architecture, in other words, did not disappear. It was unbundled, renamed, and recapitalized — with the same pooled funds providing the financing and continuity at the executive level. Contours’ incorporation in Delaware in 2025 and its IRS recognition in October of that year placed Stremlau at the head of a brand-new vehicle just as the legacy structure was being reshuffled.
The Nebraska Connection
The clearest illustration of how this matters in the current cycle is the Nebraska Senate race. Osborn, a former labor leader and U.S. Navy veteran, is running as a registered nonpartisan against Sen. Ricketts, a former two-term governor. Osborn outraised Ricketts by roughly $200,000 in the first quarter of 2026 — pulling in $1.2 million and ending March with $939,146 in cash on hand — but Ricketts retains a cumulative fundraising lead of $4.2 million to $3.3 million for the cycle, according to first-quarter filings reviewed by the Nebraska Examiner.
Osborn has built his public brand around the argument that “big money” — and specifically anonymous outside money — is corroding American politics. His 2026 launch statement framed the campaign as an attempt to “get big money out of American politics.”
That message sits uneasily alongside the fact that two of the principal outside committees in his orbit have received cumulatively at least $950,000 from a Delaware nonprofit whose donors will never be publicly identified. Independent Candidates Action and the Working Class Heroes Fund are both, in effect, downstream of Contours.
The Working Class Heroes Fund has separately drawn FEC scrutiny. On April 14, Jeffery Davis, the chairman of the Nebraska Accountability and Disclosure Commission and a 2016 appointee of then-Gov. Ricketts, filed a complaint with the FEC alleging that the WCHF improperly paid 23 individuals who were also drawing payroll from Osborn’s official Senate campaign. According to the complaint summary, eight employees and 15 paid interns appeared on both ledgers, with payments coming from the PAC’s “soft money” account that is barred from coordinated campaign activity. Davis acknowledged at a press conference that he could not produce internal communications or payroll records demonstrating coordination, and that the case rests on overlapping staff, similar payment totals (roughly $100,000 each from the two entities), and the absence of other independent expenditures by the WCHF.
Osborn’s campaign and the WCHF have called the complaint “bogus” and “frivolous” and noted Davis’s appointment by Ricketts. The FEC will determine whether there is “reason to believe” a violation occurred before deciding whether to open a formal investigation.
Why The Timing Matters
Under the Internal Revenue Code, a 501(c)(4) created in October 2025 owes its first full Form 990 disclosure to the IRS by May 15, 2026. In practice, however, nonprofits routinely request the automatic six-month extension, which would push Contours’ first detailed filing to November 15 — twelve days after the November 3 general election in which the candidates and committees its money is supporting will appear on the ballot.
Even when filed, that 990 will not name a single donor. It will, at most, identify the organization’s board (Contours has so far disclosed only one officer), its consultants and any affiliated organizations. Whether and how those affiliations connect Contours back to the Sunflower Services network — the rebadged Arabella sponsorship business — will only become visible once the document is on file.
Contours’ use of the IRS e-Postcard, designated Form 990-N, is itself notable. The e-Postcard is reserved for organizations with annual gross receipts of $50,000 or less. An entity that has already moved nearly $4 million through political committees in a single fiscal year is, by any reasonable reading, ineligible for that streamlined filing in the year ahead, and will be required to file a full Form 990 for fiscal 2026.
A Pattern Across Both Parties
The Contours pipeline is not a Democratic-only phenomenon. Sludge’s parallel April 20 analysis identified roughly $44 million in first-quarter routing through nonprofit intermediaries by super PACs aligned with both Republican and Democratic congressional leadership — a structural feature of post-Citizens United campaign finance that has accelerated as both parties chase ever-larger outside-money budgets.
What distinguishes the Contours story is its proximity to the Arabella restructuring and the speed with which a single, newly recognized entity has scaled to multimillion-dollar political activity with effectively no public profile.
What Remains Unknown
Several questions cannot be answered from public records as of this writing. The identity of Contours’ donors is, by statutory design, not disclosable. The full list of recipient committees beyond the three identified by Sludge is not yet visible in FEC summaries because the relevant quarterly reports are still incomplete. Whether Stremlau is the only individual involved in Contours’ decision-making, or whether other former Arabella-network personnel sit on its undisclosed board, will remain unverifiable until the first full Form 990 is filed — likely after the election.
What the records do show is unambiguous. A nonprofit recognized by the IRS in October 2025, with a single named officer drawn directly from the management of the largest progressive dark-money network in the country, has channeled millions of dollars in seven months into a Democratic-aligned hybrid PAC that is, in turn, putting that money to work in races where the candidates being supported have campaigned against precisely this kind of opaque outside spending. Whether voters in Nebraska and elsewhere learn the names behind those dollars before they cast their ballots will depend on extension requests filed quietly with the IRS in the weeks ahead.
Contours Inc., the Working Class Heroes Fund, Independent Candidates Action and Government That Works PAC did not respond to requests for comment. Sarah Stremlau did not respond to a request for comment relayed through her current consulting practice. The Osborn campaign, asked specifically about the Contours pipeline, referred a previous reporter to its general statement on outside spending. None of the underlying allegations against the Working Class Heroes Fund have been adjudicated by the FEC.