Independent watchdog makes DOJ referral over alleged election law violations in Alaska Senate race

An independent watchdog group on Wednesday sent a referral to the U.S. Attorney for the District of Alaska alleging election law violations by a network group that sought to damage incumbent Republican Senator Daniel S. Sullivan’s campaign in the state’s Senate race. 

The watchdog, the nonprofit American Accountability Foundation, delivered its 114-page referral to local Justice Department prosecutors on Wednesday, proposing evidence that a network of groups with ties to a "decoy candidate" with a strikingly similar name possibly coordinated contributions, contributed in the name of another, or illegally shared infrastructure as part of an advertisement campaign. 

Republicans have claimed that the alternative candidate, Dan J. Sullivan is running as a Republican in order to draw votes away from the incumbent senator and give his Democratic opponent, Mary Peltola an advantage in the general election. The Alaska Republican Party previously asked state election officials to remove the candidate from the ballot. The state Division of Elections kicked J. Sullivan off the ballot, but that decision was later overruled by a state judge.

Under Alaska’s open primary system, all candidates for an office run against each other in the primary election. The top four candidates, regardless of political party, advance to the general election in November. There, voters rank the candidates in order of preference.

The group is asking the federal prosecutors to probe the nonprofits and political action committees for evidence of communication and coordination. 

You can read the referral, obtained by Just the News, below: 

The referral builds on existing allegations that the campaign of Dan J. Sullivan illegally colluded with the nonprofit 907 Initiative to conduct a negative advertisement campaign against Senator Sullivan. In a referral last month to the Federal Election Commission, the watchdog Americans for Public Trust submitted material that purportedly showed that veteran Democratic strategist Amber Lee was working for the decoy campaign and sat on the board of 907 Initiative at the same time that organization organized a nearly $500,000 ad blitz criticizing incumbent Senator Sullivan. Lee has denied that the arrangement violates the law. 

AAF says it has found more evidence that it believes the Justice Department should investigate, including possible coordinated corporate contributions through 907 Initiative and D.C.-based nonprofit Majority Forward as well as possible “contributions in the name of another” violations involving Midnight Sun Independence Fund and Midnight Sun PAC. Both avenues could open the door for prosecutions under federal election law. 

Federal prosecutors are already investigating whether Dan J. Sullivan entered the Senate race with the same name as incumbent Daniel S. Sullivan for the purpose of confusing voters. A grand jury issued subpoenas as part of that investigation in August shortly ahead of the state’s nonpartisan primary. 

Possible coordinated expenditures under review

While Republicans worry that Dan J. Sullivan could take away important votes from incumbent Senator Daniel S. Sullivan, Alaska Public Media reported that preliminary results indicated little confusion among Alaska voters — most of Dan J. Sullivan’s votes came from Democratic-leaning districts.

Under federal law, coordinated expenditures count as contributions to that candidate. The group also believes that Amber Lee’s role fulfills all the legal prongs necessary to at least warrant an investigation into possible coordination between the decoy campaign and the 907 Initiative, which spent about $450,000 on its advertisement campaign criticizing the decoy campaign’s opponent, according to estimates by AAF. 

Three elements need to be proven

In order to prove that communications were coordinated, investigators would have to meet three standards, including payment, content, and conduct.

As for payment, prosecutors would have to determine that the political communication was paid for by someone other than the candidate or their campaign committee. The second is content: the communication has to refer to a clearly identified federal candidate within 90 days of the primary or general election. The third is conduct, whereby prosecutors would have to link the campaign and an outside group, such as both using the same vendor, sharing campaign staff or contractors, or evidence the campaign communicated with an outside group about the ads.  

Groups can get around these prongs by establishing clear firewalls that block the sharing of information between the campaign and the outside group. 

“This allegation is patently false,” a spokesperson for 907 Initiative previously told The New York Post. “907 Initiative has never employed or paid Amber Lee. Amber Lee is a board member of 907 Initiative. The fact that Americans for Public Trust can’t decipher the difference between those two tells you all you need to know.” 

Additionally, the public evidence raises questions about possible coordination and “contributions in the name of another” violations among the broader group of organizations and nonprofits in the race, including Majority Forward, the 907 Initiative, the Midnight Sun Independence Fund and Midnight Sun PAC. 

Nearly identical ads attacking incumbent Dan S. Sullivan

Under federal law, “[no] person shall make a contribution in the name of another person or knowingly permit his name to be used to effect such a contribution.” These regulations also include giving money that was provided in all or in part by another person without disclosing the ultimate source. Majority Forward is a Democratic-aligned 501(c)(4) non-profit advocacy group based in Washington, D.C. affiliated with New York Democratic Sen. Chuck Schumer’s Senate Majority PAC. 

For example, AAF identified two versions of a nearly identical video ad targeting Senator Sullivan. The only difference is that one ad disclaimed “Paid for by Majority Forward” and one disclaimed “Paid for by 907 Initiative.” Both ads “Tell Dan Sullivan: Stop Raising Our Costs,” with the same footage, graphics, and call-to-action phone number (202-224-3004). 

Another ad, this one about healthcare costs, with the same speaker, script, and graphics, appears on the Google system as “Paid for by Midnight Sun Independence Fund” and as “Paid for by Majority Forward," according to AAF. 

The Google Ads Transparency Center also lists Majority Forward as the Google-verified advertiser of a number of video advertisements which say in the ads they were instead paid for by the Midnight Sun Independence Fund (MSIF). One advertisement urging Sen. Sullivan to stop protecting "out-of-state trawlers" ran from rom July 2026 to September 2026.

According to AAF, the Majority Forward campaign totaled at least $3.5 million in spending during the 90 days leading up to the primary within the coordination window, though this is a low-end estimate because it only includes data on public air wave communications, like broadcast, and certain digital platforms like Google and Meta which voluntary disclose advertising data.  

Tweedledum and Tweedledee?

AAF contends that Majority Forward’s verified status as the advertiser of both the healthcare and the “Corporate Trawler” ads constitute evidence that Majority Forward “paid for and directed communications” that were publicly attributed to MSIF.

Further evidence also links MSIF to Majority Forward. According to corporate records, MSIF listed its address as 1032 15th Street NW, Suite 247, Washington, DC 20005, the same street address and suite number claimed by Majority Forward in its separate corporate records. The address listing was contained in a filing by the affiliated Midnight Sun PAC which reported a contribution of $100,000 from MSIF on July 14, 2026. If all or part of this contribution was funded by Majority Forward, that contribution could be a violation of campaign finance law. 

These facts raise questions, AAF said, about whether the Midnight Sun PAC serves as a conduit for expenditures for other groups, like Majority Forward. 

Same staffers keep reappearing

Several staff members also overlap between Majority Forward, the 907 Initiative, and the decoy campaign, pointing to the possibility of coordination. For example, Christopher Koob is listed as both the director of Majority Forward and Treasurer of 907 Initiative Action, a super PAC with no receipts or disbursements since January 2025. Nevertheless, it represents a bridge between the Majority Forward network and 907, AAF contends. 

The Washington Free Beacon reported in July on yet another link. This summer, Majority Forward ran an advertisement in Alaska featuring a representative of the decoy Sullivan campaign. The man in the spot, Anchorage mover Alan Harris, is also the boyfriend of strategist Amber Lee, who is under fire for her dual role with 907 and the decoy campaign. Harris delivered Sullivan's declaration of candidacy to state election officials on June 1, and the Majority Forward ad started airing June 16, The Beacon reported.  

“Neither Senate Majority PAC nor Majority Forward has ever communicated with Dan J. Sullivan, directly or indirectly, nor did Senate Majority PAC encourage him to run or have any involvement in his campaign," a spokesperson for Senate Majority PAC told the outlet.