On December 21, 2022, Axios’ Lachlan Markay reported that if Trump wins the 2024 election, he “will enjoy a key asset absent from his 2017 White House transition: a sprawling infrastructure already preparing to staff a new administration and immediately enact major policies.” Allies of the former president, Sollenberger notes, cite that infrastructure as a key difference between Trump and a MAGA Republican he may be running against in 2024’s GOP presidential primary: Florida Gov. Ron DeSantis — that is, if DeSantis decides to run. Firebrand author Ann Coulter, pundits at Fox News and Fox Business and writers for the National Review have all been pushing DeSantis for 2024.

“2021 was essentially a rebuilding year for Trump’s dark money machine,” according to Sollenberger. “That work not only came at a cost, it also appears to have happened in a black box, adding another layer of opacity on top of a fundraising and advocacy network that’s already grown so convoluted even legal experts have a hard time untangling it. In this instance, not only is it hard to follow the money, it’s hard to say for sure whether there’s all that much money to follow in the first place. At least, there appears to be a lot less of it flying around in the fractious 12 months after Trump left the White House.”

Sollenberger goes on to explain why America First Works fits the definition of a dark money operation.

“AFW is a 501(c)(4) nonprofit organization, which are often colloquially called ‘dark money’ groups,” Sollenberger explains. “These groups can raise funds in unlimited amounts, and while they don’t have to disclose their donors’ identities, the organizations can use a chunk of that unattributed money for political activity. According to its 2021 tax filing, which was first obtained by The Daily Beast, AFW — which raised about $51 million the previous year — doled out millions of dollars in transfers and grants. That filing shows that the funds all went to a handful of groups that make up a financial and political support network behind the former president.”

The Daily Beast reporter adds, “Those transactions included a $3 million grant to AFW’s 501(c)(3) counterpart, America First Policy Institute, and an additional $250,000 to Make America Great Again Policies — a lesser-known entity which has reported having a cost-sharing agreement with a new pro-Trump super PAC. AFW also paid another $250,000 for ‘research’ to Republican opposition research firm America Rising, according to the document.”

Sollenberger points out that if Trump’s dark money “maze” is “maddeningly difficult to follow,” that is “almost certainly part of the point,” according to government and campaign finance watchdogs.

Interviewed by the Beast, Brendan Fischer (who serves as deputy director of government for the watchdog group Documented), discussed the drop that occurred with America First Works in 2021 and told the Beast, “America First Works served as the dark money arm of Trump’s campaign in 2020, and it is not uncommon for a politically active dark money group to see a decline in revenue during a non-election year. But this drop is precipitous, and can’t be explained by election cycles alone…. The in-kind contributions of staff time and office space indicate that AFW employees were still working and on the payroll in 2021…. It also would be understandable if AFW was just going to spend down its existing funds and close up shop, but that’s not what’s going on either.”

The “name changes” with Trump-associated “dark money” operations, according to Sollenberger, are designed to be confusing.

“Last December,” Sollenberger reports, “an AFW spokesperson told the Daily Beast it wasn’t a name change; America First Policies had been ‘sold’ to America First Works 'in a private deal’…. However, previously unreported tax filings now show that another ‘America First Works’ was created that same year, this one in Washington, D.C. AFW1 reported a $140,100 grant to the new America First Works (AFW2), which AFW1 cites as a related entity.”

Sollenberger continues, “But The Daily Beast also obtained AFW2’s tax filing, which shows that the two groups share a slate of directors and that the grant comprised all of AFW2’s revenue for 2021. Almost all the money — around $132,000 of it — was spent on a ‘security deposit,’ the document shows, though it discloses no other underlying assets. Again, all of these moves and name changes seem designed to do one major thing: confuse.”