While serving as governor of South Dakota, Kristi Noem quietly pocketed $80,000 from a dark money organization tied to her political ambitions — and never reported it, raising serious ethical and legal questions.
According to tax records uncovered by ProPublica, the money came through a group called American Resolve Policy Fund, a nonprofit that promotes Noem and doesn’t have to reveal its donors. In 2023, that group funneled the $80,000 to a Delaware-based company that Noem secretly created called Ashwood Strategies — named after one of her horses.
Noem didn’t include the $80,000 on her federal financial disclosure forms, even though she was required to report all income when Donald Trump nominated her to serve as Secretary of Homeland Security. Experts say that’s likely a violation of federal ethics rules.
“This is new and disturbing,” said Daniel Weiner, a former attorney at the Federal Election Commission, now at the Brennan Center for Justice. “If donors to these nonprofits are not just holding the keys to an elected official’s political future but also literally providing them with their income, that’s new and disturbing.”
The $80,000 payment was listed on American Resolve’s tax form as a fundraising fee for Noem’s company. They said she helped raise $800,000 — meaning she kept a 10% cut. Another fundraiser only received 7% for doing similar work.
It’s not illegal for politicians to raise money for nonprofits. What raised red flags, experts say, is that Noem took some of the money for herself — and did it without telling the public.
“There’s no way the governor is supposed to have a private side business that the public doesn’t know about,” said Lee Schoenbeck, a longtime South Dakota Republican and former state Senate leader. “It would clearly not be appropriate.”
Noem’s lawyer, Trevor Stanley, insisted that she “fully complied with the letter and the spirit of the law” and claimed the Office of Government Ethics “analyzed and cleared her financial information.” But when pressed for proof that the $80,000 was disclosed, he didn’t respond.
He also claimed Noem “did not establish, finance, maintain, or control” the nonprofit — only that she was “simply a vendor.” But the timeline raises questions: Ashwood Strategies and American Resolve were created within minutes of each other in Delaware, on June 22, 2023.
The nonprofit, which raised $1.1 million in 2023, had no employees and unclear activities. The group spent only $220,000 of that — with over one-third of it going to Noem’s company and the rest mostly covering travel and admin costs.
Meanwhile, Noem has drawn criticism for her spending. She was seen wearing a nearly $50,000 gold Rolex while touring a prison in El Salvador. When her purse was stolen in Washington, D.C., earlier this year, it contained $3,000 in cash. Her team said it was for “dinner, activities, and Easter gifts.” Noem has also faced scrutiny for charging taxpayers for trips to Paris, a bear hunt in Canada, and dental work in Houston — though she denies any misuse of public funds.
The existence of Ashwood Strategies — and its financial tie to the dark money group — only came to light during Noem’s confirmation process. South Dakota law requires top officials to work full-time for the public. “There’s no room for side businesses like this,” Schoenbeck said.
The nonprofit American Resolve has since attacked local journalists who questioned Noem’s expenses, buying Facebook ads criticizing their reporting. It also runs a PAC — American Resolve PAC — promoting Noem across the country and helping GOP candidates.
What remains unclear is who funded the nonprofit that paid Noem. Because it’s a dark money group, donors stay hidden. What’s known is that Noem benefited directly — and failed to report it.
Now, experts are warning that this kind of hidden self-dealing blurs the line between public service and private profit — and could spell real legal trouble.
“She didn’t tell the public. She didn’t tell the feds,” one ethics expert told ProPublica. “That’s not just sloppy. That’s a serious problem.”
