Tracking the 'America First Policy Institute': Top Donors, Spending, and Influence in the 2024 Election Cycle

The traditional campaign finance playbook is dead.

Political influence no longer flows exclusively through candidate committees and traditional party structures. Today, the most powerful engines in American politics are heavily-funded policy institutes that draft legislation, house political operatives, and shape national agendas between election cycles.

The America First Policy Institute (AFPI) is the premier example of this modern political infrastructure. Founded in 2021 by former Trump administration officials, the organization operates as a massive policy and research hub.

Bottom line: Because it operates as a 501(c)(3) nonprofit, the America First Policy Institute does not disclose its donors to the FEC. However, cross-referencing its leadership and known financial backers with federal filings reveals a network of mega-donors who simultaneously fund the institute and inject tens of millions into 2024 Super PACs.

Here is exactly how the organization is structured, where its money comes from, and how its financial footprint intersects with official campaign finance data.

The 501(c)(3) Shield: Why AFPI Donors Aren't in FEC Data

If you search for "America First Policy Institute FEC" in the federal database, you will come up empty.

This is by design. AFPI is registered with the IRS as a 501(c)(3) tax-exempt research and educational organization. Under federal law, 501(c)(3) organizations are strictly prohibited from participating in political campaigns on behalf of, or in opposition to, any candidate for public office.

Because they do not engage in direct electoral politics, they are not regulated by the Federal Election Commission.

Here is what that legal structure means for transparency:

• No donor disclosure: The IRS does not require 501(c)(3) organizations to make their donor lists public.
• Tax-deductible contributions: Wealthy individuals and corporate entities can write off their donations to AFPI.
• No contribution limits: A single donor can write a $10.0M check without violating any federal limits.

This structure makes tracking conservative think tank donations notoriously difficult. Researchers must rely on voluntary disclosures, leaked donor lists, or the tax returns of other philanthropic foundations that grant money to AFPI.

Who Funds America First Policy Institute?

While the official donor list remains private, the financial engines behind AFPI are largely an open secret in campaign finance circles.

The organization raised $23.8M in its first year of operation (2021), according to its publicly available IRS Form 990. By 2023, its operating budget had expanded significantly to support over 150 staff members.

So, who funds America First Policy Institute? The money flows from three primary channels:

1. Mega-donor board members: Wealthy individuals who serve in leadership roles and anchor the organization's funding.
2. Donor-advised funds (DAFs): Financial vehicles like DonorsTrust that allow wealthy individuals to pool their money and grant it to nonprofits anonymously.
3. Corporate foundations: Philanthropic arms of private companies aligned with the institute's deregulatory and trade policies.

But there's a catch.

While these donors can hide their think tank contributions, they cannot hide their direct political spending. By analyzing the FEC profiles of AFPI's key figures, we can map the financial network supporting the organization.

The FEC Footprint of AFPI's Leadership Network

To understand the financial weight behind AFPI, you have to look at the people running it.

The organization's board of directors and senior leadership include some of the most prolific political donors in the United States. While their contributions to AFPI are dark, their contributions to Super PACs and candidate committees are fully documented by the FEC.

Here is a breakdown of key AFPI figures and their corresponding political spending footprints:

Data sourced from FEC.gov individual contribution records, accessed early 2024.

This table illustrates a critical reality of modern campaign finance. The individuals who fund policy development are the exact same individuals who fund the political action committees tasked with electing candidates to implement those policies.

Understanding the difference between these funding vehicles is crucial. For a deeper dive into how this money moves, see our guide on individual contributions vs PAC money.

America First Works: The 501(c)(4) Dark Money Arm

You cannot analyze America First Policy Institute spending without looking at its sister organization: America First Works (AFW).

Here's the thing: 501(c)(3) organizations cannot run political ads. But 501(c)(4) "social welfare" organizations can, provided that politics is not their "primary purpose."

AFW operates as the lobbying and advocacy arm of the AFPI network. This structure allows the network to draft policy in the (c)(3) and aggressively advocate for it in the (c)(4).

This is the textbook definition of dark money unreported spending.

America First Works engages in several activities that blur the line between policy advocacy and electoral politics:

• Issue advocacy campaigns: Running television and digital ads that praise or criticize lawmakers' voting records without explicitly telling viewers to "vote for" or "vote against" them.
• State-level lobbying: Pushing model legislation in state capitols regarding election administration, energy policy, and education.
• Voter mobilization: Funding grassroots organizing efforts targeting specific demographic groups in key battleground states.

When a (c)(4) like America First Works crosses the line into explicitly advocating for the election or defeat of a federal candidate, it must report that specific spending to the FEC as an independent expenditure.

However, it still does not have to disclose its donors. If you want to understand how these disclosures work, read our breakdown of how to read FEC independent expenditures.

America First Policy Institute Spending Priorities

While we cannot see the donors, IRS Form 990s give us a clear window into America First Policy Institute spending.

Unlike Super PACs, which spend the vast majority of their funds on media buys and digital advertising, AFPI spends its money on human capital and infrastructure. It is building an administration-in-waiting.

Based on their most recent tax filings, their major expenditure categories include:

1. Executive Compensation and Policy Staff AFPI employs dozens of former cabinet secretaries, agency heads, and senior White House staff. The organization spends millions annually on salaries, ensuring that conservative policymakers remain engaged and compensated while out of power.

2. Litigation and Legal Centers A significant portion of AFPI's budget goes toward its litigation arm. They fund lawsuits against federal agencies, challenging regulations on environmental policy, labor rules, and executive authority.

3. State Chapters and Infrastructure AFPI has expanded aggressively into state-level politics. They have launched state chapters in battlegrounds like Georgia, Pennsylvania, and Arizona. This localized spending allows them to influence state legislatures, which often serve as testing grounds for national policy.

Connecting the Dots: Think Tanks and Super PACs

The relationship between 501(c)(3) think tanks and Super PACs is highly synergistic.

While they are legally distinct entities with strict rules against coordination, they operate in the same political ecosystem.

Here is how the ecosystem functions in practice:

• Step 1: The think tank (AFPI) drafts a comprehensive policy agenda, complete with model legislation and executive orders.
• Step 2: Mega-donors fund the think tank with tax-deductible contributions to refine this agenda.
• Step 3: Those same mega-donors write massive, non-tax-deductible checks to Super PACs.
• Step 4: The Super PACs spend millions on advertising to elect candidates who have publicly endorsed the think tank's agenda.

The result? A perfectly legal, highly efficient pipeline that turns private wealth into public policy.

To see how the Super PAC side of this equation operates, check out our guide explaining Super PACs vs regular PACs.

How Researchers Track Dark Money Networks

If you are a journalist, researcher, or compliance officer trying to map organizations like AFPI, you cannot rely on the FEC database alone.

You have to build a composite picture using multiple data sources. Here is the standard methodology for tracking dark money networks:

• Mine foundation tax returns: Search the IRS database for the 990 forms of known conservative philanthropic foundations (like the Bradley Foundation or the Mercer Family Foundation). Look at their "Schedule I" to see if they list grants to AFPI.
• Track the vendors: Look at the vendors AFPI pays for consulting, polling, and legal services. Then, search the FEC database to see which Super PACs and campaign committees are paying those exact same vendors.
• Monitor leadership overlap: Build a spreadsheet of every board member and senior fellow at the think tank. Run those names through the FEC individual contributor database to identify their preferred political vehicles.
• Watch the independent expenditures: Set up alerts for the 501(c)(4) arm (America First Works). If they launch a last-minute ad blitz before an election, it will appear in the FEC's independent expenditures data.

This cross-referencing is tedious, but it is the only way to pierce the veil of 501(c)(3) secrecy.

The Future of Political Influence

The rise of the America First Policy Institute signals a permanent shift in how political movements are funded and organized.

Candidates are increasingly reliant on outside groups not just for advertising support, but for their actual governing agendas. When a candidate takes office, they often pull their staff directly from the ranks of these think tanks.

This makes tracking America First Policy donors and spending just as important as tracking official campaign contributions. The money flowing into these institutes today dictates the legislation of tomorrow.

Quick Takeaways

• Legal Shield: AFPI is a 501(c)(3) nonprofit, meaning it legally hides its donors and can accept unlimited, tax-deductible contributions.
• The Donor Overlap: The individuals running and funding AFPI are the same mega-donors writing $10.0M+ checks to conservative Super PACs.
• The Advocacy Arm: America First Works operates as the 501(c)(4) dark money arm, pushing the institute's policies through issue advocacy and lobbying.
• Spending Priorities: AFPI spends its millions primarily on human capital—keeping former government officials employed and drafting future legislation.
• Tracking the Money: To understand AFPI's influence, researchers must cross-reference IRS 990 grant disclosures with the FEC footprint of its board members.