By FOIA Research
on January 22, 2021 - Last updated: June 21, 2021

America First Policies

America First Policies (AFP) is a dark money group in the disguise of a "social welfare" organization which was created to collect donations for Donald Trump's America First policy agenda. AFP is registered as a 501(c)(4) organization, and is thus allowed by federal law to raise unlimited amounts of money without having to reveal its donors' identities.1 2 501(c)4 organizations have become a major conduit for funneling undisclosed money into political projects. According to The Washington Post, they3

... are allowed to participate in politics, so long as politics do not become their primary focus. What that means in practice is that they must spend less than 50 percent of their money on politics. So long as they don't run afoul of that threshold, the groups can influence elections, which they typically do through advertising.

Set out to change public policies during Trump's tenure, two of AFP's initial targets were to undo Barack Obama's healthcare reform and stricter immigration laws.2

AFP is tightly interconnected with the legally separate America First Action Super PAC (AFASP), which also can collect unlimited contributions,4 but in contrast to AFP, must disclose its donors. As opposed to AFP, due to its legal status, America First Action Super PAC may expressly advocate for the election or defeat of particular candidates (rather than only advocating for policies).

Both organizations have overlapping personnel:5

  • Linda McMahon; chair of America First Action and America First Policies
  • Brian O. Walsh; president of America First Action and America First Policies6
  • Kelly Sadler; communications director of America First Action and America First Policies7

Both organizations have courted controversies, as several senior employees had to resign due to racist and inflammatory comments. America First Policies was also part of a web of dark money activist groups that funded caravans to Washington for the rally before the 2021 insurrection attempt by Trump supporters at the US Capitol.8

America First Policies


After Donald Trump's victory in the 2016 presidential election, on December 14, 2016, a meeting took place to decide how the financial and digital infrastructure of the America First empire should be built up.9 According to a 2017 Huffington Post article9 :

... it was widely agreed that the GOP needed a nonprofit arm, supported by major donors, to push the president’s agenda across the country ... The most important component of any organization like this is its voter database, since it can be used to seek donations and mobilize supporters behind the president’s initiatives.

A major figure in the initial talks was Republican megadonor Rebekah Mercer, daughter of hedge fund billionaire Robert Mercer, who served on the Executive Committee of Trump's 2016 transition team.10 According to the Huffington Post9 :

On December 14, there was a meeting to discuss the outside group in a glass-walled conference room on the 14th floor of Trump Tower. Brad Parscale sat at the head of the table. Around him were roughly 12 people, including Rebekah; Kellyanne Conway; David Bossie; Michael Cohen, Trump’s lawyer; Jason Miller, then Trump’s senior communications adviser; and Marc Short, Mike Pence’s senior adviser.

In the course of the meeting Mercer seems to have clashed with Brad Parscale, Trump's digital and data director,11 when she met with resistance to use Cambridge Analytica (CA) as the digital infrastructure for the voter database and its microtargeting features, and withdrew temporarily. According to aforementioned Huffington Post article, Mercer "would subsequently complain about the exchange to [Steve] Bannon and others, and continued to lobby for CA to be at the center of the new organization." Her efforts must have led to some success, since it was reported only a few months later that America First Policies would rely on tools and data sets provided by Cambridge Analytica.11


From the known attendees of that December 14 meeting, only David Bossie, Trump's deputy campaign manager and Brad Parscale, Trump's digital and data director,11 were among the six founders of America First Policies on January 27, 2017, which also included1

  • Nick Ayers, a Republican consultant regarded as former Vice President Mike Pence's top political adviser
  • Rick Gates, Trump's former deputy campaign manager
  • Katrina Pierson, AFP communications team
  • Marty Obst, adviser to Mike Pence

When America First Policies was registered in January 2017, all of its founders had already worked for Donald Trump's presidential campaign, or in his immediate orbit. The most prominent among them is David Bossie, who started to advise Trump in 2010 on how to become president,12 at the time when he headed the conservative advocacy group Citizens United. It was the United States Supreme Court’s decision that year in Citizens United v. FEC which allowed unlimited political campaign financing by corporations, including nonprofit corporations, labor unions, and other associations, fueling the rise of Super PACs. Citizens United had been bankrolled to a large extend by the Koch brothers.13  Bossie’s initiative certainly paid off later, when he was made Trump’s deputy campaign manager, only interrupted by a short fallout when in May 2019 he was accused by the Internal Revenue Service of defrauding political donors by lining his own pockets.14 Bossie then returned as a strategic ally to help contest Trump’s impeachment trial, starting in December 2019.15 According to an AP article, two of the AFP founders, Bossie and Nick Ayers, "have close ties to the Mercers."2

According to Politico, Parscale was Jared Kushner's pick to head the new organization,16 and thus the headquarters of the fledgling AFP was set up in Parscale's hometown, San Antonio, Texas. Parscale's business relations with the Trump empire started in 2010, when he was making websites for several of Trump's businesses with his digital media company Giles-Parscale. According to an article in the San Antonio Current11 :

In 2010, shortly before he’d thrown in with Giles, he got an invitation to bid on the website for Trump International Realty. His $10,000 quote won him the work, and the sites for the Eric Trump Foundation and Trump Winery followed. The family was happy with the work, so when Big Daddy launched a presidential exploratory committee, Parscale got the call and slapped together a site for $1,500.

According to research by the Center for Responsive Politics, Giles-Parscale received $96 million during 2016. Parscale stated that the majority of the funds were used to place ads.11 According to an article in the San Antonio Current11 :

Indeed, Parscale located the nerve center to Trump’s digital operation here, in a cookie-cutter office building on Loop 410. In addition to 100 staffers, interns and volunteers, the group hosted workers or assets from the companies whose tools they used — Facebook, Google and Cambridge Analytica, the conservative data analytics company that improperly collected info on more than 50 million Facebook users.

“[The San Antonio center] was called Project Alamo based on the data, actually,” Parscale’s digital content director, Theresa Hong, said while providing a video tour of the space to the BBC. “That was Cambridge Analytica. They came up with the Alamo Data set, right, so we just kind of adopted the name Project Alamo.” ...

“I was the megaphone,” Parscale told conservative radio host Joe Pagliarulo during one of his post-election victory laps. “And what I needed to do was to find smart people, and those came from, again, the Republican Party, the RNC, or from other companies that were subcontractors and my own company and say, ‘How do we find these people, individual voters, and find the exact right ones?’… I didn’t need a gut, because I had the data.”


On March 30, 2017, Katie Walsh, formerly White House Deputy Chief of Staff, left that position to join America First Policies.17 Also "Trump loyalist" Brian Walsh (no relation to Katie Walsh) became subsequently involved.18

Rick Gates' AFP stint was cut short, since according to an article on FactCheck, he was19

... forced to leave the group in March 2017 because of his ties to Paul Manafort, a former Trump campaign chairman and chief strategist ... both Manafort and Gates were indicted on charges of money laundering and tax evasion related to their work for a pro-Russia political party in Ukraine.

In order to bring Republicans in line with Trump's agenda, AFP turned also against people from the Republican Party that would not go along. For example, on June 23, 2017, Republican Senator Dean Heller was targeted with an advertising campaign over his opposition to the Obamacare repeal bill. According to an article in Politico, the "advertising blitz" was "backed by more than a million dollars."18 Heller was considered to be vulnerable in the 2018 election,18 and ultimately lost to Democratic challenger Jackie Rosen.

In 2017, at least three Fortune 500 companies had contributed to America First Policies, including the "Southern Company ($1 million), CVS Health ($500,000) and Dow Chemical ($100,000)," according to an investigation by MapLight.20 The MapLight article states that in 201720

America First Policies reported spending $452,000 ... to support former Sen. Luther Strange, R-Ala., in his unsuccessful GOP primary bid, and it dropped more than $1.3 million opposing Democrat Jon Ossoff in the race for an open congressional seat in Georgia.


In January 2018, America First Policies' Director for Advocacy, Carl Higbie was forced to resign as head of Corporation for National and Community Service (the nation's largest annual grant maker supporting service and volunteering) to which he had been appointed by Donald Trump, after making racist and inflammatory comments on a radio talk show about black Americans, Muslims, women, LGBT people, veterans suffering from PTSD and immigrants, which included advocating violence.21 Higbie also pushed the false Birther conspiracy about Barack Obama, claiming that he was not an American.21

Starting in February 2018, former Vice President Mike Pence traveled across the country on a America First Policies-sponsored "Tax Cuts to Put America First" tour.22 That month Donald Trump promoted Brad Parscale to the position of campaign manager, which he would keep until July 2020, when Bill Stepien took over that role.23

On May 10, 2018, it became public that AFP's policy advisor, Juan Pablo Andrade, was a Nazi sympathizer, after he was recorded on a Snapchat video saying that "the only thing the Nazis didn't get right was that they didn't keep fucking going."24 Andrade has been on Trump's National Hispanic Advisory Council, Trump's National Diversity Coalition and the Trump campaign as a surrogate.25 He also wrote for The Hill, but the news website dropped him when it learned of the video and its contents.26 Andrade has ties to the far right, for example to "Cesar Subervi, an alt-right activist who participated in the Charlottesville white supremacist march and has been filmed with Richard Spencer," being a close friend of Andrade, according to an article by Mediaite.24

Later that month, it was reported that John Loudon, a policy advisor for the group, used inflammatory and derogatory language against women, Muslims and Democrats.27 He also spread the birther conspiracy theory suggesting that Obama was a Kenyan-born Muslim.27 According to an article by CNN27 :

Prior to working at America First, Loudon was an elected member of the Missouri Senate and the Missouri House of Representatives. Loudon and his wife, Gina, were delegates for Trump at the 2016 Republican National Convention, and Gina is on the Media Advisory Board for Trump's re-election campaign. She and her husband have visited the White House and attended pro-Trump events at Trump properties, according to her social media postings.

Following the racist and bigoted comments by the staff at America First Policies, three major donors, CVS Health, Southern Company, and Dow Chemical announced that they would no longer contribute money to America First Policies.28


America First Policies was part of a web of dark money activist groups that funded caravans to Washington for the rally before the 2021 insurrection attempt by Trump supporters at the US Capitol.8

According to a report by Open Secrets, in the run-up to the January 6, 2021, coup attempt, America First Policies was among the major funnels to finance the Capitol Hill event on that day.29 According to Open Secrets29 :

The rally’s production manager is listed as Justin Caporale, the Trump campaign’s advance director who received more than $144,000 in direct payroll payments from the campaign in the one-year period leading up to November 2020. 

Caporale’s business partner, Tim Unes, was the rally stage manager and was paid more than $117,000 by the Trump campaign through at least November 2020. Event Strategies Inc., their firm, was paid more than $1.7 million from Trump’s campaign and joint fundraising committee. 

Trump-affiliated dark money group America First Policies paid the firm another $2.1 million from 2018 to 2019, the most recent years for which data is available. America First Policies’ tax returns obtained by OpenSecrets show it also provided funding to Women for America First, a 501(c)(4) nonprofit that submitted the rally’s permit records to the National Park Service.

America First Action Super PAC

The America First Action Super PAC (AFASP) was created with a twofold purpose:

  1. To establish a fund that should unify the contributions from megadonors to the Trump campaign. In the 2016 and 2018 elections, four Trump-related Super PACs received donations from 38 people who gave over $500,000 each. To consolidate these funds, AFASP was created on April 12, 2017, for the 2020 election cycle. (However, AFASP's efforts were not particularly successful since as of August 2020, only six of the previous 38 top donors contributed to America First.4 )
  2. To engage in political activity without limitations. While as a “social welfare organization” America First Policies is not allowed to primarily engage "in political activity or coordinating with any political campaign or party,"30 AFASP is.

As a Super PAC, AFASP can receive unlimited donations from individuals and entities, but has to disclose its donors.

AFASP cycled money into Donald Trump's personal coffers. According to TruthOut30 :

The PAC has spent tens of millions of dollars on Trump’s re-election efforts over the last three years, hosting events at Trump properties and raising money through some of the president’s shadiest supporters — including accepting a $3 million illegal donation from a shell company co-founded by Rudy Giuliani associates Lev Parnas and Igor Fruman, who are currently under indictment.

As was the case with America First Policies, AFASP went on hiring people who previously had been supporting Trump's election campaign. In January 2018 Axios reported31 :

Trump campaign holdovers from America First Action include Corey Lewandowski, Katrina Pierson and Brad Parscale, while David Clarke, the controversial former Milwaukee County Sheriff, serves as a spokesman.

According to TruthOut30 :

The PAC’s chair, former pro-wrestling exec Linda McMahon, served under Trump as head of the Small Business Administration, and its spokesperson, Kelly Sadler, worked for the White House as a special assistant to the president handling surrogate and coalitions outreach.

Sadler had served as a special assistant to the president in the White House Office of Communications from May 2017 to June 2018.32 Her tenure in the White House was marked by an incident during a May 2018 meeting where she mocked Senator John McCain's failing health. She reportedly said "It doesn't matter, he's dying anyway,"33 but ultimately had to leave her post for leaking information to the press. As of 2021, "Sadler handles all media requests for both America First Action PAC and America First Policies," according to the AFASP website.5


Self-enrichment seems to have played a major role in AFASP's business dealings, at least for Brad Parscale. The same years as AFP and AFASP were founded, he registered "Parscale Strategy LLC, a marketing company that did work for America First Action, as well as others including the Republican National Committee," according to an article in The Mercury News.34


Also the company run by Brad Parscale's wife, Candice Parscale, seems to have profited from AFASP, since it received nearly $1M from America First Action, in possible violation of Federal Electoral Commission laws. According to The Mercury News:34

Delaware incorporation documents show that Candice Parscale founded Red State Data and Digital on March 2, 2018, just days after it was announced that her husband would become Trump’s campaign manager. The America First Action super PAC made its last payment to Parscale Strategy on March 13, 2018, and its first payment to Red State eight days later, on March 21. In 2018, America First paid Red State a total of $837,000, according to FEC records. That makes it the fifth biggest recipient of money from the group last year, according to Open Secrets. Since then, the company has received payments totaling approximately $70,000 for fundraising consulting and web site design and development, according to FEC filings.

In the 2018 midterm election cycle, the Super PAC spent about $36.5 million.35 The top vendor, the media strategy firm Red Eagle Media Group, is closely affiliated with the National Rifle Association (NRA), and is implicated in allegations of illegal coordination between the NRA and Donald Trump’s 2016 presidential campaign.36 According to an investigation by OpenSecrets37 :

As recently as October 2018, the Trump campaign and NRA made ad buys at the same local radio station within days of each other in filings that list the same individual ad buyer but with Trump’s campaign listing Harris Sikes Media as the firm and the NRA listing Red Eagle.


In June/July 2019 AFASP created a website called the American Herald,38 which was misleadingly portrayed by the Trump 2020 campaign as an independent news outlet.30 Articles on the website have no author bylines, and their headlines regurgitate key tropes and lies of the MAGA campaign. According to TruthOut30 :

... the top stories on the Herald’s home page include: “Democratic cities overrun by left-wing mobs”; “Trump gives aid to jobless, rentless, borrowers”; “Democrats refuse to condemn antifa”; and “President Trump’s executive orders put America first.”


In August 2020, spokesperson of AFASP, Steve Cortes, became the senior advisor and spokesman of the Donald Trump campaign. The radio host has a known history of racist and anti-Semitic remarks, and reportedly said in June 2020 that he wanted "a tad bit more of a fascist Trump."39

Screenshot from a YouTube video titled "Steve Cortes: Trump will prevail in a hand recount/audit."

According to The New York Times, the billionaire Timothy Mellon, heir to the Mellon banking fortune, donated $10 million to AFASP in 2020.4 AFASP had reported spending nearly $150 million during the 2020 election cycle.40

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