The Corruption Belt – Diagramming Oklahoma’s Dark Money Web – Political Consultants and PAC Treasurers

The Corruption Belt – Diagramming Oklahoma’s Dark Money Web – Political Consultants and PAC Treasurers

After many weeks of study, I was able to put together an initial diagram of Dark Money and how it flows among and between various 501c4 and PAC organizations influencing Oklahoma elections.

Unfortunately, it creates rather a combination of shock, dismay, frustration and confusion to look upon the document itself.  Standing at a distance, it looks a bit like a washing machine – interesting because I contend that the whole process amounts to little more than money laundering for political gain.

Definitions For Dark Money Components

501c4:  This is an IRS designation applied to organizations which desire to be considered charitable/non-profit, but also want to have the ability to spend money influencing political candidates or campaigns. According to the IRS, an organization can maintain a c4 designation if they spend LESS THAN 49% of their money/time/assets for political activity.  Donations are not generally tax deductible.

501c3:  This is an IRS designation applied to organizations which desire to be considered charitable/non-profit, but they may not engage in political activity.  Donations are tax deductible.

Dark Money:  Though 501c4 organizations must reveal the amount of money they spend on political activity, they do not have to reveal the names of their donors – hence the source of the money is ‘dark’ or unrevealed.  This article answers many questions about Dark Money if you are interested in more information.

PAC: PAC stands for Political Action Committee.  There are actually several different kinds.  The Federal Election Commission (FEC) has a webpage with definitions here.  PAC’s are created to allow an organization or individual to give (mostly) unlimited amounts of money to political candidates or campaigns.  501c4’s can donate to PACs, allowing donors to remain anonymous.  Super PACS can only make Independent Expenditures (IEs).  This means that there can be no coordination at all between a candidate, his/her campaign and donors to the PAC.  People independent of the candidate and campaign, set up the PAC, solicit donations and then spend funds from the PAC on various forms of advertising on behalf of the candidate or campaign WITHOUT THEM KNOWING.

Dark Money Web – Many Political Consultant Companies Involved

Political Consultants are people who have backgrounds in politics and/or law, who help candidates with their elections.  They provide – or contract for – services such as, photography, art, writing, polling, consultation and advertising, to include radio, social media, television and direct mail.  Candidates normally pay consultants directly from funds they raise for their campaign. 

Because I identified so many political consulting groups through the Dark Money Web, I decided to examine Ethics Commission reports for every seated Oklahoma legislator in 2022 and compile a list of all political consultants used by Oklahoma legislators.

If a legislator made a payment to a political consultant, I recorded the name and date I first found record of payment.  Many of the following firms are not implicated in the Dark Money web at all, but were included because the intent was to catalogue ALL firms for information. 

Here is the compiled list of the most popular political consultants within the House and Senate:

Amber Integrated – The Amber integrated team includes members of former “The Right Strategy Group“, and FKG Consulting groups – all of whom have long resumes in politics or government relations (aka lobbying).  Partner Tammie Kilpatrick is designated as a lobbyist for at least 14 different organizations, including Cherokee Nation Businesses LLC, according to Oklahoma Ethics reports.

Ascend Action – Run by long-time Republican political strategist Holly Gerard, the Ascend Action website states, “we exclusively work with the candidates and organization who promote [these] foundational American values and strive to see them protected in the federal and state government level.”  Much of their team has worked with Senator Ted Cruz.  Other campaigns include Jim Jordan, Greg Abbott and Chip Roy.

Campaign Advocacy Management Professionals – According to CAMP’s website, CAMP is a partnership between Fount Holland and Matt Parker.  Parker hails from Louisiana where he worked for Bobby Jindal.  Holland has a long legacy in Oklahoma politics.  In 2016, Holland was charged (along with others) on two counts of conspiracy to commit a felony relating to the campaign of then-candidate for Superintendent, Joy Hoffmeister in 2014.  During that time, Holland was operating AH Strategies with partner Karl Ahlgren and Trebor Worthen, a former two-term member of the Oklahoma legislature elected to the seat held previously by his father, at only 23 years of age.  Holland, Ahlgren and Worthen also owned Majority Designs, a printing/mailing service – now apparently called CAMP Mail run by Karl Ahlgren, who has his own questionable footprint in Oklahoma politics.  Worthen is now working on his own helping candidates he won’t name publicly and operating the Sooner State Leadership Fund dark money PAC which has paid for ads against Governor Stitt.

HPPC/Lance Cargill – Though there is no website I can find for his current organization (this is from an old website), Lance Cargill has been a fixture in Oklahoma politics for two decades.  First elected to the House in 2000, Cargill became Speaker of the Oklahoma House from 2007 to 2008 before leaving the legislature due to a scandal involving late payment of property and personal income taxes and accusations of mishandling PAC money. In 2017, HPPC helped Democrat Richard Morrissette run for Oklahoma City Council in a campaign that reported it’s only spending to HPPC.

James Martin Company – Founded by Jenna Worthen, wife of Trebor Worthen, James Martin doesn’t list their political clients or the non-profits with which they have worked.  Their team includes Macey Whitehouse, identified as a former employee of CAMP. 

Neva Hill – I was unable to find a working website associated with Neva Hill’s political consulting services, however, BallotPedia reports Hill as a fixture in Oklahoma politics over four decades during which she has worked for Tom Cole, James Lankford and Ervin Yen.  She has also been a long-time political commentator for KOSU.  She served as the State Director for the Bush/Quayle campaign and was the Assistant Commissioner of Labor under Governor Henry Bellmon.

Tomahawk Strategies – Run by John Fritz and Josh Wagoner, with – apparently at some point – Stuart Jolly.  So far, this organization has been sued by a Tulsa doctor for libel and conspiracy during a series of ads for their client Cody Rogers (they lost the case, paying Dr. Emerson nearly $10k in damages 3/2022), broke numerous FEC rules during their management of Lankford opponent Jackson Lahmeyer, racked up a Better Business Bureau complaint for services rendered, and gained public consternation about a flyer for candidate Kelly Dunkerley in Tulsa that mis-stated facts and quoted Jolly as endorsing the candidate when he had not.

Victory Enterprises – This organization headquarters out of Iowa, but has agents for Oklahoma, Missouri and Wisconsin.  Oklahoma’s agent of record is Whitney Michael who apparently lives in OKC.  Some of the people for which members of the Victory Enterprises team has worked, according to their website, include, Chuck Grassley, James Lankford and John McCain.  Many of the team members have extensive backgrounds in politics.

Dark Money Web – Many Treasurers In Common

You can find the diagram on our Scribd account.  This dark money web was created as I began to research Jake Merrick’s failed Senate re-election campaign.  I wanted to understand who wanted Jake removed from office so badly as to spend so much money on an Oklahoma Senate seat.  Clearly – with nearly $350,000 spent on the race – individual donations were exceptionally unlikely to make up the bulk of the campaign, so I believed a much wider effort had to be at play.  I was right.

The problem – if you will – of researching Jake’s race was that I kept finding where money was transferred from one PAC to another and payments were made to organizations for services. 

Lots of money went to organizations outside Oklahoma for radio, television and social media (digital) advertising.  Of those organizations within the state that were paid for services out of campaign and PAC accounts, several appeared numerous times; CAMP, South Creek Group LLC and Amber Integrated all received  checks for services rendered from numerous PACs.  In some cases, all three received payments from one PAC.

Another interesting overlap was that many of the PACs had the same treasurer, ie; Dustin McIntyre and Joel Riter and Geoffrey Long appeared numerous times.  


McIntyre is an enigma, but paperwork filed with the FEC for the Protect Our Freedoms PAC provides a McIntyre email address for the FEC Compliance Group, LLC, once the Clark Fork Group, LLC, both based out of Columbus, Ohio.  Joel Riter is a known associate of Clark Fork Group.


Joel Riter, a former aide to Republican Ohio Senate candidate Josh Mandel and lobbyist for Cap Square Solutions in Ohio, has been connected to a dark money web influencing Ohio elections including PACs that also function in Oklahoma.  CREW, an ethics watchdog group, has filed FEC complaints on several of Riter’s PACs which network to others on the Dark Money Web, including, A Public VoiceAmerican Exceptionalism Institute Inc, and Prosperity Alliance, Inc.

Riter also has a presence in Oklahoma.  The 501c4, Foundation for Economic Prosperity is operated by Trey (John W.) Richardson and Jeri Richardson with Joel Riter listed as Director and Secretary.  The Richardsons own SAGAC Public Affairs and GrPRO  – the latter of which employs Maressa Treat, the wife of Senate Pro Temp, Greg Treat, who also uses SAGAC and GrPro to manage his campaign.  IRS filings for the Foundation for Economic Prosperity are only available from 2016-2019.

Geoffrey Long, for example, is the Designated Filing Agent (originally named treasurer – an error I regret) for Truth PAC (on the upper left in our diagram).  This PAC was apparently created by CAMP as the email reads, Matthew Parker is Treasurer and the address is CAMP’s (401 NE 46th Street, OKC 73105).  Ethics records show that the PAC received $281,000 from Protect Our Freedoms Pac.  Protect our Freedoms PAC – which has a Virginia address at a Parcel Plus in a strip mall – received two $375,000 contributions: One from Benjamin Harris and one from David Chaney, founders of EPIC Charter School, now with four felony charges relating to mismanagement of taxpayer funds. Nearly every penny of the $281k was spent supporting straw candidate Steve McQuillen for State Auditor and Inspector over Cindy Byrd, the current SAI who audited EPIC on orders of the governor and found large numbers of illegalities.

During 2018, the Foundation had over a million dollars, but recorded only spending of approximately 270 thousand dollars to Gr Pro LLC and SAGAC Public Affairs for consulting and event management and a ‘grant’ of $2500 to Advancing Freedom for ‘issue advocacy’.

Foundation for Economic Prosperity Inc., filed as a PAC with the FEC in 2013/14 where it spent over $160k to support James Lankford and Patrice Douglass and nearly $65k against TW Shannon.  SAGAC Public Affairs also operates the FEC-registered Advancing Freedom Political Action Committee (for 2021/22) and the Committee For Advancing Freedom (also for 21/22), though no expenditures or deposits are recorded in either to date of publication.

Advancing Freedom, Inc – which spent $214k opposing Oklahoma AG John O’Connor – ties to the Committee for Advancing Freedom by PO Box and that the organization’s books are listed as in care of Trey Richardson.  Advancing Freedom had nearly $200k in revenue from unknown sources and spent $13k in electioneering.

More on the Richardsons here.


Geoffrey Long operates an Oklahoma City law firm, GDL Legal PLLC.  Here, he provides his resume, which includes a three-year stint with the Oklahoma Ethics Commission.  Mr. Long also operates Redbud Reporting, an organization that provides Ethics reporting services for PACS and individuals.  He is in business with Roberta (‘Bert’) Hale, also a former employee of the Oklahoma Ethics Commission.

From a client perspective this should be a real asset.  Someone who knows the Ethics Commission rules and filing dates could be indispensable as a filing agent.  On the other hand, members of the public might be concerned that previous experience at the Ethics Commission could allow them to help clients ‘skirt’ the law, or bend it to make it work for their needs. 

What Is A Taxpayer To Do?

Hopefully, at this point – if you’ve read this far – you now know that many of the political consulting firms operating in Oklahoma have clear ethics questions.  What should the public think about a person who wishes to be elected to influence taxpayer dollars and laws yet uses a political consulting firm that has observable ethics issues or is somehow tied to a firm that has observable ethics issues?  Could it be that there is corruption at the Capitol because there is corruption surrounding it and through it?

If you want a change in Oklahoma politics, here are some steps:

  1. Do not vote for any candidate without knowing who runs their campaign.  If they are engaged with members or ancillaries of the Dark Money Web – do not vote for them. 
  2. Use the Oklahoma Ethics Commission website to research candidates and find out who is donating to them.  If they are getting donations from other lawmakers or PACs in large amounts – do not vote for them because they are already influenced by someone/something other than you.  (The factors surrounding Jake Merrick’s re-election campaign make this point in spades.)  If you like the candidate and feel they are simply naïve, ask them to return the donations before you’ll vote for them.
  3. During election season, if you see a mailer that’s ugly or misleading, look at the postage and “paid for by” section to see who’s sending it.  Use the internet to look them up.  If what you find concerns you, confront the candidate they are for.  If they don’t publicly come out against them don’t vote for them.
  4. Follow the Ethics Commission meetings and attend their meetings.  This is the group that oversees political campaigns in Oklahoma and watchdogs illegal activity.  What are they doing?  Are they doing enough?  What should we expect them to do?  These are all questions that need answers – they are our first line of defense against those who want to influence elections for their own gain and, apparently, way too much is getting through their guardrails.
  5. Above all realize this; we somehow began to think that Oklahoma is the ‘reddest state in the union’ – but we are not.  True Republicans can list at least 5 conservative principles off the tops of their heads at any given time.  Oklahomans have been propagandized to believe that an “R” means ‘conservative’, but it doesn’t.  If you’re not sure what to look for or ask about, here is the Oklahoma County Republican Party Platform.  It’s only a page.  Download it and ask candidates questions based on that platform.

Conservative PRINCIPLES make conservatives, not a letter designation.

If Oklahomans can’t begin to do these things on a WIDE level IMMEDIATELY, we’ll CONTINUE to lose our state to corrupt, unethical Democrats in Republican clothing all the while lulled to sleep believing we’re ‘safe’ here in Oklahoma, the ‘reddest state in the union’.