Watchdog Group Makes DOJ Referral Over Alleged Election Law Violations In Pivotal Senate Race

The nonprofit group American Accountability Foundation on Wednesday submitted a 114-page referral to the U.S. Attorney for the District of Alaska. The filing asks prosecutors to review whether organizations that funded advertising in the state’s U.S. Senate race violated federal election law through coordinated expenditures or contributions made in the name of another, particularly in the case of a man with the same name as Republican incumbent Dan Sullivan.

The referral centers on activity linked to Dan J. Sullivan, a candidate who shares a name with incumbent Republican Senator Daniel S. Sullivan. Republican officials have contended that the similarly named candidacy could affect the senator’s vote totals in a race that also includes Democrat Mary Peltola.

Alaska conducts a nonpartisan primary in which the top four candidates advance to a ranked-choice general election. State election officials previously removed Dan J. Sullivan from the ballot after determining the filing was not made in good faith, though a state judge later reversed that decision.

The October submission expands on a September referral to the Federal Election Commission by Americans for Public Trust. That complaint addressed Amber Lee, a Democratic strategist who performed work for the Dan J. Sullivan campaign while serving as a board member of the 907 Initiative, which paid for advertisements critical of Senator Sullivan.

Materials estimate the 907 Initiative’s relevant advertising at roughly $450,000 to $500,000. Lee has denied that the dual role violated the law.

The organization has denied the allegations. “This allegation is patently false. 907 Initiative has never employed or paid Amber Lee. Amber Lee is a board member of 907 Initiative. The fact that Americans for Public Trust can’t decipher the difference between those two tells you all you need to know,” a spokesperson for the 907 initiative previously told The New York Post.

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Independent watchdog makes DOJ referral over alleged election law violations in Alaska Senate race https://t.co/LHNoZ8Weun

— John Solomon (@jsolomonReports) October 7, 2026

The American Accountability Foundation also identifies Majority Forward, a Washington, D.C.-based 501(c)(4) affiliated with Senate Majority PAC, together with the Midnight Sun Independence Fund and Midnight Sun PAC. According to the referral, nearly identical video advertisements criticizing Senator Sullivan carried different disclaimers — one stating “Paid for by Majority Forward” and another “Paid for by 907 Initiative” — while using the same footage, graphics, and the telephone number 202-224-3004 beneath the line “Tell Dan Sullivan: Stop Raising Our Costs.”

A separate healthcare advertisement appeared in public records under both Majority Forward and the Midnight Sun Independence Fund. The foundation places Majority Forward’s spending on publicly disclosed communications in the 90 days before the primary at a minimum of $3.5 million.

Corporate records cited in the referral list the address 1032 15th Street NW, Suite 247, Washington, DC 20005, for both the Midnight Sun Independence Fund and Majority Forward. A filing showed a $100,000 contribution from the fund to Midnight Sun PAC on July 14, 2026.

The materials further note personnel overlaps, including Christopher Koob’s positions with Majority Forward and a related 907 entity, and an advertisement that featured Alan Harris. Harris delivered Dan J. Sullivan’s declaration of candidacy on June 1; the Majority Forward spot began airing on June 16.

Federal law treats an expenditure coordinated with a candidate as a contribution to that candidate. Proving coordination generally requires evidence that someone other than the campaign paid for a communication identifying a federal candidate inside the applicable pre-election window, plus conduct connecting the payer to the campaign, such as shared vendors, staff, or contractors. A separate statute provides that no person shall make a contribution in the name of another person or knowingly permit his name to be used to effect such a contribution.

The referral asks prosecutors to examine communications among the named individuals and organizations from January 1 through August 18, 2026, and references these provisions.

Prosecutors were already reviewing whether Dan J. Sullivan entered the race in order to confuse voters. NBC News reported this past August that a grand jury had issued subpoenas in that inquiry.

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