Secret Honorarium in a Horse’s Name - How Kristi Noem Enriched Herself With Political Donations

From the very beginning, everything seemed discreet - perhaps too discreet. A shell company in Delaware, named after one of her horses. A dubious nonprofit organization with barely any discernible purpose. And finally: $80,000 that flowed directly to Kristi Noem’s personal company - while she was still governor of South Dakota. Officially for fundraising. Unofficially for herself. And not listed on any official disclosure form.

Our investigation revealed: The American Resolve Policy Fund was founded in 2023 almost simultaneously with Noem’s personal company - just four minutes apart, both in Delaware. In its first full year, the organization reported around $1.1 million in revenue, according to tax records - of which approximately $220,000 was spent, one-third of it going directly to Ashwood Strategies. Officially, the reason given was that Noem had raised $800,000 in donations and received a fundraising fee of $80,000. Alarming: This income was not included in Noem’s required federal disclosure - even though she had already been nominated as Secretary of Homeland Security at the time. A potential violation of ethics regulations, according to several experts. While Noem’s attorney publicly claimed the filings were accurate and the ethics office had “reviewed everything,” there is no evidence of any actual disclosure of this financial transfer. The organization itself remains a shadow entity: no employees, barely any visible activity, and only 100 followers on X. Most of the money went to Noem - the rest to travel expenses, the purpose and recipients of which remain unclear to this day.

One more noteworthy detail: In the same year, Noem’s company Ashwood Strategies received an advance payment of $140,000 for her book No Going Back: The Truth on What’s Wrong with Politics and How We Move America Forward. The amount did not go to her personally but was deposited directly into the company’s account - an account that, according to disclosure records, held between $100,001 and $250,000. Additionally, agricultural assets worth at least $50,000 in livestock and equipment were reported - a sideline enterprise that raises questions about the entanglement of politics, business, and personal enrichment. Taken together, this paints the picture of a company used not only for fundraising transfers but also for book marketing and rural investments. The exact purpose of these activities remains unclear - as does oversight.

The ethical question is clear: any high-ranking politician who solicits political donations - and personally profits from them - steps outside the bounds of legitimate public service. Daniel Weiner, an attorney with the Brennan Center and former Federal Election Commission official, called the case “new and disturbing”: if donors not only finance a politician’s career but also their personal livelihood, a red line has been crossed. Noem, through her attorney, defends herself by saying she was merely a “service provider” for the nonprofit - with no control, no influence, no responsibility. But even that defense seems questionable, given that the company and the nonprofit were founded within the same minute. The only time the organization appeared publicly was in an ad campaign attacking a local newspaper in South Dakota that had reported critically on Noem’s use of government funds. Those expenses included trips to Paris, bear hunting in Canada, and dental work in Houston - all paid for with taxpayer money, according to media investigations. Noem denies any misuse of public funds. But the impression of an extravagant lifestyle remains: in April, her handbag was stolen at a restaurant in Washington - containing $3,000 in cash for “dinner, activities, and Easter gifts,” as it was officially stated. On a visit to a high-security prison in El Salvador - where migrants are now being deported under Trump’s policy - she wore a gold Rolex Daytona worth approximately $50,000.

The Ashwood Strategies affair only came to light when Noem was appointed Secretary of Homeland Security in the spring of 2025 - and had to disclose her finances. Until then, she had never revealed that she had founded a private business during her time as governor. A clear violation of transparency obligations, and possibly of state law: according to former South Dakota Senate President Lee Schoenbeck, governors are required to devote their full time to public service. “A secret side business is unacceptable,” he said. Whether Ashwood Strategies received further payments after 2023 remains unknown. Her attorney declined to answer questions on the matter. Nor is it clear whether the ethics office in Washington was ever informed about the $80,000 deal. But the damage is already done - politically, morally, and institutionally. Because this is not about a pony or a side hustle. It is about power, money, and the ability to intertwine the two - in the shadows of democracy.