An independent watchdog has delivered a 114-page referral to federal prosecutors in Alaska, alleging a web of nonprofits and PACs illegally coordinated ads to damage Republican Sen. Dan Sullivan and boost a same-name challenger, claims Democrats and the groups deny.
The American Accountability Foundation told the U.S. Attorney for the District of Alaska that a network of Democratic-aligned groups may have coordinated contributions, contributed in the name of another, or illegally shared infrastructure in a negative ad campaign aimed at incumbent Republican Senator Daniel S. Sullivan.
AAF delivered the referral on Wednesday. It centers on ads tied to groups including the 907 Initiative, Majority Forward, the Midnight Sun Independence Fund, and Midnight Sun PAC, and on candidate Dan J. Sullivan, whose nearly identical name Republicans have long said was meant to siphon votes from the incumbent and help Democratic opponent Mary Peltola.
Federal prosecutors were already looking at whether Dan J. Sullivan entered the race to confuse voters. A grand jury issued subpoenas in August, shortly before Alaska’s nonpartisan primary. The new referral widens that scrutiny to the money and messaging machine around him.
AAF says it found two versions of a nearly identical video ad. One carried the disclaimer “Paid for by Majority Forward.” The other said “Paid for by 907 Initiative.” Both used the same footage, graphics, and call-to-action number, 202-224-3004, and both told viewers: “Tell Dan Sullivan: Stop Raising Our Costs.”
Another healthcare-cost ad featuring the same speaker, script, and graphics appeared once as “Paid for by Midnight Sun Independence Fund” and once as “Paid for by Majority Forward,” according to the referral. Google Ads Transparency Center data cited by AAF listed Majority Forward as the verified advertiser on video ads whose on-screen text said they were paid for by the Midnight Sun Independence Fund. One of those spots, urging Sen. Sullivan to stop protecting “out-of-state trawlers,” ran from July 2026 into September 2026.
Under federal law, coordinated expenditures count as contributions to a candidate. Prosecutors look at payment, content, and conduct. AAF argues the overlapping creative, shared infrastructure, and personnel ties meet those tests and warrant a full probe. Election integrity fights have sharpened nationwide, from state charges over illegal voting to federal monitors under review in other states.
The Midnight Sun Independence Fund listed its address as 1032 15th Street NW, Suite 247, Washington, DC 20005, the same street address and suite Majority Forward has claimed in corporate records. Midnight Sun PAC reported a $100,000 contribution from the Midnight Sun Independence Fund on July 14, 2026. AAF questions whether the PAC served as a conduit.
Christopher Koob appears as both a director of Majority Forward and treasurer of 907 Initiative Action, the super PAC tied to the 907 network. AAF treats that dual role as a bridge between the operations.
Majority Forward is a D.C.-based 501(c)(4) advocacy group affiliated with Senate Majority PAC, the vehicle long tied to Senate Democrats. AAF’s low-end estimate puts Majority Forward’s Alaska spending at least $3.5 million in the 90 days leading up to the primary, inside the coordination window on public airwaves and certain digital platforms. The 907 Initiative’s own ad blitz criticizing the incumbent ran about $450,000 by AAF’s count, with earlier material putting the figure near $500,000.
Those dollar figures matter because Alaska’s open primary advances the top four candidates to a ranked-choice general election in November. Small shifts in name recognition or ballot confusion can change who makes the cut.
Republicans have argued Dan J. Sullivan ran as a Republican specifically to pull votes from the incumbent and improve Mary Peltola’s odds. The Alaska Republican Party asked state election officials to remove him from the ballot. The Division of Elections did so. A state judge later overruled that decision and put him back on.
Alan Harris, described as an Anchorage mover, delivered Dan J. Sullivan’s declaration of candidacy to state officials on June 1. A Majority Forward ad featuring Harris began airing June 16. Harris is also identified as the boyfriend of Amber Lee, a veteran Democratic strategist who sits on the 907 Initiative board.
Earlier material from Americans for Public Trust, which filed its own FEC referral last month, said Lee was working for the Dan J. Sullivan effort while 907 ran its ad campaign against the incumbent. Lee has denied that arrangement violates the law. AAF contends her dual role supplies the conduct prong that should trigger a coordination investigation.
A spokesperson for the 907 Initiative previously told The New York Post the employment claim was false.
"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."
Senate Majority PAC issued its own denial of any link to the same-name candidate.
"Neither Senate Majority PAC nor Majority Forward has ever communicated with Dan J. Sullivan, directly or indirectly, nor did Senate Majority PAC encourage him to run or have any involvement in his campaign."
Federal law also bars contributions in the name of another. The statute language cited in the coverage states 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. AAF says the shared creative, addresses, officers, and timing raise exactly those questions for prosecutors already sitting on a grand jury investigation.
Americans for Public Trust’s FEC filing last month focused on the Lee, 907 overlap and the ad spending. AAF’s thicker DOJ package now asks local Justice Department prosecutors to examine communication and coordination across the full network. No arrests or charges from this referral have been announced. The document itself is the ask: open the books and test the evidence.
Voters watching Senate control already see election-security fights play out in real time, including recent Senate clashes over voter ID and related integrity measures. Alaska’s ranked-choice system and same-name candidacy only raise the premium on clear rules and honest disclosure.
State officials and parties have already fought over ballot access for Dan J. Sullivan. Federal investigators have already issued subpoenas on the voter-confusion theory. The watchdog referral adds the money trail, the ads that look the same, the addresses that match, the officers who overlap, and the spending that landed inside the coordination window.
Majority Forward’s Google-verified advertiser status on spots that carried another group’s disclaimer is the kind of paper trail prosecutors can check without relying on anyone’s press statement. So is the $100,000 transfer from the Midnight Sun Independence Fund to Midnight Sun PAC, and the dual listing for Christopher Koob.
Elsewhere, election administration disputes continue to surface in the courts and in statehouses, including a Missouri election integrity director’s retaliation suit and calls in other states for probes of federal election monitors. The Alaska referral fits that larger pattern: outside groups documenting what they say are coordination and disclosure failures and putting the evidence in front of prosecutors.
AAF’s package is 114 pages with exhibits. It does not, by itself, charge anyone. It asks the U.S. Attorney’s office to determine whether the network crossed from parallel messaging into illegal coordination or name-of-another contributions while trying to weaken Sen. Daniel S. Sullivan’s path through Alaska’s open primary and ranked-choice general.
The groups named have denied the core claims. 907 draws a bright line between board service and employment for Amber Lee. Senate Majority PAC and Majority Forward say they never communicated with Dan J. Sullivan or pushed him into the race. Those denials are now part of the record prosecutors can weigh against the ad matches, address overlap, officer ties, and spending totals.
Dan J. Sullivan’s ballot status was restored by a judge after state election officials removed him at the Alaska Republican Party’s request. The federal grand jury work on the confusion theory was already under way before AAF’s Wednesday filing. The new referral does not replace that investigation; it supplies a longer paper trail on the nonprofit and PAC side.
For a national reader, the mechanics are straightforward. Alaska lets every candidate run in one primary. The top four advance. Voters then rank choices in November. A second “Dan Sullivan” on the ballot, heavy identical advertising from groups that share addresses and officers, and a Democratic nominee waiting in the wings create an obvious incentive structure. Federal law is supposed to police coordination and straw contributions so that incentive does not become a loophole.
AAF says the evidence meets the payment, content, and conduct standards that turn independent spending into regulated contributions. The groups say the claims are false and that board membership is not employment. The U.S. Attorney’s office now has both the 114-page referral and the earlier FEC filing to sort out.
Clean elections require more than slogans. When the same ad runs under two disclaimers, when the same D.C. suite shows up on related filings, and when a same-name candidacy already sits under grand jury subpoena, prosecutors are the right place for the file, not another round of press releases.
