Internal All-Staff · Compliance Training

Don't Write Checks
the Books Can't Cash

The plain-English guide to what you can say, what you can't, and why the copy is always the evidence.

Cheering vs. Cheating
The only line that matters
A specific fact someone could check vs. an impression
CHEERING — Always Fine
Emotional urgency & volume
Say it as loud as you want
Feeling-based claims
"This is the most important race in the country"
Competitive framing
"The other side is coming for everything you care about"
Real deadlines
Fine as long as a real event actually happens
CHEATING — Never Fine
Match claims with no real matcher
Real person, real commitment, in writing, cap disclosed
"100%," "every penny," "goes straight to"
Specific & auditable — if wrong, that sentence is a trap
Fake deadlines
"Expires at midnight" with no real event behind it
Donor counts that aren't real
"Only 100 left" sent to 400,000 people
Wire Fraud — The Four Elements
Element 03 is pre-checked before we write a word
Untrue material statement
A specific false claim — not a vague impression. A stated fact someone could verify against your books.
Intent or willful blindness
You knew it was false — or deliberately didn't find out. "I didn't ask" is not a defense.
03
Used the internet or phones
Email. Text. Donate page. Every send checks this box. This guardrail is gone before we write a word.
Always pre-checked
Got money
Someone gave based on the false claim. Up to 20 years per count. Prosecutors count by the message, not the campaign.
What Actually Happened
Two real cases — stripped to the lessons
Draft PAC — Jack Daly
The claim outlasted the candidate

$1.6M raised to convince a candidate to run. He publicly said he wasn't running. Emails kept going anyway.

Result: federal prison, $70K restitution, law license permanently revoked.

We Build the Wall — Bannon et al.
The promise created the liability

$15–25M on "not a penny to salaries." Hundreds of thousands went to associates anyway.

Federal pardon — then NY indicted. Co-defendants: 3+ years. Bannon: felony plea, banned from charitable fundraising.

Lesson 1 · The Crime

It was one sentence in an email. No forged checks. No stolen cards. One false specific claim sent over the internet, to which money moved. The copy was the evidence.

Lesson 2 · The Aftermath

A pardon isn't a shield — 50 states have prosecutors. In Bannon's NY plea: he cannot use, sell, or even possess the donor data. Courts reach for the list. Our list is the most valuable thing we have.

Three Questions. Every Send.
90 seconds. No exceptions.
01
Can I Prove It?
The Receipt Test

Every fact has a document behind it today — not a memory, not "someone said." Match: who's matching, how much, in writing, cap disclosed. Deadline: what real event happens? Stat: where's the source? Can't produce the receipt in 5 minutes → the claim doesn't ship.
02
Would They Feel Tricked?
The Donor Test

Picture a real donor. 72 years old. Fixed income. Gave $25 because she believes in this. Now show her exactly where her $25 went. Does she nod — or does she feel dumb? If she'd feel embarrassed for trusting us, we did something wrong.
03
Would I Read It Out Loud?
The Room Test

This exact email projected on a screen, read aloud slowly, in a room full of strangers with every reason to think the worst of us. Some copy sounds fine in a doc and terrible out loud. When that happens, you already know. Trust it.
If any of the three feels off — say something. Asking is never annoying.
The Bottom Line
Nothing in this training limits tone, urgency, emotion, or volume — it limits specific checkable claims that aren't true.
WRITE THIS WAY
Write hard. Write urgent. Write loud. Cheer as loud as you want — that's the job.
Volume, emotion, urgency, competitive framing — all fine, all the time.
Ask questions. Raise concerns. Asking is never annoying.
NEVER WRITE THIS WAY
A match with no real matcher. If the uncle doesn't exist, you don't have a match. You have a sign about an uncle.
"100%," "every penny," "goes directly to the candidate." Precise = checkable = dangerous if wrong.
Deliberately not finding out. If you have a feeling a claim won't hold up and decide not to check — that decision is the problem.
CHEER LOUD. STATE FACTS.
1 · Can I prove it?    2 · Would she feel tricked?    3 · Would I read it out loud?   —   The copy is the evidence.