Per Aspera Policy

Per Aspera Policy is a 501(c)(4) social-welfare organization tied to Peter Thiel that steered approximately 200,000 dollars to the Protect Ohio Values super PAC supporting the JD Vance 2022 Ohio Senate primary campaign, alongside Thiel's approximately fifteen million dollars in direct super-PAC contributions. OpenSecrets reported the transfer in February 2022 as part of its analysis of dark-money spending in the 2022 election cycle. The 501(c)(4) form permits political spending without donor disclosure, which is the structural feature that distinguishes the Per Aspera vehicle from the disclosed super-PAC spending.¹²

The 501(c)(4) Structure and the Disclosure Gap

501(c)(4) organizations are designated under the Internal Revenue Code as social-welfare organizations. They are permitted to engage in political activity, including independent expenditure in support of or opposition to candidates, without disclosing their donors to the public. The only disclosure required is to the IRS on the annual Form 990, and even that disclosure is subject to redaction for donor-identity protection. The structural consequence is that a 501(c)(4) can transfer funds to a super PAC, which must disclose its receipts, without revealing the original source of the funds.¹³

The Per Aspera-to-Protect Ohio Values transfer follows this structure. The super PAC disclosed that it received approximately 200,000 dollars from Per Aspera Policy. Per Aspera Policy did not disclose its donors. The identity of the individuals or entities that funded the 200,000 dollar transfer beyond the Per Aspera vehicle is not part of the public record.¹

The Leonard Leo Parallel

The Per Aspera Policy vehicle operates in the same 501(c)(4) dark-money ecosystem as the Leonard Leo-linked vehicles (the Judicial Crisis Network / Concord Fund network) that directed approximately one billion dollars into the conservative judicial-selection project. The JCN brought in nearly 48.1 million dollars in a single reporting period to support the Gorsuch, Kavanaugh, and Barrett confirmation campaigns, per Citizens for Responsibility and Ethics in Washington. The Leo-linked and Thiel-linked vehicles use the same 501(c)(4) structure to fund political and institutional activities whose donor base is not publicly traceable.²⁴

The Thiel and Leo networks share the Teneo Network institutional terrain through Evan Baehr, who founded Teneo in 2008 and who moved in the Thiel orbit before the founding. Both networks fund through 501(c)(4) vehicles that transfer to super PACs (the Per Aspera-to-Protect Ohio Values transfer mirrors the JCN-to-confirmation-campaign transfer), and both operate through the Teneo Network for the broader institutional-placement function. The Senate Judiciary Committee under Chairman Dick Durbin sought Leo's records and testimony on the JCN network; Leo declined to comply.²⁴