PIERRE, S.D. (KELO) — The Noem Victory Fund that the governor set up two years ago at the federal level had an unusual benefit: It allowed contributors to get around South Dakota’s campaign-finance laws.

People who gave money to the joint fundraising committee were able to contribute more than the $4,000 annual limit that South Dakota law allows a person or entity to donate to a statewide candidate for election.

These donations often were in addition to money that many of them gave directly to her re-election committee and in some instances to a separate federal political action in her name.

Altogether, Noem Victory Fund in 2021-2022 received $798,500 from South Dakota contributors and $3,557,444.46 nationwide. The FEC received a termination report for the joint fundraising committee on January 5, 2023, showing final disbursements totaling $632,419.65.

Twenty-five South Dakota people and three business entities contributed at least $5,000 apiece and in some cases as much as $25,000 — and in one instance a combined $42,000 between a person and his farm — to the Noem Victory Fund in 2022, according to Federal Election Commission records. During the prior year, 24 South Dakotans and two business entities contributed at least $5,000 apiece to the fund.

Besides allowing South Dakotans and their entities to sidestep the South Dakota contribution limits, Noem Victory Fund served as a channel to re-direct money from contributors outside South Dakota into the campaign accounts for Noem and her lieutenant governor, Larry Rhoden.

State laws allow unlimited transfers to a candidate’s committee or another political action committee from a political action committee, the state political party or another candidate’s committee. Noem Victory Fund transferred nearly all of the money it received to five designated political accounts:

Her state-level campaign committee, Kristi for Governor., received five transfers totaling $1,530,549.15.

Her running mate’s state-level campaign committee, Rhoden for Lt. Governor, received five transfers totaling $502,630.03.

Her committee that funds legislative candidates, SD Strong Leadership PAC, received five transfers totaling $492,445.58.

Her federal-level KRISTI PAC (Keeping Republican Ideas Strong Timely & Inventive) received four transfers totaling $350,991.93.

And the South Dakota Republican Party received five transfers totaling $125,901.59.

South Dakota laws also set limits on amounts that a person or entity can contribute in a year to other political activities. For a legislative or county candidate, it is $1,000. For a political action committee, it is $10,000. And for a political party, it is $10,000.

KELOLAND News requested comment from the governor’s office Monday morning. We will update this story when it is received.

Noem Victory Fund paid $121,942.40 for events at Scattergun Lodge, which promotes itself as “South Dakota’s Ultimate Pheasant Hunt” and is owned by Charles and Sheila Ross. The fund also paid $97,549 to Omaha, Nebraska-based financial consultant JBest & Company; and $71,949.35 to Livonia, Michigan-based financial consultant Templar Baker Group.

Other expenses included $47,677.95 to WinRed, which describes itself as “the #1 fundraising technology used by conservatives,” and $31,636.65 to Broghamer Consulting, a Newport, Kentucky firm headed by Kevin Broghamer. He is listed as treasurer for Noem’s Kristi For Governor committee and for her SD Strong Leadership PAC; Steve Kirby of Sioux Falls, a former lieutenant governor, is listed as the chair for both.

South Dakota contributors gave the most money to the Noem Victory Fund, according to FEC records. Contributions came from across the nation, including Texas $701,179.90; California $304,324.50; Florida $280,244.50; Colorado $170,418.16; Nevada $153,528.50; Tennessee $120,330.50; and 38 others, including $7,500 from the District of Columbia and $5,000 from Puerto Rico.

Noem was South Dakota’s one member in the U.S. House of Representatives when she ran for governor in 2018. She used a similar approach of a federal joint fundraising committee in 2017-2018, with the Noem-Rhoden Victory Committee raising and disbursing $704,955 in that election cycle. Most of that money also was eventually transferred to their political accounts.

Here’s a list of South Dakota persons and entities who contributed $5,000 or more to Noem Victory Fund during the past two years. Some people gave several times in the same year; in those instances, dates reflect the last contribution in that year.

• CHRIS BRO 4 LLC — $10,000 November 8, 2022 (Harry Christianson, Craig Christianson, Rapid City) 
• Shawn Gengerke, Groton — $17,000 November 5, 2022 
• Shawn Gengerke Farms, Groton — $25,000 November 5, 2022 
• Nathan Reede, Aberdeen — $25,000 November 5, 2022 
• Robert Fouberg, Aberdeen — $25,000 November 5, 2022 
• Sharon Rivett, Aberdeen — $25,000 November 2, 2022 
• Cynthia Jewett, Aberdeen — $25,000 November 2, 2022 
• Jami Hennrich, Arlington — $5,000 October 31, 2022 
• Leeann Reiman, Rapid City — $25,000 October 16, 2022 
• Dana Dykhouse, Sioux Falls — $10,000 October 16, 2022 
• Jalayna Haug, Lake Norden — $5,000 October 13, 2022 
• Zach Neugebauer, Sioux Falls — $5,000 October 12, 2022 
• Todd Huntimer, Arlington — $5,000 October 11, 2022 
• Brad Henrich, Arlington — $5,000 October 10, 2022 
• Tim Kessler, Aberdeen — $5,000 September 27, 2022 
• Joel Jansen, Tea — $5,000 September 19, 2022 
• Steve Boote, Sioux Falls — $5,000 May 22, 2022 
• Larson Livestock Inc, Columbia — $5,000 May 21, 2022 (President Alfred Larson) 
• Preston Steele, Huron — $5,000 May 18, 2022 
• Scott Erickson, Sioux Falls — $5,000 May 18, 2022 
• Jeff Erickson, Sioux Falls — $5,000 May 18, 2022 
• Micah Aberson, Sioux Falls — $5,000 May 18, 2022 
• Ronald Rivett, Aberdeen — $25,000 May 16, 2022 
• Harvey Jewett IV, Aberdeen — $25,000 May 16, 2022 
• Michael Evans, Aberdeen — $25,000 May 16, 2022 
• James Thares, Aberdeen — $25,000 April 28, 2022 
• Rodney Peter Burwell, Sioux Falls — $21,000 March 31, 2022 
• Dan Lederman, Dakota Dunes — $5,000 March 14, 2022 
• Cimarron Label, Sioux Falls — $5,000 December 31, 2021 (President Randy Cowan) 
• Clint Ackerman, Sioux Falls — $5,000 December 16, 2021 
• Thomas P. Walsh Sr., Sioux Falls — $5,000 December 2, 2021 
• Judson Pins, Sioux Falls — $5,000 December 2, 2021 
• Gene Jones Jr., Sioux Falls — $5,000 December 2, 2021 
• Jerry’s Chevrolet of Bereseford — $5,000 December 2, 2021 (Owner Jerry Barr) 
• Dana Dykhouse, Sioux Falls — $5,000 December 2, 2021 
• David Bockorny, Sioux Falls — $5,000 December 2, 2021 
• Scott Erickson, Sioux Falls — $5,000 November 25, 2021 
• Brian Gunderson, North Sioux City — $5,000 November 23, 2021 
• Zach Neugebauer, Sioux Falls — $5,000 November 15, 2021 
• David H. Billion, Sioux Falls — $5,000 November 14, 2021 
• Scott Jones, Sioux Falls — $5,000 November 11, 2021 
• Tom Everist, Sioux Falls — $10,000 November 11, 2021 
• Duane Sather, Sioux Falls — $5,000 November 10, 2021 
• Pierce H. McDowell III, Sioux Falls — $5,000 November 10, 2021 
• Jon Jorgenson, Sioux Falls — $5,000 November 10, 2021 
• Travis Behrens, Sioux Falls — $5,000 November 10, 2021 
• Jeff Erickson, Sioux Falls — $5,000 November 9, 2021 
• Greg Carmon, Brandon — $5,000 November 2, 2021 
• Eric Yunag, Sioux Falls — $5,000 November 1, 2021 
• Jay Van Voorst, Sioux Falls — $5,000 October 29, 2021 
• Vance Thompson, Sioux Falls — $5,000 October 29, 2021 
• William Metz, Dakota Dunes — $25,000 August 18, 2021 
• Lynn Persinger, Dakota Dunes — $5,000 August 15, 2021 
• David Bailey Aalfs, Dakota Dunes — $5,000 August 15, 2021