The Consultant Behind 'Decoy Dan' Sits on the Board of a Dark-Money Group Attacking Sen. Sullivan

The Democratic consultant who helped launch the "other" Dan Sullivan's Senate campaign was sitting on the board of a liberal group that was running ads against the real one at the same time. That is not a rumor. It is in the State of Alaska's own corporate records and in the other Sullivan's campaign finance reports.

Anchorage consultant Amber Lee is listed as a director and secretary of 907 Initiative, a 501(c)(4) nonprofit that does not have to name its donors, on the group's 2026 biennial report filed with the state on May 1. Two conservative watchdogs now say that overlap may have broken federal law. Americans for Public Trust laid it out in a complaint to the Federal Election Commission on Sept. 8. The American Accountability Foundation followed with a referral to the U.S. Attorney in Alaska on Oct. 7.

Lee and 907 Initiative both deny doing anything wrong. No regulator or court has found a violation, and no one has been charged.

She worked for the campaign

The other candidate is Daniel J. Sullivan Jr., a retired Petersburg schoolteacher whose name sits on the ballot right above Republican Sen. Dan S. Sullivan's. His own FEC filings show what Lee's firm did for him. His pre-primary report lists $4,380.41 owed to Amber Lee Strategies for "Website Services and Campaign and Digital Consulting."

His October report, amended Oct. 22, shows the bill was paid. The campaign sent Amber Lee Strategies $4,380.41 on Aug. 12 for "Digital/Admin Services & Reimbursement," according to the filing. That was six days before the Aug. 18 primary, and around the time Lee told reporters she was no longer involved in his campaign. The same report shows three payments totaling $13,791 to Caplin & Drysdale, a Washington law firm, for "Legal and Compliance Services."

Her group was attacking his opponent

Americans for Public Trust says 907 Initiative has spent nearly $1.5 million against the senator this cycle, about $575,000 of it in the 90 days before the primary. Federal rules treat that 90-day stretch as a window in which outside ads naming a candidate can count as coordinated with a campaign, and the complaint says it opened May 20.

Station records back up the scale. A KTUU invoice in the FCC's public file shows 907 Initiative bought 119 spots that aired June 3 through 9, for $112,365. The American Accountability Foundation counted about $448,000 in 907 Initiative ads naming the senator in the pre-primary window, using only the spending it could verify from public records. It notes that 907 Initiative's own 2024 tax return reported total revenue of $793,705 and year-end net assets of just $32,549.

The timing is what jumps out. The other Sullivan's campaign website, sullivanforsenate.com, was registered May 28, according to the domain registry's own record. Americans for Public Trust says 907 Initiative's first ad against the senator, "Stop Raising Costs," aired that same day. The other Sullivan announced his campaign on May 29.

What the watchdogs allege

Under FEC rules, an outside group's ad becomes an illegal in-kind contribution when three things line up. Someone other than the campaign pays for it, it names a candidate inside the window before an election, and certain conduct ties the spender to the campaign. That conduct can include a campaign agent being "materially involved" in the ad, or the spender using a contractor who worked for the campaign within the previous 120 days.

Americans for Public Trust says all three are met. Lee, it argues, was a paid contractor for one campaign while serving as an officer of a group attacking that campaign's opponent, and it says she helped the other Sullivan file to run and "helped author some of Dan J. Sullivan's campaign materials." Because 907 Initiative is a corporation, the complaint says any coordinated spending would be a prohibited corporate contribution, "hundreds of thousands of dollars in illegal campaign contributions."

The American Accountability Foundation goes further. Its referral says the National Republican Senatorial Committee sent Lee a written demand to preserve her records on June 1 and named her in FEC complaints filed June 6 and June 10, and that her dual roles continued after that notice. It points to Alan Harris, whom it calls Lee's partner, citing published reporting. Alaska's filing record shows Harris delivered the other Sullivan's declaration of candidacy as his representative on June 1, the referral says, and about two weeks later Harris appeared as "Alan" from Anchorage in a Majority Forward TV ad criticizing the senator.

Majority Forward is a national 501(c)(4) that says on its own website it works with "an affiliated super PAC, Senate Majority PAC," the main super PAC for Senate Democrats. The referral says the same 30-second "Stop Raising Our Costs" ad ran under both a Majority Forward disclaimer online and a 907 Initiative disclaimer on broadcast TV. It counts about $3.55 million in Majority Forward ads in the pre-primary window. A Senate Majority PAC spokesman has said neither group "has ever communicated with Dan J. Sullivan, directly or indirectly," and that both were unaware the man in the ad was involved with his campaign, the referral notes.

AAF says it "makes no finding that any person has violated the law." It asks prosecutors to subpoena the records that would settle it: who wrote, approved and paid for the ads, and what Lee and Harris said to whom.

What they say

"This allegation misrepresents both my role and how independent expenditures operate," Lee told the Alaska Beacon in September. "I serve as an unpaid member of the 907 Initiative board. I am not an employee of the organization, and I do not manage its independent expenditure activity. The limited support I provided for Dan Sullivan as a consultant did not violate campaign finance laws."

Aubrey Wieber, 907 Initiative's executive director, said the group "is in full compliance with applicable campaign finance laws, including federal coordination rules," and called the allegations an effort "to distract from Senator Sullivan's record." The other Sullivan has said, "My intention is not to trick people."

Why the FEC can't act, and who can

The FEC itself can't touch the complaint right now. It has lacked the four commissioners it needs to open investigations or issue penalties since 2025, and only two commissioners, both Democrats, remain. Trump nominated two Republicans in February, but the Senate has not confirmed them. The FEC's quorum loss does not limit the Justice Department, which can bring criminal cases on its own, according to the Congressional Research Service. Federal law makes knowing and willful violations of $25,000 or more a felony.

That is where the case is moving. FBI agents interviewed donors to the other Sullivan's campaign in Petersburg on Saturday, the Associated Press reported Monday, and federal prosecutors have issued at least three dozen subpoenas and records demands since The New York Times reported that Peltola's aides searched for a second Dan Sullivan, as we reported. Gov. Mike Dunleavy has ordered a state investigation.

In the Aug. 18 primary the other Sullivan drew 4,107 votes, 2.47%, according to the Division of Elections, with almost no campaign at all. Election Day is Tuesday. The senator's message to voters hasn't changed: check the middle initial. The real one is Dan S. Sullivan.