Donald Trump’s penchant for turning his political and legal troubles into fundraising schemes has long been recognized, but the former US president’s money hustling tricks seem to have expanded since his defeat by Joe Biden, prompting new scrutiny and criticism from campaign finance watchdogs and legal analysts.

Critics note Trump has built an arsenal of political committees and nonprofit groups, staffed with dozens of ex-administration officials and loyalists, which seem aimed at sustaining his political hopes for a comeback, and exacting revenge on Republican congressional critics. These groups have been aggressive in raising money through at times misleading appeals to the party base, which polls show share Trump’s false views he lost the White House due to fraud.

Just days after his defeat last November, Trump launched a new political action committee, dubbed Save America, that together with his campaign and the Republican National Committee quickly raked in tens of millions of dollars through text and email appeals for an “election defense fund”, ostensibly to fight the results with baseless lawsuits alleging fraud.

The fledgling Pac had raised a whopping $31.5m by year’s end, but Save America spent nothing on legal expenses in this same period, according to public records. Run by Trump’s 2016 campaign manager Corey Lewandowski, Save America spent only $340,000 on fundraising expenses last year.

In another move, Trump last month announced he was filing class-action lawsuits against Facebook, Google and Twitter, alleging “censorship” due to bans by the platforms after the 6 January Capitol attack that Trump helped stoke. But several legal experts panned the lawsuits as frivolous and a fundraising ploy.

Trump’s new legal stratagem raised red flags, in part because he teamed up with America First Policy Institute (AFPI), a nonprofit group led by ex-White House official Brooke Rollins. At a press briefing with Trump, Rollins told supporters they could “join the lawsuit” by signing up on a website, takeonbigtech.org, a claim belied by details on the website which featured a red button with the words “DONATE to AFPI.”

“Donald Trump is a one-man scam Pac,” said Paul S Ryan, vice president of policy and litigation with Common Cause. “Bait-and-switch is among his favorite fundraising tactics,” Ryan stressed, noting that Trump’s Save America Pac told “supporters he needed money to challenge the result of an election he clearly lost, and then wound up not spending nothing any on litigation last year.

“Now he’s at it again, with frivolous lawsuits filed [in July] against Facebook, Twitter and Google, accompanied by fundraising appeals,” Ryan added. “This time he’s got the unlimited dark money group America First Policy Institute in on the racket.”

Other experts voice strong concerns about Trump’s tactics.

“The president deceived his donors. He asked them to give money so he could contest the election results, but then he spent their contributions to pay off unrelated debts,” said Adav Noti, a former associate general counsel at the Federal Election Commission and now chief of staff at the nonpartisan Campaign Legal Center.

Noti added: “That’s dangerously close to fraud. If a regular charity – or an individual who didn’t happen to be president of the United States – had raised tens of millions of dollars through that sort of deception, they would face a serious risk of prosecution.”

Such concerns have not deterred Trump’s fundraising machine from expanding further with the launch of a super Pac, Make America Great Again Action, which can accept unlimited donations. Both the Super Pac and Save America are run by Trump’s former campaign manager, Lewandowski.

The Super Pac has reportedly hosted at least two events for mega donors at Trump’s golf club in Bedminster, New Jersey, and in Dallas, but it’s not known how much has been hauled in so far. Both Pacs are seen as vehicles for Trump to raise more funds to influence 2022 congressional races, where he has vowed to defeat several politicians such as the anti-Trump Republican Liz Cheney, who voted to impeach him this year after the Capitol attack.

Campaign filings for the first six months of 2021 reveal that Trump’s political groups led by Save America raised $82m, an unprecedented total for a former president. Save America banked most of the funds while spending some to pay for Trump’s travel and other expenses, instead of challenging election results in states like Arizona, despite Trump’s false claims of fraud there.

Veteran campaign finance analysts say that the bevy of Trump-linked groups launched since his defeat raise new questions about his motives and political intentions.

“Trump’s aggressive fundraising, using a variety of committees and surrogates, raises questions about whether his continual hints at running in 2024 is primarily a ploy for donations,” said Sheila Krumholz, who leads the non-partisan Center for Responsive Politics. “Trump may be more interested in fundraising than actually running, especially given how unprecedented his post-loss fundraising is.”

Besides Trump’s fundraising pitches for his new Pacs and nonprofits, some major Republicans groups have collaborated in fundraising appeals since his defeat, and keep piggybacking on his allure to the party base, despite Trump’s repeated falsehoods that the election was stolen.

In the eight weeks post-election, for instance, the RNC, the Trump campaign and Save America reportedly raised about $255m, but spent only a small fraction on lawsuits. Further, Trump’s cachet with small donors is still exploited by party allies, including the National Republican Senatorial Committee, (NRSC) the fundraising arm for Republican senators.

For instance, the NRSC in July email fundraising pitches touted a free Trump T-shirt for a limited number of donors writing checks from $35 to $5,000 to “protect the America First Majority.”

Similarly, the RNC in a 19 July email alert rolled out a money pitch to become an “official 2021 Trump Life Member” for donors who chipped in $45 or more by midnight.

Charlie Black, a longtime Republican operative, said that Republican committees realize that Trump’s “name has the most popular appeal to the grassroots, so naturally they’re going to try to figure out ways to use his brand where they can to raise more funds.”

But legal analysts caution that Trump’s new fundraising modus operandi are different, and carry clear risks for unwitting donors and US campaign finance laws.

“Our nation’s campaign finance and anti-fraud laws have proven no match for Trump’s schemes,” said Ryan of Common Cause. “So my one piece of advice for Trump supporters, is donor beware.”

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