Kristi Noem

Noem was confirmed as DHS Secretary on January 25, 2025, and dismissed on March 5, 2026 — the first Cabinet departure of the second Trump administration. The proximate cause was a Senate hearing in which she testified that President Trump had personally approved a $220 million DHS advertising campaign. The White House publicly contradicted her, stating that 'POTUS did not sign off on a 220 MILLION dollar ad campaign' ¹. Sen. Markwayne Mullin was named as her replacement.

The advertising program had drawn scrutiny before the Senate confrontation. DHS designated a border enforcement emergency to bypass competitive bidding requirements and limited the work to four selected contractors. Strategy Group — whose chief executive is married to Tricia McLaughlin, Noem's former spokesperson — received subcontracted work on the campaign. Noem separately selected contractors for a $100 million ICE recruitment campaign. According to ProPublica, Noem misled Congress about a top aide's role in the contract awards ⁵.

Contracts awarded through Safe America Media LLC — a company formed eight days before its first DHS award — totaled at least $100.8 million across three task orders: $60.8 million in February 2025 for the 'Stronger Borders, Stronger America' campaign, $30 million in August 2025 for a second task, and $10 million in August 2025 for ICE recruitment (USASpending award IDs: 70RDA225FR0000009, 70RDA225FR0000034, 70CMSW25FR0000082) ⁵.

Noem's Form 278 nominee disclosure (ProPublica TrumpTown slug: noem-kristi, doc_id 2766) reported a net worth range of $520,011 to $1,175,000. Personal assets consisted primarily of retirement accounts at Schwab, Vanguard, T. Rowe Price, Fidelity, and American Balanced. Through her spouse, the household held Noem Insurance LLC, Noem Properties LLC, and Pierre Car Wash LLC, with at least $2 million in combined value across those entities ².

Ashwood Strategies LLC was registered in Delaware in June 2023, with Noem as managing member. American Resolve Policy Fund — a 501(c)(4) nonprofit — was incorporated the same day, four minutes later. American Resolve paid Ashwood $80,000 in 2023 as a fundraising fee on $800,000 raised, and $137,842 in 2024 for continued fundraising consulting — a 70 percent increase year-over-year. Neither payment appeared on Noem's federal financial disclosure form. The Citizens for Responsibility and Ethics in Washington confirmed the omission through independent review, and ethics law experts told ProPublica that the non-disclosure was a likely violation of the Ethics in Government Act ^{3 4}.

Delaware registry filings document the same-day incorporation of Ashwood Strategies and American Resolve Policy Fund, four minutes apart. American Resolve's stated purpose was promoting Noem's political career. The $80,000 payment in 2023 represented approximately 62 percent of her roughly $130,000 annual governor's salary at the time ³.

In June 2025, Noem issued a directive lowering the DHS contract review threshold from $20 million to $100,000, requiring her personal sign-off on a far larger number of awards. A POGO investigation subsequently identified at least five contracts in the range of $99,999 to $99,999.99 awarded after that directive — a pattern that POGO described as consistent with deliberate structuring to avoid the review requirement ⁶.

One of those sub-threshold contracts was a $99,999.99 USCIS award to Palantir Technologies for phase zero implementation of the VOWS platform (Vetting of Wedding-based Immigration Schemes). Palantir's contracting history at DHS has followed a pattern of low-dollar initial awards that establish incumbency before larger follow-on contracts, according to POGO reporting ⁶.

Corey Lewandowski, serving as an unpaid SGE and de facto chief of staff, appeared as the final political appointee checkpoint on contract routing sheets for awards over $100,000, according to internal DHS documents obtained by ProPublica. Noem told the Senate Judiciary Committee that Lewandowski had 'no' role in contract decisions; the routing documents showed his name last on approval checklists ⁵. Lewandowski declined to disclose his outside income or clients, and American Oversight filed a FOIA lawsuit seeking records of his role in the procurement process ⁵.

Corey Lewandowski served as Noem's de facto chief of staff at DHS. LittleSis records document both a professional position — described as shadow chief of staff with contract approval authority — and a personal relationship dating to 2019. According to those records, Lewandowski approved contracts and reviewed policy before Noem signed. In a March 2026 House hearing, Noem was directly questioned about the reported personal relationship; both she and Lewandowski have denied it. Multiple outlets described the relationship as 'Washington's worst-kept secret' Connection #2921.

Troy Dean Edgar served as DHS Deputy Secretary under Noem. Edgar's personal financial disclosure reported holdings in Palantir, Raytheon, and Tesla — all companies that held or were pursuing DHS contracts during his tenure overseeing department procurement Connection #2937.

Aram Moghaddassi, a DOGE detail assigned to the Social Security Administration and later DHS, coordinated with Noem on the Death Master File operation in April 2025. According to Washington Post and Spokesman-Review reporting, Moghaddassi transmitted a list of 6,300 immigrants with recently revoked temporary legal status to SSA. Noem signed two memoranda with Acting SSA Commissioner Leland Dudek authorizing their addition to the Death Master File under fabricated death dates. Career SSA IT chief Greg Pearre was physically removed from his office for opposing the action. Dudek signed the memoranda despite initially concluding the action was illegal Connection #3269 Connection #3273.

On April 8, 2025, SSA added 6,300 living immigrants to the Death Master File (renamed 'Ineligible Master File' for this operation), according to Washington Post and Spokesman-Review reporting. The list originated at DHS and comprised individuals whose temporary legal status had been revoked. The additions used fabricated death dates. The population reportedly included minors, including a child as young as 13 Connection #3269 Connection #3273.

The authorization chain ran from Aram Moghaddassi, who transmitted the DHS list to SSA, through Acting Commissioner Leland Dudek, who signed two memoranda with Noem, to Noem herself as DHS Secretary. Dudek signed despite his initial conclusion that the action was illegal. DOGE reporting identified Moghaddassi as the operational coordinator between DHS and SSA Connection #3269 Connection #3273.

SSA partially reversed the additions between March 14 and April 19, 2025, according to subsequent reporting. Approximately 407 records of living immigrants added in April reportedly remained active in the Death Master File as of the date of available reporting. No litigation specifically targeting the Death Master File additions had been filed at that time; the reversal appears to have been an administrative decision Connection #3273.