Editor’s Note: This report is part of “Seeds of Distrust,” an ongoing investigative collaboration between Lighthouse Reports, the Arizona Center for Investigative Reporting, the Texas Observer, palabra, and Puente News Collaborative.
For a retired federal employee, Tom Homan, an acting director of Immigration and Customs Enforcement (ICE) under the Trump administration, is a very busy man. For the last year, he’s crisscrossed the country with a team of former state and federal law enforcement officers, who call themselves Border911, speaking in theaters and event halls from Phoenix, Arizona, to Mission, Texas, to Ronkonkoma, New York, to promote the propaganda that the U.S.-Mexico border is under invasion and that President Joe Biden and his allies are admitting “illegal aliens” so that Democrats will “be in power for years to come.”
Homan, the president and CEO of the 501(c)(3) nonprofit Border911 Foundation, Inc., and his group’s members have largely flown under the radar, receiving little coverage outside of right-wing media. But if Trump were to win this November, Homan, the architect of Trump’s family separation initiative, and his allies could receive prominent posts. Trump already promised at a rally this summer that he is “bringing back” Homan in 2025.
“Trump comes back in January, I’ll be on his heels … and I will run the biggest deportation force this country has ever seen,” Homan vowed during a July immigration panel in Washington, D.C. “They ain’t seen shit yet. Wait until 2025.”
The mission of Homan’s tax-exempt Border911 Foundation, formed in Virginia in October 2023, is to “educate the American people about the facts of a non-secure border,” according to Internal Revenue Service (IRS) filings. But, by promoting disinformation about a “border invasion” of “illegal immigrants,” Homan’s Border911, the nickname he often uses for the foundation, is helping to lay the groundwork for challenging November’s election if the results don’t favor Trump.
Border911 remains linked to a 501(c)(4) group, called The America Project, a major funder of election conspiracy efforts. Unlike a 501(c)(3) charity, 501(c)(4)s can legally support political campaigns, and they are sometimes referred to as “dark money” organizations because they aren’t required under U.S. tax law to reveal their donors. However, they lack one important advantage of a 501(c)(3)–their donors’ contributions are not tax-deductible. (Homan also in 2023 created another 501(c)(4) he called Border911 Inc.)
Border911 Foundation, and its members, identified on its website, are promoting extremist policies, such as declaring an invasion at the border, to elected leaders and law enforcement officials and falsely portraying the country as beset by voter fraud, according to a joint investigation by a multistate team of journalists from Lighthouse Reports, the Texas Observer, the Arizona Center for Investigative Reporting, and palabra based on dozens of interviews, attendance of various Border911 events, and reviews of public records, videos, speeches, and social media posts.
Border911’s policy agenda foreshadows Trump’s most extreme immigration proposals, which include mass deportations and deploying troops to the U.S.-Mexico border. The nonprofit has already had an impact in Arizona, where several Border911-backed bills have been introduced and where Republican lawmakers are pushing a controversial November ballot initiative that would formally declare a border invasion and empower state and local officials to become immigration enforcers.
Despite his background in law enforcement, IRS filings show that Homan’s foundation and his Border911 dark money organization may be skirting federal tax law, according to tax documents and interviews with experts, that prohibits tax-exempt charitable organizations from participating in “any political campaign on behalf of, or in opposition to, any candidate for public office.”
Border911 associates have testified in Congress as law enforcement experts, instead of as Trump-aligned activists, and spread disinformation in media interviews, calling the Biden Administration’s handling of the U.S.-Mexico border “the biggest national security threat to the American people since 9/11.” Meanwhile, these same players are securing lucrative border security contracts for themselves or for-profit companies that employ them, documents show.
“BORDER911 is a team of operators with decades of experience,” Homan posted on X last November, announcing the group. “We helped create the most secure border in history. The war on America is going to be won when we band together. … The cavalry is on its way. … The border is our theater of war.”
Homan’s cavalry, who are publicly featured as team members, includes former state and federal law enforcement, some of whom have intelligence backgrounds, including Rodney Scott, former Border Patrol Chief; Derek Maltz, a former Drug Enforcement Agency special agent; Victor Avila, a former agent with Homeland Security Investigations (HSI); Sara Carter, a Fox News contributor; and Jaeson Jones, a former Texas Department of Public Safety captain turned NewsMax correspondent, according to public records and the Border911 Foundation’s website.
For the last several months, the group’s members have been targeting battleground states and cities “to educate them [about the] border crisis,” Homan said on a March podcast. At a July conference in El Paso, Homan claimed that “Millions of people heading to sanctuary cities will be counted in the next census.” When seats are apportioned for Congress, he said, “That’s going to create more seats in Congress for Democrats. They sold this country out. It’s almost treasonous.”
Since Vice President Kamala Harris became the Democratic presidential nominee in August, the gruff-talking and pugnacious Homan has attacked her on Fox News, where he is a contributor. The former federal agent, who got his start as a police officer in West Carthage, New York, before becoming a Border Patrol agent then moving to ICE, characterized Trump’s Democratic opponent on Fox as “disgusting” and said that Border Patrol and ICE agents did not respect her. She “broke the border,” he said.
Homan claims he launched his nonprofit as a purely self-funded passion project. “I started Border911 with my own funds because every day I wake up pissed off,” Homan said in a March 2024 interview. “And we have to educate Americans why border security matters.”
But before it became its own foundation, Border911 was part of The America Project, an organization founded by serial election deniers: former Overstock.com CEO Patrick Byrne and Lieutenant General Michael Flynn, Trump’s disgraced former national security advisor.
At a raucous White House meeting on December 18, 2020, Byrne and Flynn were part of a group of advisers that counseled Trump to use National Guard soldiers to seize voting machines to overturn the election. When martial law was not imposed, the two formed The America Project. And Byrne poured $27 million of his own money into that project, according to a post on X, including funding a sham election audit in Arizona, and recruiting radicalized individuals as poll workers with an emphasis on those with military and law enforcement backgrounds.
For part of 2023, Homan served as CEO of The America Project, then he launched Border911 Foundation Inc. in October of that year as a nonprofit. Homan is no longer the CEO of The America Project, but, as of June 2024, he was still listed as a board director. It’s unclear what salary and compensation, if any, he has received from The America Project.
Homan declined to be interviewed for this article, and he referred questions about Border911 to Steve Lentz, a corporate attorney in Virginia. Lentz said he didn’t know how much Homan was paid as CEO of The America Project or whether Byrne or The America Project supported Border911. “I don’t know whether the foundation has received any money from them or not,” he said. Regarding the Border911 organizations, Lentz said that “Mr. Homan received no compensation in 2023, and will receive $1.00 in 2024.”
In addition to Homan’s tax-exempt charity, IRS tax filings show that in October 2023 he created Border911, Inc, the 501(c)(4), and both organizations list their corporate headquarters as a UPS store in Fredericksburg, Virginia. Both Border911 organizations also declare the same purpose in tax filings: to “educate Americans about a non-secure border.” In 2023, both of Homan’s Border911 organizations reported almost the same expenses – about $87,000 – but the 501(c)(4) claimed zero revenue. (The groups have not yet disclosed figures for 2024.)
Two nonprofit compliance experts who examined Border911’s 2023 tax documents said it was unusual to see nearly identical expenditures for the two entities, while one of them—the dark money organization—reported no revenue. It appears, they said, that the tax-exempt charity money may have been passed through the dark money organization, which would violate IRS tax law. “I don’t have any explanation for how the (c)(4) can bring in zero money in its first year and be able to spend tens of thousands of dollars,” said Robert Maguire, vice president of research and data at the nonpartisan Citizens for Responsibility and Ethics in Washington.
It would be particularly concerning, he said, if ex-law enforcement officials openly flouted federal law. “These are hard and fast rules, to make sure that people aren’t misusing nonprofits for purposes they weren’t meant for,” he said. “You would hope that someone who cares about the rule of law would care about making sure their donors have the confidence that they are not misusing the funds.”
Lentz, the attorney who serves as a spokesman for Border911, said the 2023 tax filing for the dark money organization was incorrect. “There was an entry in the [501](c)(4) that shouldn’t have been there,” he said. “It should be all zeros. We’re going to amend that 990 for Border911, Inc.” Lentz added that the 501(c)(4) was created in 2023 but not operational until March 2024. That month, ABC News reported that Border911’s tax-exempt charity appeared to be illegally backing Trump’s campaign, which Lentz told ABC was “inadvertent.”
After being informed of Lentz’s statement, Maguire said: “Still, even if the explanation is more innocent, the impact can be such that it obscures their activities and makes it more difficult to hold them accountable. I certainly hope that if these were honest mistakes, they will correct them and endeavor to do better in the future. After all, these documents are all signed under penalty of perjury.”
Reporters for this story also requested comment from five people named on the Border911 website as team members, whom Lentz said are reimbursed for expenses by the foundation.
Two members replied to questions via email–former Border Patrol official Rodney Scott and former DEA special agent Derek Maltz–emphasizing that they joined Border911for philosophical reasons and were not paid employees. Maltz said he wanted “to educate America about border security and the growing fentanyl crisis.” Maltz deferred questions about his compensation to a Border911 Foundation representative but said that most work there is on a “volunteer basis.”
Scott said that he was “a member of the Border911 Foundation’s speaker’s team.” The organization “will normally reimburse me for limited/reasonable (coach) travel,” he said and that he has “been compensated for larger speaking events that required travel and extensive time.” Sara Carter, Jaeson Jones, and Victor Avila did not respond to requests for comment by publication date.
Homan has made no secret of his close ties with Trump, who promoted him to acting director of ICE where he initiated and pushed for separating families at the border before retiring in 2018. “I’m a Trump guy and not ashamed of it,” he said in a video announcing The Border911 Foundation, which Trump promoted on his Truth Social media platform last year.
It’s unclear when Homan first met Byrne, the Overstock.com millionaire, who has funded numerous election denial groups across the country through The America Project. (Byrne did not immediately respond to an interview request.) But, in April 2023, only a few months before Homan started Border911 as “his organization,” Byrne celebrated Homan’s hire as CEO of The America Project at a fundraising event in a gilded ballroom at Trump’s Mar-a-Lago resort in Florida. “What an honor it is to be turning the command of this vessel over to a real national security professional,” he said.
Byrne then launched into a speech. “I’m not sure that the affluent people who I’ve met know what’s coming for them,” he said. Under President Biden’s America, we are “living through a Chavista Revolution. It’s a classic Maoist doctrine coming at you in all stages,” he told the audience. “I have literally poured 90 percent of my liquidity into this effort because there is no country, no future, if we don’t win this.”
Homan nodded from the stage. “I’ve never met a man who loves his country more than Patrick Byrne,” he said. “I’m honored that you even asked me.”
A year later, Homan would return to Mar-a-Lago heading his own fundraiser for the Border911 Foundation with Trump in attendance. Lentz, the attorney representing Homan and the Border911 organizations, said an individual donated the Mar-a-Lago venue to Homan’s group for the April 2024 fundraiser, but he said he didn’t know who it was. The attorney also said that he had no idea how much the group had raised at the event, but that the amount would be reported in their 2024 tax filing next year.
“He’s going to be our next president whether you like it or not.”
Prior to becoming CEO, Homan had already participated in America Project events: In January 2023, he appeared alongside Arizona state Representative Steve Montenegro, who had been serving as the America Project’s national political director, at a Phoenix press conference to promote a slate of Border911-endorsed bills, followed by a speaking event two days later with MAGA-aligned Arizona legislators, which included free entry and meals for active-duty military.
At the press conference, the men repeatedly tied fentanyl deaths to the border “invasion,” insinuating migrants were bringing in the drugs, even though most fentanyl is smuggled by U.S. citizens through ports of entry, according to a recent study by the Cato Institute, a libertarian think tank. “This border is out of control. It’s a crisis,” Homan told reporters. “Anybody who argues differently is ignoring the data, and they’re lying to you.”
Two days later at a nearby theater, Montenegro publicly touted a “Border911” legislative agenda for the 2023 session that included declaring cartels foreign terrorist organizations, repurposing the Arizona National Guard as a border force, allowing unauthorized immigrants to agree to orders of deportation to avoid prosecution, and prohibiting migrants from pleading down charges if they caused the death of an American citizen, mirroring some initiatives that Texas had already adopted under Republican Governor Greg Abbott. (Trump has suggested cartels be designated as foreign terrorist organizations as part of the justification for his proposal, if reelected president, to use his emergency powers to deploy even more active duty military to police the border and protests elsewhere.)
“We’re going to focus on educating representatives and senators on what their authority is … so that we can start passing the right legislation,” Montenegro told the audience. Then, he added, “We’re going to replicate what we’re doing here” in other states “so that the entire country understands that every state is a border state.”
Montenegro introduced bills in 2023 and in 2024 that would’ve furthered Border911’s goals. Much of this legislative work coincided with Montenegro’s tenure as the America Project’s national political director, which he followed up with paid consulting work, according to state disclosure forms. Yet he never filed a personal financial interest statement with legislative officials before introducing or voting on Border911-aligned bills, a House clerk confirmed.
It’s unclear how much The America Project has paid Montenegro, since Arizona doesn’t require legislators to disclose compensation amounts. Whether Montenegro remains on the group’s payroll is also unknown, since his most recent state filings don’t cover 2024. The lawmaker did not respond to multiple requests for comment.
Receiving money from an outside group while advancing its legislative agenda raises ethical questions, according to Paul Eckstein, a longtime Arizona attorney and expert in legislative conflicts of interest. “If he’s receiving … $10,000 or more, if I were giving the advice, I would say he’s got a substantial enough financial interest that he should not be involved in any way, in any (related legislative) action,” Eckstein said.
Some Border911-backed bills have made it through the Republican-controlled House and Senate only to be vetoed by Arizona Governor Katie Hobbs, a Democrat. But Montenegro and other Republicans successfully referred the “Secure the Border Act” to the November ballot, which, if approved by Arizona voters, would authorize state and local law enforcement to act as immigration officers—even though Arizona border sheriffs have said they lack the manpower and funding to carry it out. One ex-border sheriff, a Republican, called it an “ill-conceived political stunt.” (Similar bills have previously been approved, and largely struck down by the courts, in Arizona and other states.)
By May 2024, Homan was running the Border911 Foundation as a separate nonprofit, but he was still collaborating with Montenegro and The America Project. In his capacity as a state elected official, Montenegro approached city leaders in Tombstone, Arizona, in May and requested and received a special permit on behalf of The America Project for a Border911 “Borders and Elections” town hall meeting. Alongside Montenegro at the city council meeting was Shawn Wilson, CEO of a private security firm called Mayhem Solutions Group. “We partner with [Mayhem] them for data and intel coming across the border, not to mention with our law enforcement,” Montenegro said of The America Project’s relationship with Mayhem. (Wilson, who describes himself as an Army veteran, previously volunteered with Arizona Border Recon, a paramilitary group that claims on its website to provide intel and security services to federal agents.)
The purpose of the event, where Border911 member Victor Avila, the former HSI agent from Texas, was identified as a speaker, would be to “sound the alarm” about the “current administration failing to do its job” when it came to securing the border, Montenegro said, according to the city council meeting minutes. “We’re trying to sound the alarm … not just in the state of Arizona, but we’re trying to reach out to every state in the union.”
In addition to a press conference and a Border911 panel with elected officials, they would meet privately with “law enforcement intel officers and other folks that collect data intelligence,” he said. The America Project would also deliver food to local Border Patrol and law enforcement, Montenegro said, and give the local sheriff an award.
Border911 members have held and filmed similar events in Texas, New York, and elsewhere. Team members often produce and distribute strategically edited video from the border that bolsters MAGA conspiracy theories about invasion and immigrants as criminals. Like Homan, Sara Carter, another Border911 team member, is also a Fox News contributor who often talks about “criminals flooding the border.”
Jaeson Jones, the former captain in Texas DPS’s intelligence division, who identified himself at one point as Border911’s vice president, creates “invasion” content as a correspondent for the far-right NewsMax, and has been featured on Fox News. Those two media companies separately settled multimillion-dollar defamation lawsuits with voting machine companies after falsely alleging voter fraud in the 2020 election. Trying to overturn that election was The America Project’s initial focus, and election denial remains a major theme of Trump’s reelection campaign.
Jones and Mayhem Solutions Group use the same video production company, Cine 48, co-founded by the media director of the far-right group Turning Point USA. (Turning Point USA is yet another 501(c)(3) charitable organization with an eponymous dark money group for political purposes.) Jones and Border911 have also regularly produced content about the border for a Turning Point USA series called “Frontlines,” as well as a mini-series co-starring Mark Lamb, the sheriff of Pinal County, whom Jones has called a “close friend.”
Lamb is closely aligned with the far-right constitutional sheriffs movement, and he is a promoter of election conspiracies, including about non-citizen voting.
In one presentation to a Central Texas GOP chapter, Jones showed videos that he said revealed armed cartel members driving around Arizona. He attributed the footage to his firm Omni Intelligence and to Mayhem Solutions Group, and bragged of embedding with Pinal County deputies in Arizona.
The tactic of portraying the border as under invasion has proved useful for efforts to undermine confidence in the election—and has proved profitable for Border911’s members.
Last summer, Maltz, the former DEA special agent, and Jones, the former DPS captain, testified in Washington, D.C., before the House Homeland Security Committee about the border, identifying themselves only as private citizens and former law enforcement. Jones didn’t mention his Border911 public relations role, his private intelligence company, or the $20,000-30,000 speaker fees he advertises that he charges as a border expert.
Maltz did not disclose his Border911 speaker role or his job with a firm that has earned more than $250 million in federal government security contracts. Maltz is the executive director of government relations for PenLink, Ltd., a tech firm that sells surveillance tools to law enforcement, including software that can track cell phones without a warrant. The tech has been purchased by ICE, the DEA, and Texas DPS, among other agencies. Maltz said his job with PenLink includes interacting with the firm’s U.S. government and foreign customers, but he’s not registered as a lobbyist because his position does not involve lobbying. He said he became a member of Border911 because of his concern about Mexican cartels, Chinese organized crime, and escalating fentanyl deaths: “My work with the Border911 Foundation is completely independent of my role with Penlink. … I am a member of the Border911 Foundation’s speaker’s team, but I am not a board member or employee.”
Maltz isn’t the only Border911 team member linked to a firm that’s cashing in on border security-related government contracts. Rodney Scott, the ex-Border Patrol chief, founded a consulting firm in July 2021—about a month before retiring from the federal government. At the time, a nonprofit immigrant advocacy group in California filed a complaint alleging that founding the firm, Honor Consulting, while serving as Border Patrol chief violated federal law and ethics rules. (The Justice Department did not respond to questions about the complaint. The FBI and Homeland Security inspector general’s office said they could not confirm or deny the existence of an investigation.) In an email response to questions for this story, Scott said that prior to founding the firm, he consulted with U.S. Customs and Border Protection legal counsel, who, according to him, said there were no legal issues or concerns. When asked about the complaint, a CBP spokesperson said the agency does not comment on personnel matters.
In 2023, Scott incorporated a new company with a similar name: Honor Consulting Plus. Some of the firm’s customers include Republican Wisconsin Congressman Bryan Steil’s re-election campaign, and the Texas Office of the Attorney General, records show.
In May, the Texas Attorney General’s office granted Scott’s firm, Honor Consulting Plus, a $50,000 contract to advise on the state’s lawsuit defending Governor Abbott’s contentious floating buoy barrier on the Rio Grande, part of the governor’s multibillion-dollar militarized immigration enforcement initiative called Operation Lone Star. Scott is tasked with providing expert testimony in the case and is approved to invoice $600 an hour, with no monthly billing limit, according to the contract. Scott referred questions about the contract to the AG’s office.
Since 2018, Homan has also had his own for-profit firm, Homeland Strategic Consulting. His Virginia-based firm registered to lobby in Texas in 2021, though state filings show no activity. Public records reveal only a handful of clients, including $32,000 to provide “strategy consulting” for failed U.S. Senate candidate Jim Lamon, one of the 11 Arizona Republicans who falsely claimed he had been authorized to cast the state’s electoral votes for Donald Trump in the 2020 election. Homan also has been personally paid $1,300 in travel reimbursement funds from Trump’s campaign, according to Federal Election Commission data.
Border911 team member Avila has focused less on government contracts and more on aspirations for public office, making unsuccessful bids for city council, Texas Land Commissioner, and Congress. A year ago, Avila launched Border Patriot PAC, which to date has endorsed a single candidate, John Fabbricatore, a former ICE agent running as a Republican for a congressional seat in Colorado. Fabbricatore, who resides in the Denver suburb of Aurora, contributed to nationwide misinformation about a Venezuelan prison gang taking over an apartment complex in his city—a false story the Trump campaign repeated.
Otherwise, Border Patriot PAC hasn’t done much. According to its July 2024 filing, the PAC only had $19,000—of which $15,000 came from Wilson’s Mayhem Solutions Group.
In the weeks before the election, members of Border911 have joined a final America Project-backed blitz called “Operation Restore Freedom,” giving speeches about the border along with other pervasive election conspiracy theorists in Texas and in crucial swing states like Nevada and Arizona that Trump needs to win.
If Trump does prevail, Homan and other Border911 members may get the chance to fundamentally reshape national security and immigration policy.
If Trump loses, Homan and his former military and law enforcement allies at Border911 and the America Project will likely be on the frontlines sowing doubts about the election for months to come.
At speaking events, Homan sounds confident in Trump’s victory. At an America Project fundraiser at Mar-a-Lago, Homan said he’d pledged to Trump, as they dined together in Las Vegas, that the former president would win the November election and he’d serve under him again. “I can’t wait to be back,” Homan said. “He’s going to be our next president whether you like it or not, and I will be at the White House with him.”
