UPDATE -- "The Strategy Group" Sends The Watchdog Report a Cease and Desist...

UPDATE: It appears that the latest edition of THE LIST has struck a nerve with individuals closely tied to former DHS Secretary Kristi Noem. For those who don’t know, THE LIST is a running log of potential oversight targets for House Democrats seeking to investigate allegations of waste, fraud, abuse, and mismanagement by the Trump Administration and its allies. On Friday, we featured Ben Yoho, CEO of The Strategy Group and husband to former DHS spokesperson Tricia McLaughlin. Shortly after going to press, we received a cease-and-desist letter from The Strategy Group and its principals (as CEO, we’re assuming Yoho is one of these principals).

To maintain full transparency and context, the full letter is provided at the end of this post for all to see.

As a former House Oversight Committee staffer myself, this is not my first rodeo with aggressive legal maneuvers by lawyers. I understand the desire to protect their client and respect the game. But even when I was at Oversight, this kind of letter always made us dig deeper and look more closely. It’s the old Shakespearean adage of “the lady doth protest too much, me thinks.”

First, the letter takes issue with my use of the word “managed” regarding the Strategy Group’s involvement in the now-infamous Kristi Noem DHS ad campaign. Okay, I’m happy to revise that word and/or add additional context. What would you suggest? Oversaw? Organized? Participated in? Is there a verb here that is preferable to “managed” that you would recommend?

The ProPublica article reported that “executives from The Strategy Group traveled to the shoot and hired subcontractors to fill out the film crew, according to records and a person involved in the campaign.”

Call me crazy, but that sure sounds like “managing” an ad campaign/filming session to me. But in the spirit of transparency, how about The Strategy Group provide a full detailing of precisely what they did as a subcontractor on this project? That might help clarify this matter and ensure accuracy.

I think we’ll go with “participated in” for now until we receive further guidance from The Strategy Group’s counsel.

So now that we have the verbiage down, the next thing to address is the type of contracts that were used for this ad campaign. According to the cease-and-desist letter, The Strategy Group was never under direct contract with DHS, but rather a subcontractor to Safe America Media, an entity that reportedly was formed just days before the contract was awarded.

Their concession on this matter validates precisely why there are so many questions regarding their involvement. For what it’s worth, in my original post, I accepted the premise that they were a subtractor. It was the secrecy alleged in the ProPublica article that I found both suspicious and worth congressional examination. Clearly, Senators Peter Welch and Richard Blumenthal agreed, as evidenced by the investigative letter they sent on March 6, 2026.

Finally, the money. The Strategy Group’s attorneys asserted that the company only received $226,137 for “limited production services.” While I agree that this is only a fraction of the $220 million Kristi Noem recklessly spent on the ad campaign, that does not preclude anyone involved in the ad campaign from facing questions about the use of taxpayer dollars.

So now that we’ve addressed The Strategy Group’s concerns, there are still many questions that need to be answered. In reality, anyone with visibility, inside or outside of DHS, is going to have to be prepared to answer these questions from Democrats in Congress who are investigating: 1.) Did Tricia McLaughlin play any role in interviewing/selecting any contractors involved in this ad campaign? 2.) Did Corey Lewandowski? 3.) Did the Secretary, who reportedly demanded to have personal approval of any contract and/or expense worth more than $100k, have visibility on this decision? 4.) How much of this $220 million taxpayer-financed campaign was spent on actual advertising (ad buys), and how much was pocketed by contractors, subcontractors, etc. for “overhead”? 5.) What kind of interactions did Yogo have with McLaughlin or anyone at DHS regarding this subcontract? 6.) How did the Strategy Group become a subcontractor to an entity that literally did not exist until days before the deal was finalized? 7.) Who approached The Strategy Group about this subcontract? 8.) Does anybody with a financial interest in The Strategy Group also have any financial interest in Safe America Media? 9.) Who at Safe America Media hired The Strategy Group as a subcontractor? 10.) Did anyone at DHS suggest to Safe America Media that they should hire The Strategy Group as a subcontractor?

Democrats in Congress have made it very clear that leaving office won’t stop the investigations. House Judiciary Committee member Rep. Ted Lieu said, “She abused her power. She engaged in corruption. She spent millions of taxpayer funds on a luxury jet fleet with beautiful bedrooms, and her masked federal agent killed Americans. We’ll definitely investigate anyone within DHS who violated criminal law.”

And so, for Kristi Noem, Safe America Made, People Who Think, and yes, Ben Yoho’s The Strategy Group, Senate Democrats have put you on THE LIST.