Article III: Self-Dealing

(a) Kristi Lynn Arnold Noem has violated 5 CFR pt. 2635, Misuse of Position by using her position for personal gain while inappropriately using taxpayer dollars, when: (1) Kristi Lynn Arnold Noem is using her position to circumvent the Federal contracting process and funneling Federal funds to her friends’ businesses. Kristi Lynn Arnold Noem used the cover of a national emergency to bypass the competitive bidding process and direct Federal dollars to close associates. Secretary Noem used taxpayer dollars to fund a $200 million ad campaign for recruiting ICE agents Kristi Lynn Arnold Noem used the national emergency declared at the southern border to bypass the normal contract process, which included competitive bidding, to award multi-million dollar contracts to republican-led ad agencies. One such contractor which was formed days prior to the award, subcontracted with the Strategy Group, a company run by the husband of senior DHS official, Tricia McLaughlin and a close friend of Kristi Lynn Arnold Noem.