WASHINGTON — Huge funding from influential conservative donor networks is flowing into a conservative venture aimed at creating a Republican “government-in-waiting,” including over $55 million from groups linked to conservative activist Leonard Leo and the Koch network, according to an Accountable.US review shared exclusively with NBC News.

Launched by the Heritage Foundation in April 2022, Project 2025 is a two-pronged initiative to develop staunch conservative policy recommendations and grow a roster of thousands of right-wing personnel ready to fill the next Republican administration. With former President Donald Trump now the GOP’s presumptive 2024 nominee, the effort is essentially laying the groundwork for a potential Trump transition if he wins the election in November.

With contributions from former high-level Trump administration appointees and an advisory board that has grown to over 100 conservative organizations, proponents describe Project 2025 as the most sophisticated transition effort that has existed for conservatives. The initiative includes a manifesto devising a policy agenda for every department, numerous agencies and scores of offices throughout the federal government. 

In this Nov. 16, 2016 file photo, Federalist Society Executive Vice President Leonard Leo speaks to media at Trump Tower in New York. Leo is advising President Donald Trump on his Supreme Court nominee.
Federalist Society Executive Vice President Leonard Leo in New York on Nov. 16, 2016.Carolyn Kaster / AP file

Since 2021, Leo’s network has funneled over $50.7 million to the groups advising the 2025 Presidential Transition Project as part of its “Project 2025 advisory board,” according to tax documents reviewed as part of the analysis by Accountable.US, a progressive advocacy group. That sum includes donations from The 85 Fund, a donor-advised nonprofit group that funnels money from wealthy financiers to other groups, and the Concord Fund, a public-facing organization. 

In 2022, the donor-advised fund DonorsTrust, which received more than $181 million from Leo-backed groups from 2019 to 2022, contributed over $21.1 million to 40 organizations advising Project 2025. It contributed nearly $20 million to 36 nonprofit organizations advising Project 2025 in 2021.

Leo, a top conservative megadonor, has worked to shift the American judiciary further to the right, having previously advised Trump on judicial picks while he was in office and helping to build the current conservative Supreme Court majority.

In addition to Leo’s funding to organizations advising Project 2025, the Heritage Foundation’s own donations surged in 2022. It contributed $1,025,000 to nine of the advisory groups, up from a total of $174,000 in grants to other nonprofit groups a year earlier.

The Heritage Foundation did not immediately respond to a request for comment.

The review by Accountable.US also found that oil billionaire Charles Koch’s network directed over $4.4 million in 2022 to organizations on Project 2025’s advisory board via its donor conduit, Stand Together Trust. 

Project 2025’s vision for the next conservative administration’s energy agenda would rapidly increase oil and gas leases and production through the Interior Department to focus on energy security, and proposals include reforming offices of the Energy Department to end focus on climate change and green subsidies.

The Environmental Protection Agency would cut its environmental justice and public engagement functions, “eliminating the stand-alone Office of Environmental Justice and External Civil Rights,” according to a proposal drafted by Mandy Gunasekara, a former chief of staff at the EPA under Trump.

The advisory board for Project 2025 includes representatives from conservative groups led by veterans of the Trump administration, such as America First Legal, the Center for Renewing America and the Conservative Partnership Institute, as well as conservative mainstays like the Claremont Institute, the Family Research Council and the Independent Women’s Forum.

Accountable.US executive director Tony Carrk warned that Project 2025’s stark conservative program and its advisory groups are made possible by funding from right-wing donors’ funneling tens of millions of dollars to the effort.

“The ‘MAGA blueprint’ isn’t a one-off project — it’s backed by the same far-right figures who have long dictated the conservative agenda,” Carrk said. “Leo, Koch and others should be held to account for propping up a policy platform that puts special interests over everyday Americans and poses an existential threat to our democracy.”

While the groups advising Project 2025 haven’t been supporting a candidate outright, many of the people leading them or with longtime affiliations have close ties to Trump after having served in his administration. NBC News projects that Trump has now clinched the delegate majority for the Republican nomination, setting up a rematch with President Joe Biden in November.  

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