The $23 Million Silence

For thirteen years, Kevin Sabet has built a career on a single, endlessly serviceable exhortation: follow the money. Smart Approaches to Marijuana — the organization he co-founded with former Congressman Patrick Kennedy in Denver in January 2013, in the raw aftermath of Colorado’s legalization vote — has made “Big Marijuana” its bogeyman and financial transparency its cudgel. The industry, SAM tells legislators from Tallahassee to Austin, is addiction-for-profit, awash in dark money and cynical lobbyists.

It is advice worth taking. So The THC Report took it. We pulled the network’s newest federal tax filings from the IRS e-file record and ran the complete 2025 and 2026 lobby registration databases published by the Texas Ethics Commission. What emerges is a portrait Sabet himself might have sketched, had the subject been anyone else: a $23 million war chest assembled almost entirely in the dark, a disclosed charity quietly starved while its unaccountable political twin balloons, a founder whose salary migrated into invoices from his own consulting firms — and a Texas influence operation that runs not through any registered SAM lobbyist, of which there are none, but through the multistate marijuana corporations whose commercial interests in prohibition happen to rhyme perfectly with SAM’s ideological ones.

Three heads, one address

The SAM operation is legally three creatures sharing a single suite at 107 S. West Street in Alexandria, Virginia: SAM Inc., a 501(c)(3) charity (EIN 47-2400657); SAM Action Inc., its 501(c)(4) political arm (EIN 47-3688463); and the Foundation for Drug Policy Solutions (EIN 88-1041205), a smaller c3 vehicle. Donations to the first and third are tax-deductible and their donors face at least the theoretical discipline of charitable norms. The c4 is where politics lives — and where, under federal law, donors may remain forever anonymous.

The 2024 returns, the most recent available, tell the story in the divergence between the twins. SAM Action reported revenue of $15,865,551 — including $8,601,743 in contributions, a five-and-a-half-fold leap from the $1,576,210 it raised the year before, supplemented by $6.46 million in securities sales and $800,316 in investment income. Against that torrent, it spent a mere $1,166,233. It banked the rest, closing the year with net assets of $23,035,823.

Schedule B of the return, where contributors would be listed, is entirely restricted. Names, amounts, dates: all dark. The largest cash infusion in the organization’s history arrived precisely as the federal campaign against hemp-derived cannabinoids crested, from parties the public is not permitted to know.

The timing of the filing itself deserves a footnote in the annals of bureaucratic poetry. SAM Action’s return was submitted to the IRS on November 13, 2025 — one day after the President signed H.R. 5371, the shutdown-ending appropriations package whose Section 781 redefines federal hemp to a 0.4-milligram total-THC ceiling per container, effective November 12, 2026. The Senate had voted 76–24 just days earlier to preserve that language. Sabet told The Hill the provision was, in his words, “the biggest change in marijuana policy, I would say, in a generation,” and that his organization was proud of it. The generation-defining victory was announced on a Tuesday; the filing showing who had quietly amassed $23 million to help pay for the fight arrived, unreadable in all the ways that matter, on a Thursday.

Meanwhile the disclosed charity withered. SAM Inc.’s contributions collapsed in 2024 from $3,052,344 to $692,684. It spent $2,264,970 against $1,202,541 in revenue — a deficit of more than a million dollars — and reported $1.86 million in new liabilities. The money did not vanish from the movement. It migrated, as money in such architectures reliably does, toward the arm with no donor disclosure and the longest political leash.

The president’s invoices

Both entities’ 2024 filings check the box that nonprofit accountants least enjoy checking: Schedule L, transactions with interested persons. SAM Action’s version spells it out. Kevin A. Sabet-Sharghi — the founder’s full legal name — is the owner of two consulting firms, LUA Partners and Policy Solutions Group, Inc., which billed the organization a combined $121,322 in 2024 ($66,322 and $55,000 respectively). The disclosed scope of services: serving as the public and media contact for all three charitable organizations, communicating with advocacy consultants and key policymakers, and helping design a comprehensive plan of action.

Set beside the compensation tables, the arrangement acquires a certain elegance. Sabet’s reported W-2 compensation from SAM Inc. was $154,224 in 2021. It fell to $104,941 in 2022, then $78,927 in 2023, and finally to $6,668 in 2024 — budget dust in an organization whose executive vice president, Luke Niforatos, drew $231,946 plus benefits the same year. The founder’s compensation did not so much shrink as change costumes: from a salary line that watchdogs and reporters scrutinize into consulting invoices from companies he owns, disclosed in a schedule most readers never reach. All of it is lawful; all of it is reported; none of it is the posture of an organization whose stock-in-trade is lecturing others about financial hygiene.

Where the war chest points

Schedule I shows where SAM Action’s money went when it went anywhere at all. The organization granted $128,600 to the Coalition for Safe Communities in Beverly, Massachusetts, and $100,000 to Keep Florida Clean Inc. in Tallahassee — each grant explicitly designated, in the filing’s own words, to support state ballot initiatives against legalization — plus $10,000 to Protect Our Kids in Colorado. This is the model SAM has run for a decade, from California in 2016 to Michigan in 2018: national money, raised centrally and often anonymously, deployed into state fights under locally wholesome letterhead. The $23 million now sitting in Alexandria is a promissory note against every state campaign to come. Texas legislators convening in January 2027 might reasonably wonder how much of it has their names on it.

The Texas registry: absence, and presence

Here is what the Texas Ethics Commission’s complete lobby databases for 2025 and 2026 show about Smart Approaches to Marijuana: nothing. No SAM entity appears as a client. Neither Sabet nor Niforatos nor any officer of the network holds a Texas lobby registration. The organization whose rhetoric echoes through Senator Charles Perry’s committee hearings and the Lieutenant Governor’s press conferences maintains no registered presence in Austin whatsoever. The nearest ideological kin on the registry is Texans for Safe and Drug-Free Youth, represented both years by lobbyist Shelton Green.

What the registry does show is who else has been arming up — and when. Green Thumb Industries, freshly minted as a Texas Compassionate Use conditional licensee, registered three Austin lobbyists on October 8, 2025, weeks after the HB 46 license awards. Verano Holdings carries a four-lobbyist team into 2026, led by Robert Miller. And Trulieve, the largest of the multistate operators, has assembled something closer to a phalanx: Lara Keel’s registration jumped two prospective compensation bands between 2025 and 2026, into the $100,000-to-$149,999 range; Will Yarnell registered for Trulieve Texas on April 10, 2026; Allison Billodeau for Trulieve Holdings on June 26.