Legislative audit finds Crooked Adam Crum violated fiduciary obligations with CBR investment

A recently released legislative audit of the State of Alaska’s financial activities found former Revenue Commissioner Crooked Adam Crum violated his fiduciary obligations when he directed a $75 million investment from the Constitutional Budget Reserve (CBR) into a private equity scheme. 

Crum made the investment with DigitalBridge on his way out the door as Revenue commissioner. He resigned last August to run for governor. He’s one of a dozen Republicans running the open governor’s seat. 

Legislative leadership was not made aware of the investment until September. The Landmine broke the story on October 1. 

The Office of Governor Mike Dunleavy (R – Alaska) hired the D.C. law firm WilmerHale to investigate the matter. The no-bid contract cost the state $350,000.

There were multiple findings in their report, most notably that Crum violated the law when he did not obtain approval from the attorney general when he hired an outside law firm, Schulte, Roth, and Zabel, in connection with the CBR investment. 

The legislative audit found that Crum did not notify legislative leadership of his scheme even though the Senate Finance Committee told him in May 2025 that it was “highly likely” the CBR would be needed to balance the FY2027 budget, and possibly the FY2026 supplemental. 

The audit confirmed that Crum had originally sought to commit up to $225 million of the CBR to the scheme. That amount represents 7.5% of the $3 billion in the CBR. 

The audit also found that Crum did not adhere to Revenue investment policies and procedures when he made the non-routine investment. From the report: 

DOR had established investment policies and procedures for both routine and non-routine investments to help ensure fiduciary responsibilities were met. When making the non-routine CBRF investment, the commissioner did not adhere to several of DOR’s investment procedures; including:

    • Seeking guidance from the appropriate investment officer/subject matter experts to select and evaluate potential investments and possible alternative investments.
    • Documenting the determination that the investment opportunity was not better suited for other funding sources.
    • Documenting why seeking guidance from external auditors on potential concerns/disclosures was not necessary.
    • Disclosing the specific non-routine investments being considered to the investment advisory committee during its May quarterly State investment review meeting.
    • Notifying the Office of Management and Budget and the Division of Legislative Audit prior to the investment.
    • Informing the Senate and House Finance Committee chairs of the decision to move forward with the investment.
    • Updating the subaccount investment allocation in the Investment Policies and Procedures manual.

The Commissioner’s failure to follow DOR’s established investment procedures calls into question compliance with CBRF fiduciary responsibilities.

After this scandal was brought to light, the state ultimately opted to sell Crum’s loose investment – at a loss of $859,000. The state has refused to produce the contract Crum signed for the scheme or the contract in which they sold the investment. 

When asked about the audit and the investment scheme Crum attempted to make, Brian Fechter, a former deputy Revenue commissioner, told the Landmine:

The non-routine investment protocol was put into place because a lot of political figures with absolutely no investment expertise started having a lot of big ideas on how the almost $200 billion that the Department of Revenue is responsible for is invested. The goal was to insert real data and analytics into the investment decisions rather than gambling away the state’s Permanent Fund and retirement funds like some other states have.

The department had just come off a great controversy after making a foolhardy investment in the MOC 1 oil field that today is worthless. They did not want to repeat that mistake. The Department of Revenue has dozens of extremely qualified CFA investment charter holders that should have been advising him but, unfortunately, former Commissioner Adam Crum was able to sidestep this absolutely vital internal control and large sums of money are now gone.

Crum, who either can’t read or has no shame, put out a bizarre statement from his campaign claiming he “did everything by the book.” Both the WilmerHale report and the legislative audit found the exact opposite. 

Crum left the Department of Revenue in shambles. 

Janelle Earls has been the acting commissioner since Crum left, likely because they can’t find anyone who wants to clean up his mess. Earls was named acting commissioner in August. Dunleavy did not designate a commissioner after the start of the legislative session, though the the law says he is required to. Legislative leadership has rightfully decided that Earls will be subject to a confirmation vote in May. Otherwise, a precedent would be set where a governor could just name an acting commissioner as a department head who would never be subject to confirmation. 

There has been no deputy Revenue commissioner since April 2025 when Crum fired then-Deputy Revenue Commissioner Fidel Limani.

The Tax director has been in an acting role since May 2025 when then-Tax Director Dale Yancey resigned. 

The Department of Revenue is responsible for managing billions of dollars in state funds as well as overseeing complex tax matters and settlements. It is arguably the most important department in the state. 

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