[EL] An insidious foreign dark money threat: New reports about Russian money going to the NRA could prove watchdogs’ fears correct

[Jeff Hauser]

 "The NRA said that in fact they do receive foreign money, but not for
election purposes. [...]

*While the NRA claims it does not receive foreign money for election
purposes, the movement of its money between accounts could make it
difficult, if not impossible, to track how the money is spent since it is
not isolated or sequestered.*

The NRA has a variety of accounts, and the NRA Political Victory Fund is
their official political action committee and must report all of its
spending to the Federal Election Commission.

It also has other accounts that require less transparency, and do not
report spending to the FEC — and in those funds, the NRA told Wyden, they
"receive funds from foreign persons only for purposes not connected to
elections, as permitted by federal law."

*However, the NRA acknowledges that money moves between those accounts:
"transfers between accounts are made as permitted by law," the NRA's
general counsel wrote.*

The NRA did not immediately respond to a request from NPR to disclose the
total sum of its donations from foreign sources."
https://www.npr.org/2018/03/27/597279176/nra-says-it-receives-foreign-funds-but-none-goes-to-election-work


On Sat, Jan 20, 2018 at 10:04 AM, Smith, Brad <BSmith at law.capital.edu>
wrote:

> I hope that this is adding light, not just heat, especially to those not
> steeped in this aspect of election law.
>
> Jeff writes:
> *"Issue ads" are known to be a falsely narrow dumb legalism by anyone who
> works in electoral politics.*
>
> This argument merely indicates an unwillingness to come to grips with the
> reason for the distinction between issue ads, that, per Buckley v. Valeo,
> have been largely unregulated, and political ads, which are much more
> heavily regulated. One might disagree that Buckley was right in making the
> distinction, but it's not a falsely dumb legalism by any means. The Buckley
> Court itself recognized the dilemma:
>
> "the distinction between discussion of issues and candidates and advocacy
> of election or defeat of candidates may often dissolve in practical
> application. ... [but]
>
> "constitutional deficiencies [of vagueness and overbreadth] can be
> avoided only by reading § 608(e)(1) [of FECA] as limited to
> communications that include explicit words of advocacy of election or
> defeat of a candidate, ...
>
> "in order to preserve the provision against invalidation on vagueness
> grounds, § 608(e)(1) must be construed to apply only to expenditures for
> communications that, in express terms advocate the election or defeat of a
> clearly identified candidate for federal office. ...
>
> "assuming, *arguendo,* that large independent expenditures pose the same
> dangers of actual or apparent *quid pro quo* arrangements as do large
> contributions, § 608(e)(1) does not provide an answer that sufficiently
> relates to the elimination of those dangers. ... The exacting
> interpretation of the statutory language necessary to avoid
> unconstitutional vagueness thus undermines the limitation's effectiveness
> as a loophole-closing provision by facilitating circumvention by those
> seeking to exert improper influence upon a candidate or officeholder. *It
> would naively underestimate the ingenuity and resourcefulness of persons
> and groups desiring to buy influence to believe that they would have much
> difficulty devising expenditures that skirted the restriction on express
> advocacy of election or defeat, but nevertheless benefited the candidate's
> campaign."*
>
>
> 424 U.S. 1, 42-45
> <https://maps.google.com/?q=U.S.+1,+42-45&entry=gmail&source=g> (emphasis
> added).
>
> In other words, the Court understood your argument, Jeff, but it put the
> distinction in place for other reasons--crudely put, to prevent FECA from
> swallowing up the First Amendment in its entirety.
>
> So your argument is kind of like complaining that those nearly ubiquitous
> electronic pet fences we now see do nothing to keep stray animals or
> trespassers out of the owners yard. True, but that's not why people install
> them.
>
> All this is why I ask in part how much disclosure and regulation will
> satisfy you, and what definitions you want to use.
>
> For example, our listmeister Rick and I both do lots of stuff--op-ed
> writing, talking to reporters, amicus briefs, public speaking--that might
> influence how others eventually vote, and so do many others on this
> listserv. Our work is supported, in part, by donors to our respective
> academic institutions. Should those donations be publicly reported and
> disclosed? Should those donors be identified as paying for the
> dissemination of our views? I don't think so, and I doubt you do either.
> But what line do you want to draw? It's not good enough to just say "stuff
> that will influence an election" or is "intended to influence an election"
> or something like that, because at some point we will need to flesh out a
> legal definition--what both Rick and I do probably meets those vague
> definitions. I'm not saying that coming up with a workable standard can't
> be done, and there are perfectly good reasons for arguing it should be
> tried. I'm only saying it has to be done if we're then going to be able to
> talk about the merits of your proposal for a significant regulatory
> expansion over the discussion of public affairs.
>
> In the meantime, the traditional definition of political advocacy is
> express advocacy and, since 2003, "electioneering communications" as
> defined by statute. And that is what proposals such as the California
> statute described by Trent aim to cover, what Sean was discussing, what is
> discussed in the article you link to and in Ciara's article that Rick
> linked to, what Jonathan Singer was discussing in the post from 2010 that
> you quoted in starting this thread.
>
> So in terms of the original conversation, you are moving the goal posts.
> You wanted to take issue with my point that only about 3% of political
> spending is what is loosely called "dark money." Your argument for that,
> however, centers around a vague (but it appears quite significant)
> expansion of the definition of political spending. The traditional
> definition I use includes spending by political committees, independent
> expenditures, and electioneering communications (as defined by statute),
> and the number is 3 percent, more or less (less in 2016). That's what the
> great "dark money" debate has centered on for the past 8 years. And that
> was the subject of *your* original post that launched this thread.
>
>
> *Bradley A. Smith*
>
> *Josiah H. Blackmore II/Shirley M. Nault*
>
> *   Professor of Law*
>
> *Capital University Law School*
>
> *303 E. Broad St.
> <https://maps.google.com/?q=303+E.+Broad+St.%0D+Columbus,+OH+43215&entry=gmail&source=g>*
>
> *Columbus, OH 43215
> <https://maps.google.com/?q=303+E.+Broad+St.%0D+Columbus,+OH+43215&entry=gmail&source=g>*
>
> *614.236.6317*
>
> *http://law.capital.edu/faculty/bios/bsmith.aspx
> <http://law.capital.edu/faculty/bios/bsmith.aspx>*
> ------------------------------
> *From:* Jeff Hauser [jeffhauser at gmail.com]
> *Sent:* Saturday, January 20, 2018 7:07 AM
>
> *To:* Smith, Brad
> *Cc:* Rick Hasen; Sean Parnell; Election Law Listserv
> *Subject:* RE: [EL] An insidious foreign dark money threat: New reports
> about Russian money going to the NRA could prove watchdogs’ fears correct
>
> "Issue ads" are known to be a falsely narrow dumb legalism by anyone who
> works in electoral politics.
>
> Social media makes that even more so, since you build your fan base on
> Facebook via ads and then deploy through "organic engagement," which keeps
> most useful Facebook spending outside the time window.
>
> And digital is very relevant because our knowledge of it is vastly less
> than that of TV ads, for which serious expenditure estimates are possible.
>
> On Jan 19, 2018 10:29 PM, "Smith, Brad" <BSmith at law.capital.edu> wrote:
>
> Ah, you want to include issue ads? But if that's the case, "enormous
> amounts" of non-digital spending are not disclosed, either. That gets to
> the question of what is "political spending."
>
> But it's worth noting that we don't even try or purport to ban foreign
> spending on issue ads, not to mention lobbying.
>
> In short, you are calling here for an enormous increase in the current
> regulatory regime. That may be justified, but we should be clear that that
> is what you are advocating. And at that point, "digital" has nothing to do
> with it--the relevant category is not the medium, but the message. What you
> need to define is what type of messaging you think should be subject to
> compulsory disclosure.
>
> Meanwhile, the discussion of 501(c)(4) spending, including disclosure laws
> such as those advocated by Trent Lange, and Rick's concern about
> undisclosed (c)(4) spending, pertain to the traditional definitions of
> political spending. Again, using the standard for political advertising in
> effect since the 1976 decision in Buckley v. Valeo, plus its expansion to
> include "electioneering communications" in 2003, spending for which the
> "true" or "actual" source of funding is unknown is a very small percent of
> the total--about 3%.
>
>
> *Bradley A. Smith*
>
> *Josiah H. Blackmore II/Shirley M. Nault*
>
> *   Professor of Law*
>
> *Capital University Law School*
>
> *303 E. Broad St.
> <https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+E.+Broad+St.%250D+Columbus,+OH+43215%26entry%3dgmail%26source%3dg&c=E,1,jBRVMvYChE16HSqn8i5rJPf44Mw7XBhuCyNw1w6_J4pJrtyE3b7NW7KRXlC1BEbh-syGiBQnzkRNxWGu7sitgVoSISgzGYqiQnWOpLJiLLlrgm_WIVQ_k-Qw13U,&typo=1>*
>
> *Columbus, OH 43215
> <https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+E.+Broad+St.%250D+Columbus,+OH+43215%26entry%3dgmail%26source%3dg&c=E,1,nWMOgZ2pKyzObTnFENUopEkyBSPpw2OwPZSljelU8OBl5VP4eU9iCawu5wlpZyEAFDEortkxWNhXIVaeFr3bzKBaHnz4kCPgYR109HjkR51ZxJNdv5RzGrnc&typo=1>*
>
> *614.236.6317*
>
> *http://law.capital.edu/faculty/bios/bsmith.aspx
> <http://law.capital.edu/faculty/bios/bsmith.aspx>*
> ------------------------------
> *From:* Jeff Hauser [jeffhauser at gmail.com]
> *Sent:* Friday, January 19, 2018 10:13 PM
>
> *To:* Smith, Brad
> *Cc:* Rick Hasen; Sean Parnell; Election Law Listserv
> *Subject:* RE: [EL] An insidious foreign dark money threat: New reports
> about Russian money going to the NRA could prove watchdogs’ fears correct
>
> You're claiming all c4 issue ads on the Internet about politicians are
> disclosed to the FEC? Is that seriously your claim?
>
> And the fact that a Senator took the number of the first, nearly one year
> overdue concession from Facebook that ads purchased in rubles from St.
> Petersburg,  Russia about politicians might be problematic doesn't mean
> that is even a tiny fraction of what was being spent in both ads and paid
> trolls.
>
> On Jan 19, 2018 9:54 PM, "Smith, Brad" <BSmith at law.capital.edu> wrote:
>
> Jeff,
>
> What is your evidence for claiming that "enormous amounts of digital
> spending is not available to the FEC"?
>
> 52 U.S.C. 30104(c)(1): Every person (other than a political committee) who
> makes independent expenditures in an aggregate amount or value
> in excess of $250 during a calendar year shall file a statement
> containing the information required under subsection (b)(3)(A)
> of this section for all contributions received by such person.
>
> That includes internet spending.
>
> There is, of course, a fair amount of all kinds of spending that is not
> disclosed--independent expenditures by a person aggregating less than $250,
> some spending on membership communications, that sort of thing. But even
> including such longstanding provisions, which also apply to the web, what
> is your evidence, or even reason for believing, that "enormous amounts of
> digital spending is not available to the FEC"? I know of nothing to suggest
> that, and of course, by and large "enormous amounts" of unreported spending
> would already be illegal.
>
> I'd note that in introducing the "honest ads" act, Senator Klobuchar
> stated that “$1.4 billion was spent on online advertising in the 2016
> election." As her source, she cited https://www.borrellassoc
> iates.com/industry-papers/papers/2015-to-2016-political-adve
> rtising-outlook-august-15-detail
> <https://linkprotect.cudasvc.com/url?a=https://www.borrellassociates.com/industry-papers/papers/2015-to-2016-political-advertising-outlook-august-15-detail&c=E,1,QaaA7zw64OO4qJBNecL_PEdRKMaGQKob9uTvrv5rBaCgnMQneKfs0uyjJUvBuSJSe0dvtpso1-8YpHG98Uo69uGIlSBMWTGTssLT3V0aJxs,&typo=1>
> .  https://www.borrellassociates.com/industry-papers/
> papers/2015-to-2016-political-advertising-outlook-august-15-detail.
> <https://linkprotect.cudasvc.com/url?a=https://www.borrellassociates.com/industry-papers/papers/2015-to-2016-political-advertising-outlook-august-15-detail.&c=E,1,T1N21LcaiSWoiQBOnyjWk7MaudG0xezVlOMK0rs8qedq1jxWtzXRwDhJzQAfxhLoSQBkn_rNEyb1m6SRwO5Cbf2LFnamDHzFknLylHT_0AWQ7NqM9r0n-wdH848B&typo=1>
> In turn, the legislative findings in Section III of the Honest Ads Act
> notes that Facebook reported "between June 2015 and May 2017, Russian
> entities purchased $100,000 in political advertisements."
>
> *Bradley A. Smith*
>
> *Josiah H. Blackmore II/Shirley M. Nault*
>
> *   Professor of Law*
>
> *Capital University Law School*
>
> *303 E. Broad St.
> <https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+E.+Broad+St.%250D+Columbus,+OH+43215%26entry%3dgmail%26source%3dg&c=E,1,_gCMEcFXcPC6nmrCmc4KcrJWP1u5aLhU4xKvIGBOedNdpHplJTPGgHRD3loCiVI_PTRNs0XWst2cNJ6719_yxq7OQ70LqBAdD-Jjlos4gYPwkJZ-tMHBlFKHJlg,&typo=1>*
>
> *Columbus, OH 43215
> <https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+E.+Broad+St.%250D+Columbus,+OH+43215%26entry%3dgmail%26source%3dg&c=E,1,TveNBivOhp4efux3fQBGRLh4RTGAirWAM8mAGpf-MrwCLnb3AlAL0kGwKPr_yjemShOqOma9muuHQ9m4oCRi5Nx59sov-K5xRcsBNcGaBFE,&typo=1>*
>
> *614.236.6317*
>
> *http://law.capital.edu/faculty/bios/bsmith.aspx
> <http://law.capital.edu/faculty/bios/bsmith.aspx>*
> ------------------------------
> *From:* Jeff Hauser [jeffhauser at gmail.com]
> *Sent:* Friday, January 19, 2018 12:54 PM
>
> *To:* Smith, Brad
> *Cc:* Rick Hasen; Sean Parnell; Election Law Listserv
> *Subject:* Re: [EL] An insidious foreign dark money threat: New reports
> about Russian money going to the NRA could prove watchdogs’ fears correct
>
> Brad first wrote," What would such a statute look like? I’ve never really
> seen one that solves the alleged problem without creating double reporting,
> and often providing misleading information to the public.
>
>
>
> And always remember, we’re talking about approximately 3%, more or less
> (less last year)* of political spending.*"
>
>
> He then wrote, "I didn’t give any statisitics on digital spending. I gave
> stats on total spending. We at IFS derive those from Open Secrets and
> from FEC records."
>
>
> But an enormous amount of digital spending is not available to either Open
> Secrets or the FEC.
>
>
> If you purport to discuss the denominator of "political spending," you are
> purporting to know the actual amount of digital spending.
>
>
> But since you cannot know the full amount of digital spending. you should
> not be making claims about "political spending."
>
>
>
>
>
>
> On Fri, Jan 19, 2018 at 12:49 PM, Smith, Brad <BSmith at law.capital.edu>
> wrote:
>
>> I didn’t give any statisitics on digital spending. I gave stats on total
>> spending.
>>
>>
>>
>> We at IFS derive those from Open Secrets and from FEC records.
>>
>>
>>
>> *Bradley A. Smith*
>>
>> *Josiah H. Blackmore II/Shirley M. Nault *
>>
>> *  Professor of Law*
>>
>> *Capital University Law School*
>>
>> *303 East Broad Street
>> <https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+East+Broad+Street%250D+_Columbus,+OH+43215_%26entry%3dgmail%26source%3dg&c=E,1,6878QynwdMpnK9GVhwjPbemedLwLIH_8fEwSSXDgQ9QFY4ElackKG-vv2dK5tDzIAYuSv58uuGQ8SsaydVwCzUkGK4_dd52K4HmlTmV8ExyxHQ,,&typo=1>*
>>
>> *Columbus, OH 43215
>> <https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+East+Broad+Street%250D+_Columbus,+OH+43215_%26entry%3dgmail%26source%3dg&c=E,1,ZcV0uDmN9xndIIneN0YtMXyLq0Ff-eIwdAWPQZFvR3cpezrHoM5w7uByXqg3W8Swxw7NuIauQuYggSAuG4mUqv8UAwT5VlETmWSWuN78x7xtVwV9X_C9&typo=1>*
>>
>> *(614) 236-6317*
>>
>> *bsmith at law.capital.edu <bsmith at law.capital.edu>*
>>
>> *http://www.law.capital.edu/faculty/bios/bsmith.asp
>> <http://www.law.capital.edu/faculty/bios/bsmith.asp>*
>>
>>
>>
>> *From:* Jeff Hauser [mailto:jeffhauser at gmail.com]
>> *Sent:* Friday, January 19, 2018 12:46 PM
>> *To:* Smith, Brad
>> *Cc:* Rick Hasen; Sean Parnell; Election Law Listserv
>>
>> *Subject:* Re: [EL] An insidious foreign dark money threat: New reports
>> about Russian money going to the NRA could prove watchdogs’ fears correct
>>
>>
>>
>> "And always remember, we’re talking about approximately 3%, more or less
>> (less last year) of political spending."
>>
>>
>>
>> Brad, what is your source of statistics on total digital political
>> spending in 2016, and the proportion disclosed?
>>
>>
>>
>> On Fri, Jan 19, 2018 at 12:43 PM, Smith, Brad <BSmith at law.capital.edu>
>> wrote:
>>
>> What would such a statute look like? I’ve never really seen one that
>> solves the alleged problem without creating double reporting, and often
>> providing misleading information to the public.
>>
>>
>>
>> And always remember, we’re talking about approximately 3%, more or less
>> (less last year) of political spending.
>>
>>
>>
>> *Bradley A. Smith*
>>
>> *Josiah H. Blackmore II/Shirley M. Nault *
>>
>> *  Professor of Law*
>>
>> *Capital University Law School*
>>
>> *303 East Broad Street
>> <https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+East+Broad+Street%250D+_Columbus,+OH+43215_%26entry%3dgmail%26source%3dg&c=E,1,S7bonyLVvU0kPXLO0VvCJ05LsPUKl_xAUWIrdanWxC1UNwSpHpjJ2fJbgL8LJglwPWU6dATnYbrzMcQBBZypXcy1pQRqc-AGtGMkE9rbffoKl64,&typo=1>*
>>
>> *Columbus, OH 43215
>> <https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d303+East+Broad+Street%250D+_Columbus,+OH+43215_%26entry%3dgmail%26source%3dg&c=E,1,-_-oWvTskmv9apWftdyGAG2EOw-gwMA4BDrbFhC95JMSBnT0MATCP7vSYI8tmqlT-RAtOTkVniOuJSRyRj0ummkO-me6wcrrSxyK0-LQI5Bhi30aw3fO1s0f&typo=1>*
>>
>> *(614) 236-6317*
>>
>> *bsmith at law.capital.edu <bsmith at law.capital.edu>*
>>
>> *http://www.law.capital.edu/faculty/bios/bsmith.asp
>> <http://www.law.capital.edu/faculty/bios/bsmith.asp>*
>>
>>
>>
>> *From:* Law-election [mailto:law-election-bounces at d
>> epartment-lists.uci.edu] *On Behalf Of *Rick Hasen
>> *Sent:* Friday, January 19, 2018 12:28 PM
>> *To:* Sean Parnell; Jeff Hauser
>> *Cc:* Election Law Listserv
>>
>>
>> *Subject:* Re: [EL] An insidious foreign dark money threat: New reports
>> about Russian money going to the NRA could prove watchdogs’ fears correct
>>
>>
>>
>> That seems like a pretty good argument for Congress to pass improved
>> disclosure laws, regardless of the tax status of a particular organization,
>> for any organization or person who spends or contributes BIG money (I’d
>> raise thresholds dramatically) on election-related activity (we can discuss
>> how that is best defined, but at least extending electioneering
>> communications to digital ads seems like a good start).
>>
>>
>>
>> This way we know where the ultimate source of money is, without allowing
>> the kind of shell games to go on.
>>
>>
>>
>>
>>
>> *From: *Sean Parnell <sparnell at philanthropyroundtable.org>
>> *Date: *Friday, January 19, 2018 at 9:22 AM
>> *To: *Jeff Hauser <jeffhauser at gmail.com>, Rick Hasen <rhasen at law.uci.edu>
>> *Cc: *Election Law Listserv <law-election at uci.edu>
>> *Subject: *RE: [EL] An insidious foreign dark money threat: New reports
>> about Russian money going to the NRA could prove watchdogs’ fears correct
>>
>>
>>
>> And the same goes for the public, of course, who would only see “We’re
>> Totally Not The Russians LLC” listed on whatever form of disclosure is
>> envisioned by Ciara and others in the “reform” community.
>>
>>
>>
>> Sean
>>
>>
>>
>>
>>
>> *From:* Jeff Hauser [mailto:jeffhauser at gmail.com <jeffhauser at gmail.com>]
>> *Sent:* Friday, January 19, 2018 12:11 PM
>> *To:* Rick Hasen <rhasen at law.uci.edu>
>> *Cc:* Sean Parnell <sparnell at philanthropyroundtable.org>; Election Law
>> Listserv <law-election at uci.edu>
>> *Subject:* Re: [EL] An insidious foreign dark money threat: New reports
>> about Russian money going to the NRA could prove watchdogs’ fears correct
>>
>>
>>
>> Michael Cohen has been alleged by the Wall Street Journal to create an
>> LLC to pay off an actress aleged to have an affair with Trump:
>> https://www.wsj.com/articles/trump-lawyer-used-privat
>> e-company-pseudonyms-to-pay-porn-star-stormy-daniels-1516315
>> 731?utm_source=The+Point+with+Chris+Cillizza+Alerts&utm_camp
>> aign=d827904afa-EMAIL_CAMPAIGN_2018_01_19&utm_medium=email&
>> utm_term=0_ada7c7ac0a-d827904afa-83775533
>>
>>
>>
>> If Russians created shell companies in Delaware to give money to the NRA,
>> all the IRS would see is "Delaware LLC."
>>
>>
>>
>> (the NRA would presumably make inquiries about any unexpected
>> contributions, and I doubt they lack information on who is giving them big
>> money)
>>
>>
>>
>> On Fri, Jan 19, 2018 at 11:59 AM, Rick Hasen <rhasen at law.uci.edu> wrote:
>>
>> Has the NRA issued any public statements denying the receipt of money
>> from Russian government sources/sources allied with Russian government
>> which were used by its c4 for election-related activity?
>>
>>
>>
>>
>>
>> *From: *Sean Parnell <sparnell at philanthropyroundtable.org>
>> *Date: *Friday, January 19, 2018 at 8:55 AM
>> *To: *Rick Hasen <rhasen at law.uci.edu>, Election Law Listserv <
>> law-election at uci.edu>
>> *Subject: *re: An insidious foreign dark money threat: New reports about
>> Russian money going to the NRA could prove watchdogs’ fears correct
>>
>>
>>
>> I wanted to clear up what some might mistakenly infer from the piece by
>> Ciara Torres-Spelliscy linked to below concerning the latest speculation
>> regarding foreign money, Donald Trump, and those pesky Russians (hold on a
>> sec, it appears the 1980’s are calling and wish to talk to me about
>> something). She writes:
>>
>> *For many years now, good-government groups and campaign finance experts
>> have warned that illegal foreign funds could be hiding in that dark money.*
>>
>> *That’s because, in federal races, political spenders that go dark are
>> exploiting a loophole between the campaign finance system overseen by the
>> FEC, which typically insists on that all donors to campaigns identify
>> themselves, and charities the Internal Revenue Service allows to collect
>> funds donated anonymously.*
>>
>> Three things:
>>
>>    1. The National Rifle Association is not a “charity,” at least as
>>    defined by the IRS. It’s a 501c4 “social welfare” organization (it does
>>    have an associated foundation, which is a 501c3, but I don’t believe it’s
>>    alleged that this entity was funding any political ads, let alone
>>    Russian-funded ads).
>>    2. While the NRA and other 501c organizations do not reveal donors to
>>    the public, they do reveal them to the IRS (or at least are required to) on
>>    Schedule B. Presumably, if there is a concern that the NRA took in millions
>>    of dollars from Russian sources (whether state or “private” to the extent
>>    there’s any distinction in Russia), it should be relatively easy for the
>>    FBI to get the information from the IRS (I’m not sure if it requires a
>>    subpoena or not in this particular instance, but law enforcement is able to
>>    get confidential tax records). I’d guess that someone at the NRA handed a
>>    few million dollars by a Putin pal would have realized this and handed it
>>    back, if such a highly-speculative transaction occurred, but then there are
>>    some imprudent people out there so who knows?
>>    3. Anonymous contributions to charities are hardly a “loophole,” it
>>    is in fact a practice with a long and deeply ingrained history in
>>    philanthropy, praised in the Gospel of Matthew 6:1 – 6:4 and also by Seneca
>>    the Younger, among others. I’ve written an overview of anonymous charitable
>>    giving, published last year, if anyone is interested:
>>    http://www.philanthropyroundtable.org/file_uploads/Protectin
>>    g_Donor_Privacy.pdf
>>    <https://linkprotect.cudasvc.com/url?a=http://www.philanthropyroundtable.org/file_uploads/Protecting_Donor_Privacy.pdf&c=E,1,yB8z6rp4LjNjM5ymoJ1dImrzWM79VhYNJoqxPC_XoXt9GjQT0InnValyOCkhJtMP_8pHZoIqhgWkOAemSMJDexQDkzwm71eIcqSOvJJOrtAElXaUNJul5RoCSQ,,&typo=1>
>>
>> Best,
>>
>> Sean Parnell
>>
>> Vice President of Public Policy, The Philanthropy Roundtable
>>
>> 1120 20th Street NW, Suite 550
>> <https://linkprotect.cudasvc.com/url?a=https://maps.google.com/%3fq%3d1120+20th+Street+NW,+Suite+550%26entry%3dgmail%26source%3dg&c=E,1,ZSWvIYPRn84sKS13Ax9ZK6c-a2JJcOUgmhZh1u-6g3eKfV7j8xw-gLwMl08sCin-6g7wtZuMFxZmB-uGLA8YLHKgrMoMk86BMOji7S_G7S4,&typo=1>
>> South
>>
>> Washington, DC  20036
>>
>> (202) 600-7883 (direct)
>>
>> (571) 289-1374 (mobile)
>>
>> sparnell at philanthropyroundtable.org
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>> *“An insidious foreign dark money threat: New reports about Russian money
>> going to the NRA could prove watchdogs’ fears correct”
>> <https://linkprotect.cudasvc.com/url?a=http://electionlawblog.org/%3fp%3d96992&c=E,1,BKi2Bl65mU5t49bOewqAU826TvtS3eDYa8NI60HN9UKbJwZj9V_sIszWT4hRZH5TMPfGuNrBkBlk_HzUjasx-ls5ZBiDEC-68FaeWbdVmqYtQ3BuUgXvZw,,&typo=1>*
>>
>> Posted on January 19, 2018 7:16 am
>> <https://linkprotect.cudasvc.com/url?a=http://electionlawblog.org/%3fp%3d96992&c=E,1,3Vamj5-VOxEeYqxdG_0blzHJ_2qRAmm75-uAR2swPatBXSs7ZH531VACjxuix2nc-mHZX-jT4DVvLzUnxoTizF19Ja3SzFcXdCbB4v8u1bx8gYB9rZ-WLLLDuQ,,&typo=1>
>>  by *Rick Hasen*
>> <https://linkprotect.cudasvc.com/url?a=http://electionlawblog.org/%3fauthor%3d3&c=E,1,SmymVOI1x1o5FHgDBghPFJE8Hid_DkCm86r_yypWpQTeY8-KPIdE14N1JZQb4O6F_-vpZzg3JqhoHNCGleWkr37i6H98w7w83AhogQ0c9tNg5evNeuyq&typo=1>
>>
>> Ciara Torres-Spelliscy
>> <http://www.nydailynews.com/opinion/insidious-foreign-dark-money-threat-article-1.3765048> NYDN
>> oped.
>>
>> Posted in campaign finance
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D96992&title=%E2%80%9CAn%20insidious%20foreign%20dark%20money%20threat%3A%20New%20reports%20about%20Russian%20money%20going%20to%20the%20NRA%20could%20prove%20watchdogs%E2%80%99%20fears%20correct%E2%80%9D>
>>
>>
>> _______________________________________________
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>> Law-election at department-lists.uci.edu
>> https://department-lists.uci.edu/mailman/listinfo/law-election
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D96992&title=%E2%80%9CAn%20insidious%20foreign%20dark%20money%20threat%3A%20New%20reports%20about%20Russian%20money%20going%20to%20the%20NRA%20could%20prove%20watchdogs%E2%80%99%20fears%20correct%E2%80%9D>
>>
>>
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D96992&title=%E2%80%9CAn%20insidious%20foreign%20dark%20money%20threat%3A%20New%20reports%20about%20Russian%20money%20going%20to%20the%20NRA%20could%20prove%20watchdogs%E2%80%99%20fears%20correct%E2%80%9D>
>>
>>
>>
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