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It is unethical and illegal for public servants to evade the caps and the prohibition on any donation by foreign entities at all, under U.S. campaign finance law. The Foreign Corrupt Practices Act defines such behavior as corrupt. FCPA has harsh criminal penalties for any American who seeks to influence a foreign official by donating to his or her related charity — a standard way of money-laundering bribes. CF is no charity. This is a for-profit operation that brokers funds that it raises to other charities. Brokering is its sole activity and that is not a charitable activity. CF is soliciting the wealthy to pay to it huge sums with no scrutiny as to its arrangements downstream, using the allure of a promise of influence at the highest levels of the U.S. CF then takes a cut off the top far greater than the fair market value of these same services if performed by any for-profit broker — call it 10% of the gross, which, at these levels, would not only cover all costs, but a shockingly healthy profit margin for the fundraiser.

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