In the Dark Money report I argue disclosure is entirely optional because payments as large as $20million can be concealed through donation splitting. Ie breaking large amounts into small payments that individually come in below the disclosure threshold.
This claim is often made about payments of $100,000. This based on making payments to separate branches. However the reality is worse. Payments made on separate days do not have to be aggregated. So you can pay $10,000 a day, 5 days a week, 50 weeks a year to eight branches and pay $20m without having to disclose.
My evidence that this is permissable is from AEC guidelines to political parties on how to complete their returns
Check it out for yourself! They even give an example.