ACAMS Today, March-May 2025 | Page 31

Most FIs do not have personnel familiar with campaign finance laws , as it is not part of typical anti-money laundering ( AML ) or fraud training . One violation , however , that seems to consistently manifest itself is the occurrence of straw donations , known legally as donating in the name of another . This is where an FI can play a significant role in recognizing and reporting this violation via a SAR .
Apart from the candidate , whose personal donations to their campaign are unlimited , donations from individuals are capped at certain amounts based on the office being sought . The architect of these straw donation schemes may be the candidate alone , but generally it is a political operative and / or the true wealthy donor . The concept is simple : Provide funds to individuals who in turn make the donation to the campaign . Ironically , while a candidate has no ceiling on their own funds , they can also funnel some of those funds to straw donors , thus creating the illusion of large-scale public support , which is also against the law .
Conceivably , in some cases a candidate new to the election process may be shielded from the scheme , believing their message has just resonated with the public . However , even a political novice should question why multiple strangers would donate at the maximum amount .
Of course , the source of funds in such a scheme would be subject to investigation . The true donor , however , is often just a wealthy individual with clean funds . Often , the true donor will not even make their own donation as their reputation may have a negative impact on the candidate . An example would be a builder who is facing community opposition to a controversial construction project supported by the candidate .
The straw donor
Who exactly are these mysterious straw donors ? They are often just regular people whose reasons for becoming involved can vary greatly . Some are hardened partisans who will do anything to help the candidate and / or the political party . They know that they are violating the law and generally do not care , emboldened
ACAMS Today | March – May 2025 31