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All told, major Chinese companies publicly acknowledge spending $3.8 million on
federal lobbying in 2017 and $20.2 million in total since 2000,22 modest amounts by
global standards. The Chinese e-commerce behemoth, Alibaba, was the largest source of
expenditures in 2017, accounting for $2 million, followed by technology company ZTE
($510k), Sinopec ($384k),23 and the Wanda America Group ($300k), affiliated with Dalian
Wanda.24 More difficult to track is Chinese corporate participation in American trade
associations. In early 2018, two Chinese companies have joined two major lobbying groups
noted for their political heft.25

Indirect Donations A key exception to the ban on foreign federal campaign contributions
is permitted through activity conducted via a US subsidiary of a foreign company.
The Federal Election Commission has written that “where permitted by state law, a US
subsidiary of a foreign national corporation may donate funds for state and local elections
if (1) the donations derive entirely from funds generated by the subsidiaries’ US operations,
and (2) all decisions concerning the donations, except those setting overall budget amounts,
are made by individuals who are US citizens or permanent residents.”

This exception inherently creates the potential for exploitation, particularly given the
intrinsic difficulties of monitoring and enforcement. For example, the Intercept has reported
that American Pacific International Capital (APIC), an American subsidiary of a corporation
owned by a Chinese citizen, contributed $1.3 million to the Super PAC of presidential
candidate Jeb Bush on the advice of a prominent Republican campaign finance lawyer.26
(Neil Bush, the brother of George W. and Jeb Bush, and former ambassador Gary Locke have
served as advisors of American Pacific International.)27

Employees of Chinese enterprises, who in making the donations are presumably American
citizens, are also active donors. A review of campaign donation data finds that several
individuals cited as members of the China General Chamber of Commerce or employed
by member firms have made recent campaign contributions. For example, two individuals
associated with HNA Group, including Tan Xiandong, the group’s president, in 2017
donated $2,500 each to the congressional campaign of Greg Pence, the brother of the vice
president.28

In May 2018, China-based companies reportedly invited Chinese to attend several
Republican Party fund-raising dinners at which President Trump would appear. The
invitations prominently featured the Republican Party’s logo along with that of
China Construction Bank, making it appear as if there was some formal connection.29
The Republican Party and China Construction Bank both denied awareness of the
solicitations in their name. Foreigners may attend fund-raisers so long as they do not pay
their own entry, another instance in which the fungibility of money makes it easy to
skirt this rule.

Section 7

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