BCRA added two more types of communications requiring this attribution: (1) general advertisements by political committees, and (2) “electioneering communications” by any person, that is, communications to a targeted electorate within certain periods before primary and general elections that refer to a federal candidate. Section 30120 does not cover anonymous communications that leave to inference the identity of a particular candidate. The FEC, acting pursuant to its advisory opinion authority under 52 U.S.C. § 30108, has excluded several categories of campaign advocacy (such as bumper stickers and skywriting) from the reach of this law. 11 C.F.R. § 110.11(a)(2). Although BCRA expanded the scope of Section 30120, only violations involving, generally, the two communications originally covered by the statute – communications that expressly advocate a federal candidate’s election or defeat and communications that solicit contributions – are subject to prosecution. Funds expended for such communications are “expenditures” under the Act, and are therefore subject to its criminal provision, section 30109(d)(1). Electioneering communications and general political advertising by political committees, on the other hand, generally involve “disbursements,” which are not reachable by the Act’s criminal provision. (e) 52 U.S.C. § 30121: Prohibition on contributions, donations, and expenditures by foreign nationals Section 30121 prohibits contributions and “donations” by foreign nationals to all United States elections, whether federal, state, or 138