defined for purposes of Section 30121 as “disbursements” and therefore are not covered by the Act’s criminal penalty. The term “foreign national” means: (1) a “foreign principal” within the meaning of the Foreign Agents Registration Act, 22 U.S.C. § 611, and (2) any person who is not a citizen of the United States, or a national of the United States who is not lawfully admitted for permanent residence. 52 U.S.C. § 30121(b). A “foreign principal” includes a foreign government, a foreign political party, and a corporation organized under the laws of a foreign country. None of these entities may make contributions or donations to any candidate or political party in the United States. Through its regulations, advisory opinions, and civil enforcement actions, the FEC has addressed the application of Section 30121 to contributions by domestic subsidiaries of foreign corporations. 59 The Commission has determined that a domestic subsidiary that is chartered under the laws of any state or United States territory, and has its principal place of business in the United States, is not a foreign principal – even though all of its capital stock may be owned by foreign individuals or entities. The FEC has, however, concluded that Section 30121 prohibits contributions by a domestic subsidiary if the parent foreign corporation provides funding for the contribution, or if individual foreign nationals are involved in any way in making the contribution. In 1991, the FEC rejected proposed rulemaking that would have expanded the scope of Section 30121 to include domestic subsidiaries of foreign-owned entities. There are significant enhancements for FECA violations involving a foreign national or foreign government. U.S.S.G. § 2C1.8(b)(2). The Guideline is discussed in Chapter Six. Persons who rely in good faith on an FEC advisory opinion may be immune from sanctions under FECA, including criminal prosecution. 52 U.S.C. § 30108(c)(2). 59 140