from the personal resources of corporate or union officials, provided, of course, that the value of the funds given or spent are not reimbursed or otherwise passed back to a corporate or a union fisc such that the corporation or union would be engaging in conduct prohibited by the statute. As with all other FECA violations, to reach the level of a Section 30118 criminal violation, the act had to have been committed “willfully.” Absent direct evidence of such criminal intent (as through a confession), a prosecution under Section 30118 will most likely be successful when funds were diverted from a corporate or union treasury and laundered in some fashion to a candidate or when an entity using corporate or union funds to engage in election activity coordinates its expenditures with a candidate. (c) 52 U.S.C. § 30119: Prohibition on contributions by government contractors Section 30119 prohibits any person who is a signatory to, or who is negotiating for, a contract to furnish material, equipment, services, or supplies to the United States government, from making or promising to make a contribution “for any political purpose.” It has been construed by the FEC to reach only contributions for the purpose of influencing the nomination or election of candidates for federal office. See 11 C.F.R. § 115.2(a). The statute applies to all types of businesses, including sole proprietorships, partnerships, and corporations, and reaches gifts made from such entities’ business or partnership assets. 56 With respect to partnerships, however, the FEC has determined that Section 30119 does not prohibit contributions made from the personal assets of the partners, provided of course, that The D.C. Circuit reaffirmed that the ban on individual contractor contributions furthers the government’s compelling interest in preventing quid pro quo corruption and the appearance of corruption in an 11-0 en banc decision. See Wagner v. Fed. Election Comm’n, 793 F.3d 1 (D.C. Cir. 2015). 56 136