BloombergPolitics reported this morning that the Clinton Foundation refused to disclose the identities of at least 1,100 donors, most of whom are not U.S. citizens, to a Clinton Foundation affiliate. The donations were routed through the Clinton Giustra Enterprise Partnership (Canada), or CGEPartnership, a Canadian charitable organization. That organization then effectively bundled the foreign donations and sent them along to the Clinton Foundation itself, and it did all of this without ever disclosing the individual foreign sources of the income.

If that sounds to you like more of a laundering operation than a charitable organization, that’s because it certainly looks like more of a laundering operation than a charitable organization. In this case, however, rather than taking cash from blatantly illegal activities (as far as we know) and then cleaning it up by running it through legitimate businesses before it ends up at its final destination, the Clinton Foundation mops up cash from wealthy foreigners, bundles it within a larger organization to hide the money’s original source, and then funnels the cash from that legitimate charity right into the Clinton Foundation coffers.

After the New York Times uncovered the connections between uranium mining magnate Frank Giustra, his Canadian charitable organization, the Clinton Foundation, and official actions taken by Secretary of State Hillary Clinton that benefitted Giustra’s global uranium mining operations, the Clinton Foundation immediately entered spin mode.

According to Clinton Foundation executives, CGEPartnership was banned by federal law in Canada from releasing any donor names without the prior consent of the donor. However, an extensive analysis of Canada’s federal privacy laws by The Federalist found that the Clinton Foundation’s claim had zero merit.

Multiple Canadian tax and privacy law experts contacted by The Federalist, the Washington Post, and BloombergPolitics said there was no such blanket prohibition on public disclosure of charitable donor identities. While Canada does include a ban on the release of donor information in the course of commercial activity, it specifically exempts fundraising from that definition. And because the public disclosure of a donor’s name doesn’t include any transaction or consideration, it’s not considered to be commercial activity.

“Federal law prohibits disclosure related to commercial activity: things like selling, renting, or bartering of a list. Fundraising is not a covered activity under PIPEDA, the federal privacy law,” Adam Aptowitzer, a Canadian charitable organization attorney, told The Federalist.

“I don’t see how the public disclosure of a donor’s name constitutes commercial activity,” Aptowitzer concluded. “There’s no transaction; there’s no consideration.”

The Clinton Foundation’s deliberate misinterpretation of Canadian privacy law in order to rationalize its secrecy raises several questions, chief among them: why? Why go to all this effort to hide years’ worth of million-dollar donations from foreign citizens and foreign governments? Donations which were almost certainly being made while Hillary Clinton was serving as Secretary of State, and almost certainly with the intent to influence her decisions?

The Clinton Foundation looks more and more like a foreign laundering operation than a charitable organization.

The answer is an easy one, albeit one that is highly uncomfortable: for the past several years, the Clinton Foundation has basically been a foreign money-laundering operation. The scheme works like this: collect millions of dollars in foreign money, dump it into a foreign charity, pretend that the law prohibits you from ever disclosing the identities of those foreign donors to the foreign charity, then have the foreign charity bundle all the cash and send it to the Clinton Foundation. Then, when the time comes–whether it be a Clinton Foundation conference or a lavish Clinton Foundation trip overseas–make sure those individuals get some me-time with the Clintons.

As The Federalist detailed earlier this week, the Clinton Foundation spun off the bulk of its charitable medical activities back in 2010. By 2013, the main Clinton Foundation entity — the Bill, Hillary, and Chelsea Clinton Foundation — housed only a handful of charitable initiatives, the largest of which existed solely to serve the Clintons, via their conference series and the Clinton presidential library, rather than truly charitable causes. In 2013, for example, the Clinton Foundation spent less than 10 percent of its budget on charitable grants.

The foreign-to-domestic laundering scheme satisfies a number of key Clinton objectives. First, it gave Secretary of State Hillary Clinton total plausible deniability about the millions in foreign cash that were being funneled into her family’s non-profit coffers. She wasn’t on the board of CGEPartnership, and wasn’t even named to the board of the Clinton Foundation until 2013, so how could she have known about this? Second, it gave Hillary’s allies the ability to claim that wealthy foreign individuals were not sending cash to the Clinton Foundation.

How? Because they were sending cash to the Canadian CGEPartnership. And while Bill Clinton’s name is obviously in the organization’s name, he never actually served on its board while Hillary was Secretary of State. Instead, Clinton retained control of the organization by placing Bruce Lindsey on CGEPartnership’s board. Lindsey, a long-time Clinton confidant and adviser, currently serves as the chairman of the board of the Clinton Foundation. He was also the Clinton Foundation’s CEO for over a decade.

If you look holistically at the entire scheme’s setup, at the massive flow of foreign cash, at the refusal to disclose donors, at the secret (and now destroyed) private e-mail servers, at the blatantly bogus excuses, at the falsified tax returns, everything about it suddenly makes a lot more sense.

From soup to nuts, the entire operation was constructed in order to provide a facade of plausible deniability for Hillary Clinton. Conceal the cash. Hide the donors. Delete the e-mails. The circumstantial evidence is overwhelming. In its current form, the Clinton Foundation is a charity in the same way La Cosa Nostra was an Italian soup kitchen. There’s a reason a top Clinton executive said of the foundation, “This is not charity. It’s a commercial proposition.” And that reason is that it’s not charity.

The simple commercial proposition underlying the Clinton Foundation is access to and potential favors from one of the most powerful couples in the world.