Australia's patchwork and opaque disclosure regime makes it virtually impossible to make sense of how much money is flowing in and out of Mr Turnbull's electorate's fundraising entities. Prime Minister Malcolm Turnbull attended a private fundraising function at the Conservative Leadership Foundation in Adelaide on Thursday 2 June 2016. Credit:Andrew Meares About 20 of Australia's richest 200 people, including billionaires Kerry Stokes and Frank Lowy, kicked in to the Wentworth Forum between 2007 and 2009, with membership then costing up to $55,000. "The Wentworth Forum" maintains an active Australian Business Number and is a trading name owned by the Wentworth Federal Electoral Conference (or FEC, a structure that incorporates all party branches located within the Prime Minister's federal seat). The forum's website remains live, listing former party treasurer Michael Yabsley​ as honorary chairman and linking to Mr Turnbull's and the party's websites. Its domain registration was updated by an employee of the Prime Minister's private company, Turnbull and Partners Pty Ltd, last year.

An email inquiry sent via the site was answered within hours, but, in his reply, Mr Yabsley said he had not been involved in party fundraising since 2010 and "the Wentworth Forum has not operated since 2009". Mr Yabsley recently told the ABC's Four Corners that he had known of illegitimate fundraising by the Liberal Party, and called for root-and-branch reform. Prime Minister Malcolm Turnbull. Credit:Andrew Meares The Wentworth FEC – like the broader party itself – is an unincorporated entity, a structure not-for-profit experts say is risky for an organisation handling significant sums of money. They have no reporting obligations, cannot hold assets in their own name, cannot be sued and may not pay tax. Neither the Wentworth Forum nor Wentworth FEC make funding disclosures to the Australian Electoral Commission as an "associated entity", unlike many other fundraising bodies associated with current senior Liberal ministers. Former Liberal Party Treasurer Michael Yabsley (centre) arrives at Sydney's Independent Commission Against Corruption. Credit:Daniel Munoz

However, according to disclosures by donors to the NSW Electoral Commission, "Wentworth," "Wentworth FEC", "Malcolm Turnbull" or the postal address of Mr Turnbull's electorate office, received a number of political donations. Billionaire Harry Triguboff​'s Meriton Properties made $10,000 donations in 2013-14 and 2010-11, while fellow BRW Rich Listers Allan Moss (ex-Macquarie Bank) and Alan Rydge​ (Greater Union cinemas and the Thredbo ski resort) also kicked in during 2010-11. Prime Minister Malcolm Turnbull leaves Justin Hemmes' exclusive Liberal fundraiser in Vaucluse. Credit:Christopher Pearce Lobbyists Premier State Consulting (linked to Liberal powerbroker Michael Photios​) and Advocacy Services Australia (which represents big infrastructure and tourism interests) also contributed in recent years. There is no way of knowing if these or other payments below the disclosure threshold made their way to an FEC initially via the Wentworth Forum. Donations above the threshold would be listed in the party's disclosures, with any links to the Prime Minister's electorate obscured.

Fairfax Media is not suggesting any wrongdoing by Mr Turnbull. Donations regime expert Joo-Cheong Tham​ said transparency in campaign funding is vital for public confidence in the political process. "This principle is undermined by fundraising organisations for candidates which have been allowed to operate with a high degree of secrecy. This is especially of concern with organisations which fundraise for senior politicians [such as] the Prime Minister," said Dr Tham, associate professor in law at the University of Melbourne. Mr Turnbull's Wentworth FEC is similarly opaque, but does show up in Liberal returns as a donor to other party divisions. In 2013-14, Wentworth donated $30,000 to the Victorian branch, $15,000 to Tasmania and $30,000 to Queensland's Liberal National Party. Again, there is no way of knowing the source of these funds.

A spokesman for the Prime Minister said all donations made by the Wentworth FEC to other divisions have been to support marginal seats. "All donations have been fully disclosed and declared in accordance with relevant laws," he said. Governance expert at Monash University Ken Coghill said intra-party financial transfers defeat the very purpose of disclosure laws. At least $17.1 million came via Liberal-linked entities and intra-party transfers in 2013-14 and $19.9 million in 2010-11, a Fairfax Media analysis of the last two federal election years shows. Many are distributions of consolidated funds derived from public funding as well as donations and sponsorships. In election year 2013-14, for example, the federal division of the party transferred about $3 million (recorded as "other" receipts) to the NSW division for campaign-related costs.

But the NSW party disclosure also records a $50,000 "donation" from the federal division. The same year, the Wentworth FEC was distributing $75,000 in other states, about $170,000 was flowing into NSW from interstate Liberals. Experts say these transfers could potentially keep above-threshold donations at arm's length from an intended candidate and avoiding scrutiny by "laundering" it through another division's account. The Victorian fundraising entity Enterprise 500 donated $75,000 to NSW, and the Tasmanian Liberals $24,650. The Queensland-based Fadden FEC associated with sacked former Turnbull minister Stuart Robert – whose secretive fundraising entity is being examined by Queensland's Crime and Corruption Commission – made a $20,000 donation to NSW. Entities linked to Foreign Minister Julie Bishop's seat of Curtin kicked in $25,000 to the Queensland LNP and $50,000 to the NSW Liberals. The "Senator M Cormann Campaign Fund" donated $80,000 to the Federal division. Victorian Ombudsman Deborah Glass last year identified the loophole during her investigation into allegations of improper political donations at the state level. In her report, she noted even a summons for bank accounts didn't reveal the money's source.