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Latest 18 June 2024

Shadowy groups that poured £500,000 into politics failed to register in 2023

Shutterstock / Chris Dorner

Unincorporated associations don’t have to reveal much about political donations, but 10 of them have breached the law. Is our politics for sale?


Secretive groups funnelling hundreds of thousands of pounds into political parties have failed to meet the low bar on transparency set by the government, with 10 unincorporated associations failing to register with the Electoral Commission for 2023.

Unincorporated associations are groups that can be set up without complicated legal structures. Good Law Project revealed last month that these groups have poured £5.3m into our divided politics since Rishi Sunak became prime minister, with the details of the individuals behind these donations kept entirely hidden.

Associations which give more than a certain amount in a calendar year must register with the Electoral Commission – a limit which increased from £25,000 to £37,270 in 2024. But 10 of these murky groups breached this threshold in 2023, giving a total of £510,000, all while unregistered.

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Three of these associations, representing 45% of the total amount, channel money to the Tories: The United and Cecil Club, The Conservative Friends of Ukraine, and the UK Office of Victor Pinchuk Foundation.

Founded by Winston Churchill in 1949, The United and Cecil Club is one of Tories’ biggest donors, and plays a key role in funding campaigns for marginal seats. The United and Cecil gave £150,000 to the Conservatives in 2023 without registering and is already hard at work handing out money to embattled Tories in seats across the country. The club has given £67,000 to 18 MPs in the first five months of 2024 alone. Recent records show that the United and Cecil Club registered for 2024 only after we got in touch with the Electoral Commission during this investigation.

Unincorporated associations don’t have to publish accounts, disclose membership lists, use business bank accounts, maintain a formal set of rules or even register a formal name. Associations with membership fees don’t have to declare gifts at all. Even when they need to be declared, gifts of less than £500 can remain entirely anonymous, and someone can give £499 anonymously again and again. 

There are strict rules around political donations in the UK to make sure that foreign powers and people who live abroad can’t buy influence. But unincorporated associations offer a way around them. Since there’s no way of telling who gives these shadowy groups their money, there’s no way of telling if the money they funnel into party coffers comes from sources not normally allowed to make donations in the UK.

Labour Milton Keynes Council group also failed to declare it had passed the annual donation threshold, as well as six local council groups working on behalf of the Liberal Democrats: Sheffield, Dorset, Hertfordshire, Portsmouth, Richmond upon Thames, and South Cambs. These groups collect a portion of councillors’ allowances, paying it back to the central party to support campaigning. Reports suggest that the Liberal Democrats set this levy at 10%.

When Good Law Project told the Electoral Commission about the groups that had failed to register, the commission said it “had not reviewed any of the unincorporated associations on the list”.

“Our compliance strategy includes checking the information we hold on donations to ensure that if any unincorporated association exceeds the registration threshold, we contact them to bring them into compliance,” the commission said. “This does mean we sometimes review the information that has been provided to us to ensure that registration is actually necessary and where necessary we will take enforcement action in line with our enforcement policy.”

The commission “has the power to seek forfeiture of impermissible donations and can impose fines as well as other penalties to secure compliance”, it continued, making clear that fines can apply to issues “such as late registration”. Even though some of these anonymous groups exceeded the threshold by as much as six times last year, the commission was “unable” to say if it had taken any enforcement action, pending a review, due to be released in late July – weeks after the general election.

For Dr Jess Garland, head of policy and research for the Electoral Reform Society, unincorporated associations “create significant problems for transparency around donations, potentially allowing money from impermissible sources, including overseas donors, to flow into our politics”.

“As political donations increase during this election,” Garland said, “people will rightly question what very wealthy donors expect for their money. The concern here is that we end up with a politics for sale to the highest bidder, where the greatest influence is not wielded by ordinary voters but those with the deepest pockets.”

“Rather than rolling back on transparency, we need to end the big-donor culture and help shift the balance back towards voters by bringing in a maximum amount that anyone can donate and increasing the transparency of those donations.”

Since the start of January 2024, unincorporated associations have already donated over £665,000 to political parties. 

All those mentioned in this article were approached for comment.