Let me pour some salve on that itch, yo:
FEC v. Democratic Senatorial Campaign Comm., 454 U.S. 27, 37, 102 S.Ct. 38, 70 L.Ed.2d 23 (1981)
You see folks, the government has to prove that the person willfully violated the statute, and if they are relying on FEC guidance regarding what the statute means, well, that is all she wrote.
Cool, where did Trump or Cohen state that they were relying on FEC guidance when they structured this payment?
I probably just missed it as I haven't been paying close attention to these finer details.