Tonight, President Obama will address the “founders summit” of Organizing for Action, the political advocacy group created to promote his second term agenda. The moment will complete an important reversal in the president’s stance on campaign finance: an unmistakable embrace of politically active nonprofits known as “social welfare” organizations—or 501(c)4s, per the IRS—entities that Obama once decried as a threat to American democracy for accepting unlimited and often undisclosed donations.

OFA drew howls of protest from reform groups when it was formed in January out of the remaining infrastructure of Obama’s reelection campaign. Bob Edgar, the president of Common Cause, told the New York Times last month that the setup “just smells,” and Common Cause, Democracy 21 and other organizations called on the president to shut it down.

Following this storm of criticism, OFA President (and former Obama campaign manager) Jim Messina announced several measures last week intended to improve the group’s transparency and curb the influence of special interests. OFA will not accept contributions from lobbyists, corporations or foreign donors. It will also disclose on a quarterly basis the names of donors who contribute more than $250, as well as the amount that they contribute.

OFA did not respond to written questions from CJR. But both the organization and the White House have described the current arrangement as a means of facilitating grassroots advocacy on behalf of popular Obama agenda items, such as immigration reform and gun control, without opening the door to undue influence. “There’s going to be no opportunity to lobby the president through this organization,” Ben LaBolt, an advisor to OFA and former Obama campaign spokesman, told CNN.

However, the reassurances from the Obama and OFA teams paper over important loopholes that undermine their recent pledges to shun special interest contributions. Good government groups say a number of common tactics for funneling political donations could allow lobbyists and corporations to circumvent OFA’s latest guidelines and direct major dollars to the group.

Reporters at the local and national levels should keep close watch for the strategies outlined below, both in scrutinizing OFA’s activities and in uncovering the identities and agendas of donors from within their own communities. The tactics are also applied to avoid disclosure under the more restrictive rules guiding traditional donations to candidates, and should be on the radar of all reporters covering money in politics.

Here are four techniques that special interests can still use to steer unlimited sums into the president’s new operation without leaving a fingerprint:

1) Use Unregistered Lobbyists

OFA’s new policy prohibits federal lobbyists—who are required to register with the US Senate—from contributing to the organization. But under the complex rules that govern lobbying, some people who engage in lobbying activities manage to avoid registration. At Obama’s second inaugural celebration, for example, the Sunlight Foundation found that in spite of an official ban on lobbyists there were several deregistered lobbyists in attendance who were still lobbying part-time, directing other lobbyists, or providing “government relations strategy” advice.

These unregistered lobbyists can further boost their influence by acting as “bundlers”—elite fundraisers who solicit contributions from relatives, friends and business associates and deliver the entire package of funds in a bundle. The Center for Public Integrity reported last week that a number of top bundlers in Obama’s reelection campaign (whose infrastructure was used to form OFA) had significant ties to the lobbying industry. In 2011, The New York Times found that the directors of the lobby shops at Pfizer and Comcast Corporation, respectively, were not registered as lobbyists themselves and had each bundled $500,000 for President Obama’s reelection bid.

OFA has not indicated that it will disclose who its bundlers are—501(c)4s are not required to do so—leaving the public without any way of knowing who is performing this crucial fundraising role.

2) ‘Laundered’ Contributions

Sasha Chavkin covers political money and influence for CJR's United States Project, our politics and policy desk. He has written for ProPublica, the Center for Public Integrity, and The New York World. Follow him on Twitter @sashachavkin.