Certainly looks that way. The US Chamber of Commerce, effectively a funnel for foreign funding, denies it. But only sort of.
In recent years, the Chamber has become very aggressive with its fundraising, opening offices abroad and helping to found foreign chapters (known as Business Councils or “AmChams”). While many of these foreign operations include American businesses with interests overseas, the Chamber has also spearheaded an effort to raise money from foreign corporations, including ones controlled by foreign governments. These foreign members of the Chamber send money either directly to the U.S. Chamber of Commerce, or the foreign members fund their local Chamber, which in turn, transfers dues payments back to the Chamber’s H Street office in Washington DC. These funds are commingled to the Chamber’s 501(c)(6) account which is the vehicle for the attack ads...
The Chamber protested that, gee, they were being very careful...
...The Chamber's Tita Freeman did not dispute that the Chamber's 501(c)(6) organization running attack ads receives foreign funds, and simply claimed, "We have a system in place" to prevent foreign funding for the Chamber's "political activities." ...Think Progress
TPM Muckraker doesn't think this will go any further than the action against Karl Rove's Crossroads GPS.
The Chamber is not organized as a PAC or political campaign. Instead, it's organized under the IRS as a 501(c)(6), or "business league." We have a request in to the IRS to explain whether business leagues can accept contributions from outside the U.S., but it appears that they can.
But they still engage in political activity and lobbying. That's allowed under IRS rules, although such activity can't be a business league's "primary activity."
If the Chamber is breaking campaign law by soliciting election donations from foreign nationals, it's unlikely the IRS or the FEC will go after them.