An anti-poverty organization that boasted of making the largest independent advertising buy of the political season, the ONE Campaign, has not filed a public list of its donors despite what some campaign finance lawyers say is a legal requirement to do so. “This organization is running a serious risk by ignoring the disclosure and reporting laws,” an advocate for strict enforcement of campaign finance regulations, Paul Ryan of the Campaign Legal Center, said.

At issue is a brief sequence in ONE’s television ad showing simulated campaign buttons for 14 presidential hopefuls from both major parties. “Ask each presidential candidate if they’re on the record fighting global poverty and disease,” the ad’s narrator intones. “One voice, plus yours and millions of others. … They will hear.” Under the Bipartisan Campaign Reform Act of 2002, also known as McCain-Feingold after its senate sponsors, any broadcast or cable ad that references an identifiable federal candidate and can reach 50,000 people in a given state in the 30 days before that state’s primary triggers a requirement to report the cost of the ads and to identify the underlying donors, according to the Federal Election Commission.

An election law specialist, Rick Hasen of Loyola Law School, said the visual reference to the candidates activates the McCain-Feingold law’s disclosure requirement. “Everybody has to disclose unless they can claim they’d be subject to harassment,” he said.

Mr. Hasen said the group could argue that applying the so-called electioneering rules to its ads violates the First Amendment, but federal regulators have not accepted that argument except when the courts force it upon them. “Tell them to hire a good election lawyer,” the professor quipped.

Two weeks ago, the ONE Campaign, which was formed by a coalition of relief groups, said it bought $1.8 million in television advertising time in New Hampshire and Iowa as well as on national cable as part of an effort “to ultimately save the lives of millions of the world’s poorest people by impacting the 2008 election.” An attorney for the group, James Joseph, said it was not required to file with the FEC because the ads obviously were not designed to promote or oppose specific candidates. “These ads are purely issue related,” the lawyer said in a phone interview yesterday. “The FEC generally regulates only express advocacy and advocacy that cannot be interpreted any other way.” Mr. Joseph said one indication of the ad’s neutrality is that voters could support the group’s goals and still vote for any of the presidential candidates. “We don’t draw any conclusions,” he said.

Mr. Joseph argued that a Supreme Court decision earlier this year, Wisconsin Right to Life v. FEC, gave groups leeway to run issue ads without reporting to the government. He also said new regulations on the subject only went into effect on Wednesday.

“That’s nonsense,” Mr. Ryan insisted. “These requirements to file have been on the books for years.” Last night, Mr. Joseph said that as a result of the new regulations and a decision to run the ads through the end of the year, ONE filed information on $2 million in ad expenditures with the FEC yesterday evening. But he said the group still doesn’t plan to disclose its donors since they were not solicited to support the ad campaign. A spokesman for the Federal Election Commission, Robert Biersack, said he could not comment on the legality of the group’s actions. However, he said the regulations the commission recently issued permitting corporate and union financing of issue ads did not affect the rules about disclosing donors and expenditures. “There’s nothing in that exception that affects requirements for disclosure,” Mr. Biersack said.

ONE announced earlier this year that it planned to spend $30 million to press poverty and public health issues in the 2008 election and that $22 million of that came from the Gates Foundation. Mr. Joseph declined to identify the group’s other donors. “A lot of nonprofits … don’t give out full lists of their donor information,” he said. The ONE Campaign is chaired by two former senators, William Frist of Tennessee and Thomas Daschle of South Dakota. Neither responded to requests for comment for this article.

A conservative group, Citizens United, sued the FEC this month to block enforcement of the electioneering rules, but there has been no ruling yet in that case.