Nor is there any public evidence to suggest he personally drove the solicitation of donations for policy or advised donors to split donations to keep under the $15,000 limit to avoid transparency.
Peters is a lawyer and well aware that "form" matters when it comes to the delicate matter of political party funding - particularly that question of what comes first: the "chicken" - i.e. policy, or the "egg" - donations. Get that wrong and the omelette won't be worth eating.
Nor has the Serious Fraud Office investigation – which was publicly launched yesterday – named him personally. It simply said it has commenced an investigation in relation to the NZ First Foundation, pointing out the relevant section of the SFO Act which enables the director to act where she "has reason to suspect that an investigation into the affairs of any person may disclose serious or complex fraud, and/or, where there are reasonable grounds to believe that an offence involving serious or complex fraud may have been committee."
An earlier inquiry by the Electoral Commission concluded, "based on the information available, we have formed the view that the New Zealand First Foundation has received donations which should have been treated as party donations for the New Zealand First Party," the commission said.
"In the commission's view, the donations were not properly transmitted to the party and not disclosed as required by the Electoral Act 1993."
This whole issue needs to be dealt with before September's general election.
Former NZ First president Lester Gray publicly said last year he would not sign off the party's accounts and has naively allowed himself to be photographed with a journalist who is investigation the funding trail. It has taken a very long time to get to this point.
What is, however, out in open is the fact the SFO is prosecuting four people over donations to the National Party. As revealed on Monday, that involves not one but two $100,000 donations - in June 2017 and June 2018.
Court documents outlining some of the particulars of the charges were released to the media this week by Judge Eddie Paul.
The court papers allege two donations of $100,000 in 2017 and $100,050 in 2018 were made "in circumstances where the identity of the donor was not disclosed in the National Party's Annual Return of Party Donations".
The maximum penalty if convicted on the charge is seven years' imprisonment.
The fourth man is charged alongside the other three over the 2018 donation, while also being accused of supplying false information to the SFO.
National's leader Simon Bridges has said allegations by former National whip Jami-Lee Ross against both himself and the party were baseless and false.
But it is not that simplistic, of course.
According to a tape released by Ross, Bridges did hear the former suggest a major donation would be split.
Bridges may have been set up by Ross but surely his ears were not entirely shut when Ross told him: "The way they've done it meets the disclosure requirements ... it meets the requirements where it's under the particular disclosure level because they're a big association and there's multiple people and multiple people make donations, so that's all fine."
The brutal truth is, political funding in New Zealand has been murky for a very long time.
The difference is, in 2020 we finally have an SFO that is game to take the players on.
