Cohen made the payment just days before the 2016 presidential election, which gives the appearance that the electoral results, and not protecting someone like Melania, was the main purpose of the payment. (businessinsider.com)
«The true purpose of these payments is unknown, but it does appear not to be a purpose related to public office. (buffalonews.com)
To simplify, if you transmit information electronically for purposes of payment by third party payers (e.g. insurers, government entities) even for one client, you are considered a Covered Entity (CE) under the regulations. (blog.aamft.org)