“A foreign national may not direct, dictate, control or directly or indirectly participate in the decision-making process of any person (such as a corporation, labor organization, political committee or political organization) with regard to the person’s federal or nonfederal election-related activities. This includes decisions concerning the making of contributions, donations, expenditures or disbursements in connection with any federal state or local election or decisions concerning the administration of a political committee.”
https://www.fec.gov/help-candidates-and-committees/foreign-nationals/
I think it would be pretty hard to argue that a donation swap didn’t at least involve indirectly participating in someone’s decision to donate.