They are, and as Angela Rayner notes (see Guardian Live Politics blog) the Electoral Commission report shows that he lied.
It is right that the Electoral Commission has fined the Conservative party but the prime minister must now explain why he lied to the British public saying he did not know who was behind the Number 11 flat refurb - all the while he was messaging the donor asking for more money.
This also means that he lied to the earlier enquiry conducted by his own adviser, Lord Geidt.