The attached Executive Summary continues an investigation into the Clinton Foundation public record begun, by chance, in February 2015.
Readers who visit Clinton Foundation websites are forgiven for believing information found there presents the complete record.
In fact, key documents and disclosures are missing or contradict other filings that a persistent investigator only finds by scanning a raft of state, federal, and foreign databases.
In this letter, I explain my general approach to analyzing Clinton Foundation public filings, and list out specific topics that will shortly be covered in extensive detail.
Get ready for lots more analysis of the Clinton Foundation.
I will soon start posting new, in-depth, detailed reports explaining what I have found in the public record concerning the Clinton Foundation. In the latest document, I provide information concerning some of the new avenues we shall start exploring in coming days.
From beginnings in the state of Arkansas in 1997, the Clinton Foundation quickly grew to become a sprawling international organization after 2001, despite the fact that this tax-exempt entity was only authorized to serve as a facility devoted to the study of Bill Clinton’s tenure as president of the United States.
Especially from 2001 onwards, state, federal, and foreign governments have never regulated material defects in many Clinton Foundation public disclosures. Material deficiencies exist in documents ranging from filings from applications before the I.R.S., to registrations before U.S. state and foreign governments, to annual reports required in numerous legal jurisdictions.
From January 2001 through January 2009, when apparent unauthorized and illegal activities began and first escalated, Republicans were in control of the Executive Branch and had substantial influence in the House of Representatives, and in the Senate.
Was a decision reached in this period to give the Clinton Foundation free reign to operate outside any effective governmental controls--if so, by whom?
Since January 2009, even though Republicans held reduced influence within the federal government, many have held authority to investigate and to prosecute manifest unauthorized and illegal operating and fundraising activities of the Clinton Foundation.
Still, and even after multiple public and private warnings, no progress has resulted in attempting to bring the Clinton Foundation into compliance with strict U.S. state and federal laws.
So, perhaps we must rely on foreign government authorities to investigate obvious discrepancies in Clinton Foundation filings with records of major donors.
Please read the attached Executive Summary and then join with me, and with other citizens who believe that all public charities must be operated in strict compliance with applicable laws.
No individual stands above the law. And no person, not even a leading candidate for president of the United States is “too big to jail”, because government authorities and the major U.S. political parties are too conflicted to protect inherent interests of “we, the people”.
Evaluation of Clinton Foundation public filings inside and outside the United States continues.
Starting 11 January 2016, I will publish additional detailed analyses that are designed to serve the audience of journalists, professionals, and government authorities familiar with the suite of laws and accounting guidelines that regulate IRS-approved public charities operating internationally.
For now, this brief update targets the general public and spares you consideration of the voluminous body of financial figures and words that Clinton Foundation entities send to the IRS, to regulators in key U.S. states, and to foreign authorities.
Though the subject of a given charity’s public disclosures is ordinarily dull, this case is a special one, particularly during what shapes up now as a momentous election year.
Here are 10 predictions, centered on the Clinton Foundation, that could affect developments during 2016 in many geographic locations.
When you understand relevant accounting rules and laws, you will reach a simple conclusion: the Clinton Foundation (including all of its various corporate subsidiaries and "initiatives") has been operating boldly and illegally out of control, in plain view of the general public and government authorities.
Late on 16 November 2015, the Clinton Foundation filed tax returns for itself and for its largest operation (Clinton Health Access Initiative, Inc. or "New CHAI") concerning 2014. Also filed were amended tax returns for 2010, 2011, 2012, and 2013 for the main Foundation and amended tax returns for 2012 and for 2013 for New CHAI.
Welcome Washington Examiner readers. Here is a link to some prior work: Are Clinton Foundation Agents and Principals Truly Too Big to Jail? Here is a link to the Charity Fraud Countdown Clock.
Disaster relief charity fraud is a serious, escalating problem because it is so easy to perform and quite tough to police--just consider recent reports of such scams that are said to involve celebrities and even official government-linked enterprises, including many tied to the U.S. government and to the United Nations.
These first two General Exhibits introduce those who might have little familiarity with how financial frauds operate to warning signs that experts watch for, and to special and strict laws designed in New York state to catch charity fraud.
Trustees are one protection against charity fraud, assuming they take their solemn duties seriously and are given leave to exercise them independently. Particularly in the early period starting in 2001, Trustees do not seem to have been truly independent, nor did they take their duties seriously enough, judging from a close and ongoing review of Clinton Foundation public filings.
Competent, engaged, and independent accountants are another bulwark against charity fraud; however, from 2001 to present, no accounting firm associated with Clinton Foundation actually completed a proper audit of any Clinton Foundation entity, as is strictly required under numerous laws.
Read these first two Exhibits carefully and start to see for yourself how serious uncured problems are with regard to Clinton Foundation public disclosures and operating practices.