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4 November 2015

FALSE PHILANTHROPY
Exhibits to the First and Second Foundation Reports
Volume 1
: Executive Summary
Important Disclaimer
Information concerning the Bill, Hillary & Chelsea Clinton Foundation (the Clinton
Foundation) that is analyzed in the First Interim Report (the First Foundation
Report), the Second Interim Report (the Second Foundation Report), and these
Exhibits is derived only from publicly available primary and secondary sources. No
attempt has been made to verify the accuracy of underlying source material;
however, every reasonable effort has been made to direct readers to public filings
and other documents evaluated and mentioned in the First Foundation Report, the
Second Foundation Report, and these Exhibits. The analysis contained herein,
together with accompanying Tables, Exhibits, and Appendices, does not constitute
expert advice of any kind, whether legal, financial, accounting, policy, or otherwise.
Readers are urged to evaluate relevant publicly available facts about the Clinton
Foundation, in appropriate context, and to form their own independently derived
conclusions. For the convenience of readers, Appendix I contains Selected Caveats,
Qualifications, and Definitions that are used and apply throughout materials issued
concerning the Clinton Foundation, its constituent elements, and affiliates.

by
Charles K. Ortel
www.charlesortel.com
4 November 2015
Subject to Disclaimer
Copyright asserted by Charles K. Ortel

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Revealing New Relevant Information

The purpose of this and companion documents is to provide certain background and
context to concerned members of the American and global public who may not have
requisite familiarity with relevant laws, regulations, and practices applicable to
charities such as the Clinton Foundation that continuously solicit using the mails,
telephones, and digital media across state and national boundaries.
This extensive package of detailed Exhibits and Appendices offers a different set of
perspectives grounded in
crucial, publicly available information that is not found or
obscured on Clinton Foundation internet-based portals.
The Looming Deadline of 16 November 2015
As noted recently1 , the Clinton Foundation must submit truthful and comprehensive
declarations within 12 days to state, federal and foreign government authorities,
concerning its consolidated financial and operating performance during calendar
year 2014 and 2013.
In addition, and as is customary under domestic and international laws governing
larger public charities, the Clinton Foundation must make truthful and complete
representations and provide supporting evidence to competent and independent
external auditors so that they can confirm that financial disclosures are presented in
accordance with applicable accounting standards.
Starting in May 2015, PricewaterhouseCoopers LLP (PwC) was alerted to apparent
material irregularities in its audit of consolidated Clinton Foundation financial
results for calendar years 2013 and 2012.
To meet legally binding reporting requirements regarding 2014 and 2013, the
Clinton Foundation, with PwC or with a replacement auditor, must amend and
explain multiple years of false and materially misleading historical disclosures to the
general public and to government authorities.
Clinton Foundation trustees, executives, and independent advisors are now making
final decisions that have far-reaching financial, personal, and political implications.

To see an earlier warning, follow this link:

http://charlesortel.com/clinton-foundation-important-moments-ahead
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Structure of the Accompanying Exhibits and Appendices

This package of Exhibits supports information contained in the First Foundation
Report dated 20 April 20152 and the Second Foundation Report dated 8 September
20153.
Volume I of the Exhibits, released 4 November 2015, introduces a more detailed set
of analyses and targets individuals who are comfortable considering accounting,
legal and related topics pertaining to the operation of and solicitation for
IRS-authorized public charities such as the Clinton Foundation.
Volume II of the Exhibits (72 pages in length in current draft form) is scheduled for
release starting 5 November 2015, and treats 10 General Background topics:
Table 1: Index of General Topics Covered in Volume II of Exhibits
to the First and Second Foundation Reports
Exhibit
1

Description

Pages

Selected Considerations Concerning Financial Statement and Reporting Fraud

11

Special Reporting and Operating Considerations Involving Tax-Exempt

Organizations Required to Register under New York Law

Known Legal Entities Associated with the Clinton Foundation

Links to Selected Public Filings of the Clinton Foundation, its Constituent

Elements, and Certain Affiliates

Reported Tax-Exempt Purposes of the Clinton Foundation

Persons in Position to Exercise Significant Influence over the Clinton Foundation

5

Reported Contributions and Grants to the Clinton Foundation

Marketing and Fundraising Across State and National Boundaries

Key Periods in the Known Clinton Foundation Timeline

10

Selected Commentary Concerning the Clinton Foundation

To access the First Foundation Report, follow this link:

http://charlesortel.com/the-latest-available-clinton-foundation-filings-appear-deceptive
3

To access the Second Foundation Report, follow this link:

http://charlesortel.com/second-interim-report-on-the-clinton-foundation

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Volume III of the Exhibits (176 pages in length in current draft form) is scheduled for
release starting by 9 November 2015, and treats 18 topics, including:
Table 2: Index of Specific Topics Covered in Volume III of Exhibits
to the First and Second Foundation Reports
Exhibit
11
12

Description

Pages

Uncorrected Failures of the Clinton Foundation to Procure Independent,

Certified Audits of Consolidated Financial Statements

15

Uncorrected Failures of the Clinton Foundation to Exercise Legally Required

Control Over Foreign Operations from Bases inside the United States

Unauthorized and Illegal Activities, in Theory, Providing Earthquake Relief to

Victims in Gujarat, India Starting in 2001

18

Unauthorized and Illegal Activities Fighting HIV/AIDS from July 2002 through
April 2004

12

15

False and Materially Misleading Application to Form Old CHAI in April 2004

15

16

Illegal Diversion of at Least $62 Million during and After 2004

17

Unauthorized and Illegal Activities, in Theory, Providing Tsunami Relief Starting

in 2005

Unauthorized and Illegal Activities Providing Relief to Victims of Hurricane

Katrina Starting in August 2005

13
14

18
19
20
21

Illegal Operation and Subsequent Sham Merger of Old CHAI into the Clinton
Foundation Effective 31 December 2005
Illegal and Deceptive Arrangement of Strategic Partnership with UNITAID
through 2006

11
8

Deceptive Procurement by Hillary Clinton of her Role as U.S. Secretary of State

10

22

Fraudulent Procurement of Major Donations to Clinton Foundation Entities

through 2009

23

Fraudulent Procurement of Tax-Exempt Authorization to Operate New CHAI

13

24

Fraudulent Procurement of Tax-Exempt Authorization to Operate New CGI

15

25

Unauthorized and Illegal Activities Providing Earthquake Relief to Haiti Starting

in January 2010

False and Deceptive Characterization of Clinton Foundation Reorganization

Starting in 2009

26

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27
28

Fraudulent Activities of the Clinton Foundation While Hillary Clinton Served as

Trustee

Fraudulent Activities of the Clinton Foundation After Hillary Clinton Resigned as

Trustee

Supporting the First Foundation Report, the Second Foundation Report and the
three Volumes of Exhibits are 8 Appendices that are 215 pages in length in current
draft form.
Table 3: Index of Appendices to the First and Second Foundation Reports
Appendix

Title

Pages

Selected Caveats, Qualifications,and Definitions

10

II

Selected Background and Source Materials

45

III

Known Efforts to Fight HIV/AIDS Before 2010

55

IV

Preliminary Review of Financial Statement and Public Disclosures, 2013 to

Present

10

Preliminary Review of Financial Statement and Public Disclosures, 2010

through 2012

25

Preliminary Review of Financial Statement and Public Disclosures, 1998

through 2009

35

Summary Analysis of Private Gain and Potential Inurement Created by the

Clinton Foundation, and Appropriated by Clinton Foundation Insiders

10

Selected Additional Materials

25

V
VI
VII
VIII

Specific release dates for all Appendices will be published by 9 November 2015.

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4 November 2015

Understanding Flawed Public Disclosures of the Clinton Foundation

Exhibits to the First and Second Foundation Reports and supporting Appendices
explain in more detail how the Clinton Foundation and constituent elements
repeatedly made declarations to government authorities and to the general public
that are false and materially misleading, while also omitting to state relevant facts
concerning the true and illegal nature of their endeavours.
These repeated falsehoods, omissions, and illegal acts are not episodic, technical
breaches--instead, longstanding, unrepentant practices of the Clinton Foundation
and of its constituent elements, while continuously fundraising are a massive global
fraud, that government authorities in key jurisdictions, so far, refuse to investigate
and to prosecute.
Since 20 January 2001, and after a rocky start, Bill Clinton and members of his
family have been lauded for charitable work by numerous leaders:
By 2005, former President Jimmy Carter (not an ally though a fellow Democrat)
heaped praise upon Bill Clinton and the Clinton Foundation, singling out their
international efforts fighting HIV/AIDS:
The foundation assists health leaders in [resource poor] countries in implementing modern business
procedures and protocols for the management of drug storage, trading and distribution, and
information sharing.
http://www.nfid.org/awards/clinton.pdf

By September 2007, In the heat of Hillary Clintons first campaign to become

president of the United States, admiration for supposed good works of the Clinton
Foundation only seemed to grow, as this review by Peter Baker of Bill Clintons book
Giving: How Each of Us Can Change the World
illustrates.
http://www.washingtonpost.com/wp-dyn/content/article/2007/09/06/AR2007090602053.html

However, close and ongoing review of the public record tells a different story.
Instead of complying with applicable laws, Bill Clinton and those in his orbit began in
2001, and continue since then a global charity fraud on mammoth, illegal that
appears to exceed $13 billion.

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Operating and financial controls are manifestly ineffective--as demonstrated

herein, numerous legally mandated filings are late, incorrect, and materially
misleading.
http://newsbusters.org/blogs/tim-graham/2015/05/01/npr-exposes-holes-chelsea-and-bill-clintonsmost-transparent-foundation

Trustees fail to discharge essential duties of care, loyalty, and obedience.

Meanwhile, most of these people are stalwart supporters of the Democratic Party
and of Democratic candidates to hold elected and appointed offices throughout the
United States..
Legal entities associated with the Clinton Foundation are not constituted or
maintained in compliance with applicable state, federal, and foreign laws.
To see the dimensions and implications of this ongoing, and as yet unprosecuted set
of frauds, you must look past the otherwise gripping pictures in glossy Annual
Reports and printed media of needy victims who, theoretically have been aided, and
engage, knowing essential context, on stubborn facts.
Numerous indicting facts are incorrectly stated in materially false and misleading
public filings, while others are found in the public domain, yet illegally and
purposefully omitted from Clinton Foundation filings.
In late September 2015, close to 90% of the worlds national leaders gathered in
New York CIty--epicenter of Clinton Foundation frauds-- to participate in functions
hosted by the United Nations. A few of these visitors also participated in an Annual
Meeting of the Clinton Global Initiative, an organization that has falsely held itself
out as a duly-constituted tax-exempt organization beginning in 2005.
Readers of the First and Second Foundation Reports, of these Exhibits, and of
supporting Appendices will appreciate that the global frauds perpetrated by
Trustees of Clinton Foundation entities are so vast and so lucrative, that powerful
leaders in global governance have, perhaps, concluded they would prefer to emulate
Clinton Foundation practices for their benefit, rather than expose and punish
malefactors who, until now, have hidden gargantuan illegality under the brightest
lights shining on human activity, outside entertainment and athletics.

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In stark contrast, conservative author, filmmaker, and political activist Dinesh

DSouza was sentenced 23 September 2015 to eight months in a halfway house, five
years of probation, weekly counseling sessions, and a $30,000 fine for making illegal
campaign contributions to a single New York State campaign, and for making false
statements on forms submitted to the Federal Election Commission.
http://www.justice.gov/usao-sdny/pr/dinesh-d-souza-sentenced-manhattan-federal-court-five-yearsprobation-campaign-finance

Prosecution and a tough sentence for a first-time offender such as DSouza may
well have been justified--if so, imagine what penalties may lie in store for the
Clinton family and for their allies who seem to have perpetrated the largest disaster
relief charity fraud ever attempted in the United States, that started following the
first week of Bill Clintons post-presidency.

Are the Clinton family and Clinton Foundation Trustees Too Big to Jail?
On 1 November 2015,
www.drudgereport.com
highlighted a piece in
www.mclatchydc.com
by Anita Kumar and Greg Gordon with the banner headline
Shes Too Big to Jail.
http://www.mcclatchydc.com/news/nation-world/national/article41972739.html

The piece, actually titled As Benghazi Inquiry Fades, Clinton Still Faces Legal
Questions about Emails, does not delve appropriately into the extensive record of
deceit and dishonest reporting filed by Clinton Foundation trustees for calendar
years 2001 through 2013.
In fact, justice
is
blind when it comes to enforcing strict laws that govern public
charities operating internationally from U.S. bases, while soliciting donations using
the telephone, the mail, and digital media.
Read these materials carefully and examine the public record for yourselves--once
you inform yourselves, you will recognize a criminal conspiracy in action, one that
has already raised more than $13 billion since 2000, on the basis of false and
materially misleading public disclosures.

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4 November 2015

Time is of the Essence

On 26 April 2015, acting Clinton Foundation CEO Maura Pally observed in the first of
two relevant paragraphs:
I also want to address questions regarding our 990 tax forms. We have said that after a voluntary
review is completed we will likely refile forms for some years. While some have suggested that this
indicates a failure to accurately report our total revenue, that is not the case. Our total revenue was
accurately reported on each years form--our error was that government grants were mistakenly
combined with other donations> These grants have always been properly listed and broken out and
available for anyone to see on our audited financial statements posted on our website.
www.clintonfoundation.org/blog/2015/04/26/commitment-honesty-transparency-and-accountability

The above statements may have been made in ignorance of underlying facts--as will
be seen through review of these materials, the first paragraph cited in Ms. Pallys
press release continues a longstanding practice of deception and materially
misleading representation by those in position to exercise significant influence over
the Clinton Foundation, its constituent elements, and affiliates.
In summary,
all 990s filed for all Clinton Foundation entities from 2001 forward
are
riddled with errors and intentional misstatements. Moreover, no accounting work
product held out by the Clinton Foundation as being a legally required and
independently certified set of financial statements constituted an audit within the
widely accepted and commonly understood meaning of this term.
The second paragraph in this portion of the statement made by Ms. Pally on behalf
of the Clinton Foundation is equally dishonest and, in hindsight, false:
So yes, we made mistakes, as many organizations of our size do, but we are acting quickly to remedy
them, and have taken steps to ensure they dont happen in future. We are committed to operating the
Foundation responsibly and effectively to continue the life-changing work that this philanthropy is
doing every day. I encourage you to read more about our good work at
www.clintonfoundation.org
.

A large, U.S.-domiciled public charity operating internationally must comply

thoroughly with a raft of state, federal, and foreign laws--these Exhibits and related
materials will demonstrate, in detail, that trustees and others responsible for
direction of the Clinton Foundation activities have repeatedly failed to comply with
applicable laws, while soliciting donations continuously using the mails,
telephones,and digital media, starting in 2001.

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The general public should not have to guess how a large tax-exempt organization
actually performed, months following the end of their latest financial
year--applicable federal and state laws require that charities supposedly serving
public interests demonstrate their true accomplishment in independently verified
ways, using competent professional experts,
Starting in March 2015, in a piece entitled With So Many Red Flags, Why Isnt the
IRS Auditing the Clinton Foundation?, repeated efforts have been made to regulate
the persistent and flagrantly illegal activities of a celebrity organization that
masquerades as a charity, when it seems to be, instead, a political and personal
slush fund.
http://www.breitbart.com/big-government/2015/03/16/with-so-many-red-flags-why-isnt-the-irs-aud
iting-the-clinton-foundation/

Last week, the Clinton Foundation actually boasted that its donations during the
nine months ended 30 September 2015 exceed those during the prior comparable
period, even though the Clinton Foundation has yet to amend errors in historical tax
returns and submit a complete tax return for 2014.
https://philanthropy.com/article/Clinton-Foundation-Says/234006

Early in October 2015, Hillary Clinton uttered tough talk on holding Wall Street
bankers and market participants accountable for financial crimes:
...the best way to deter corporate wrongdoing is to hold individuals responsible for their
misconduct...That includes holding corporate officers and supervisors accountable when they knew
about misconduct by their subordinates and failed to prevent it or stop it. When people commit crimes
on Wall Street, they will be prosecuted and imprisoned.
http://www.bloombergview.com/articles/2015-10-08/hillary-clinton-s-plan-to-prevent-the-next-cras
h

Existing state, federal, and foreign laws already hold trustees and related family
members accountable for
any
illegal acts carried out in the name of a public charity.
Indeed, these rules, applicable penalties, and attendant shame for failing to manage
a nonprofit organization properly serve to ensure that the overwhelming majority of
U.S. public charities operates in full compliance with the letter and legislative intent
of the law.

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Records and Evidence-General

Trustees of U.S. public charities are required to safeguard permanent
records--these are defined as:
application[s] for recognition of tax-exempt status, the determination letter[s] recognizing tax-exempt
status, and organizing documents, such as articles of incorporation and by-laws, with amendments, as
well as board minutes.

https://www.irs.gov/pub/irs-pdf/p4221pc.pdf
The Clinton Foundation purposefully omits to include permanent records
concerning key subsidiaries, including Clinton Foundation HIV/AIDS Initiative, Inc.
(Old CHAI), among others, on its website that serves as its key public disclosure
portal.
Reporting Changes
According to the IRS:
Regardless of whether a public charity files an annual information return, it [may] also report...change
to the EO {Exempt Organization] Determination Office [of the IRS]

Like
all
other tax-exempt organizations created under U.S. law, the Clinton
Foundation is required to define
specific
purposes, to achieve these purposes, and to
seek permission from the IRS, in advance, should it wish to change its authorized
purposes in any material way.
As Exhibits and Appendices demonstrate in detail, the Clinton Foundation was
authorized as an archival records repository and related research facility into the
Clinton Presidency that was to be based in Little Rock, Arkansas.
Instead, Bill Clinton and Ira Magaziner and others held themselves out to the
general public as being in position to bind the Clinton Foundation in legal
documents starting 12 July 2002 to fight HIV/AIDS internationally. This radically
different, supposed tax-exempt purpose was
never
validly authorized by the IRS.
Moreover, Bill Clinton and Ira Magaziner were neither officers, nor directors of the
Clinton Foundation until years after July 2002.

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Required Accounting Approaches

Certainly by 2001, the Clinton Foundation was required to account for its financial
results completely and truthfully in conformity with Generally Accepted Accounting
Principles that mandate strict adherence to accrual-basis techniques.
Instead, the Clinton Foundation may have employed inappropriate accounting that
is illegal in the United States for all years from 2001 through 2004.
Curiously, though accounting work product characterized inaccurately as being
audits for years 2005 through 2013
is
linked at the Clinton Foundation website, no
such information for years 2001 through 2004 is found at the Clinton Foundation
website
Applicable Consolidation Rules
All public charities are required to report annual activities on a basis that
consolidates (meaning includes) appropriate shares of entities it controls and
influences, on bases that are in conformity with GAAP and that are consistent, year
to year.
The Clinton Foundation has never, during the period 2001 to present, complied with
these elementary and bedrock reporting requirements. In consequence, public
filings of the Clinton Foundation remain in gross violation of applicable state,
federal, and foreign laws.
Agent or Principal?
As will be demonstrated in Exhibits and Appendices, the largest ongoing and
illegally constituted activity of the Clinton Foundation has been to solicit donations
and claim a fight against HIV/AIDS internationally.
In particular, from November 2006 through December 2013, the Clinton Foundation
solicited and may have received $566.3 million from a single donor, even though the
Clinton Foundation was not validly authorized by the IRS or established lawfully in
key states to carry out this specific purpose as a tax-exempt organization.
Under U.S. laws, public charities operating abroad must exercise strict control over
their foreign activities from bases inside the U.S.
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The public record is clear that the Clinton Foundation did not, in fact, exercise strict
control over its foreign operations from legally constituted bases in the U.S.
Moreover, the Clinton Foundation repeatedly held itself out as acting as principal,
when it may have only been able to function lawfully as an agent. For this reason,
and for related reasons, the Clinton Foundation incorrectly accounted for its
activities outside and inside the U.S. in grossly negligent and reckless ways.
Related Party Transactions
Trustees and others in position to exercise significant influence over the Clinton
Foundation, as well as certain family members of the foregoing, are required to
make full and truthful declarations concerning transactions with related entities
and persons.
http://www.nonprofitcpa.com/charity-cant-begin-close-home/
Starting with filings concerning 2001 that do not disclose Bill Clintons substantial
involvement with the American India Foundation (AIF), and with trustees, officers,
and donors of AIF, Clinton Foundation disclosures omit describing material related
party relationships, and make other disclosures concerning related party
transactions that are false and materially misleading.
False and Misleading Representations to Independent Auditors
Financial statements created by Clinton Foundation management, approved by
Clinton Foundation trustees, and, in theory, verified and therefore audited by
accounting firms including B.K.D., LLP (BKD), Mayer Hoffman McCann P.C.
(MHM), and PwC that concern calendar years 2001 through 2013 inclusive are
false and materially misleading, yet these remain in the public domain and none
have been corrected nor revoked, to date.
The Public Company Accounting Oversight Board (PCAOB) should forthwith
commence investigations into the unrepentant practice clearly evident in the public
domain wherein Clinton Foundation trustees have procured audits of their
operations starting with regard to 2001 that are premised upon false and materially
misleading representations.
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4 November 2015

Exposing and Regulating False-Front Charities that Form the Core of

the Clinton Foundation
Under applicable laws pertaining to charities, disclosures made to state, federal, and
foreign government authorities matter--they include information of crucial
importance to potential and actual donors.
If public disclosures are false and materially misleading, if these false disclosures are
sworn to under penalties of perjury, and if these illegal actions are neither exposed
nor punished, a large and distinctive swath of what makes America and most
Americans exceptional ends up being corrupted.
Public disclosures made by the Clinton Foundation are not thorough, nor complete,
nor timely--these indisputable conclusions raise numerous red flags as
experienced evaluators of public charities have made plain in media reports.
To understand underlying reality concerning solicitations since 2000 by the Clinton
Foundation, you must persistently engage on facts, perform rigorous analysis, and
look beneath the surface to the rotten core that, sadly, has infected an institution
established to honor the remarkable years of Bill Clintons millennium-ending
presidency.
The Exhibits and supporting Appendices are limited in the sense that they assess
only the facts Clinton Foundation entities are required to file on forms submitted to
state, federal, and foreign authorities, which any member of the public may obtain,
performing diligent inquiry.
Government authorities, in time, will be able to perform far more grounded and
analysis once they gain access to items validly outside the public domain including,
board meeting minutes, bank statements, monthly budgets, monthly operating
reports, and operating agreements with strategic partners as well as major donors.
What do Clinton Foundation public disclosures tell an appropriately informed
reader--one who understands key rules charities must follow and appreciates the
significance of entries
and omissions
in financial statements that are supposed to
be consolidated (incorporating all material entities) and prepared on a consistent
basis through time?

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4 November 2015

To answer key questions about Clinton Foundation public disclosures, you must
have an open, curious mind and retain appropriate focus upon what facts and
trends key forms and financial statements are designed to reveal.
Above all, you must retain a healthy sense of scepticism and search out independent
verification of as many important assertions as you can.

What is sold to the public and to donors as near final chapters in a life of selfless
service is actually a continuing tragedy involving serial and expanding episodes of
disaster relief charity fraud, mounted on global scale.
Close and ongoing analysis of public disclosures made by the Clinton Foundation
reveals that Bill, Hillary, and Chelsea Clinton, aided and abetted by others, created
and operate myriad entities that solicit billions of dollars, while falsely claiming they
actually are engaged as philanthropists, performing charitable good works.
Informed assessment finds a burgeoning, defiant, and unrepentant criminal
enterprise, whereas uninformed observers see only false appearances of propriety
surrounding an organization that holds itself out as being nonprofit.
Around the Clinton Foundation, numerous parties derive billions of dollars in
private gain through operation of the charity, some of which is appropriated by
insiders in criminal acts that are called inurement.
Moreover, supporters of the Clinton Foundation and of Democrats are able to derive
tax benefits donating unlimited amounts of money to organizations whose ultimate
spending is
not
controlled or verified by truly independent third parties, as
applicable laws require.
Worst of all, when gala gatherings involving powerful personages who celebrate
their supposed good works are finished in fashionable cities worldwide, despicable
horrors remain unfixed--billions of dollars in contributions raised never actually
reach the hundreds of millions of desperate victims whose teary faces and prostrate
forms inspire generous hearts, when their stories are incorporated into fundraising
solicitations here in America and elsewhere.

Why do smart people trade on the misery of victims?

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Why would accomplished, already powerful celebrities tap donors to supposedly

assist some of the most deserving victims of adversity, and instead divert donations
to serve personal and political ends?
Why would these celebrities take credit at conferences and in scripted, closed
settings for achieving noble, high-sounding aims but ensure that required
disclosure forms are almost impenetrable?
And why would the Clinton Foundation allow so many false-front initiatives to be
used in so many desperately poor nations as cover to extract riches for corrupt
government rulers and their cronies?
History is replete with cases where supposed charities are used as shields for
scoundrels.
As Judge Jed S. Rakoff noted4 in connection with an historic set of insider trading
trials:
The annals of white collar crime in [the Southern District of New York State] are filled with people who
worked to make themselves respected, powerful members of society by giving to charity.

In New York and across America, too many nonprofit institutions operate out of
effective control--donations made in good faith (as well as bribes) then get
diverted and corrupted. This is especially true of charities domiciled inside the
United States engaged in foreign activities in remote places that are tough to police,
particularly when controls are intentionally loosened, even rendered impotent.
Here, high income and wealthy persons are able to derive substantial economic
benefits claiming donations of appreciated property to charities--if these charities
are run irresponsibly and illegally, forces for supposed good morph into conduits
where illicit favors get exchanged in devious ways that are difficult for understaffed
regulators to track,

Saying you are performing good works as a charity does not mean you actually are
performing charitable good works.

Anita Raghavan,
The Billionaires Apprentice: The Rise of the Indian-American Elite and the Fall of the
Galleon Hedge Fund
, p.389.

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4 November 2015

Instead, the burden of proof that a given charity is fully compliant with applicable
laws rests on the shoulders of trustees (also called directors), who cannot delegate
away reporting requirements and attendant legal risks to underlings.
So, the full public record that is augmented annually and supplemented periodically
matters a lot, especially because public charities are not permitted to engage in
any
illegal activities.
Concluding Summary Comments
Analysis of Clinton Foundation public disclosures must concentrate upon facts and
be grounded in thorough understanding of key laws and regulations that govern the
basis upon which public charities are required to report.
Supporting independent work that began earlier in 2015, this Executive Summary
introduces certain background and contextual data that an interested party might
deem relevant in reaching an informed conclusion regarding the public record of the
Clinton Foundation, its constituent elements, and certain affiliates.
From an initial base in Little Rock, Arkansas, whose Attorney General bears primary
responsibility for legal oversight, the Clinton Foundation has established itself in
other U.S. states, including New York and Massachusetts, and it has conducted
operations in numerous foreign countries.
Unfortunately, regulators in the locations where the Clinton Foundation functions,
to date, have not yet compared notes and discovered major infractions of relevant
laws and regulations that become obvious following close and determined
inspection.
Perhaps America has reached a place in November 2015 where stubborn,
inconvenient facts do not matter anymore.
If the discordant facts and analysis presented herein do not grip American
authorities, foreign governments and international eyes may ultimately force the
kind of reckoning that those responsible for perpetrating ongoing Clinton
Foundation frauds so richly deserve,

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4 November 2015

Those with grounded and independent minds, and particularly those who care about
charity and the proper practice of philanthropy will read these Exhibits carefully and
consider their wider implications.
There are worse crimes than running disaster relief charity frauds on global scale;
however, doing so over 15 years in the center of a minimum $13 billion scam that
will only grow if left unpunished is indefensible.

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