Proof Obama funded Al Qaeda

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https://www.finance.senate.gov/imo/medi ... gation.pdf

n February 2019, the Committee began investigating allegations concerning a diversion of government funds by World Vision (an Evangelical 501(c)(3) non-profit organization) to a terrorist-funding organization, the Islamic Relief Agency (ISRA). The investigation was initiated in response to a news article alleging that World Vision, and/or its subsidiaries, had intentionally partnered with an organization that was listed by the Office of Foreign Assets Control (OFAC) as a sanctioned entity for its ties to terrorist organizations.1 The report alleged that World Visioncontracted with the Islamic Relief Agency (ISRA) despite clear and readily discoverable evidence of ISRA’s sanctioned status.2

In a press release, World Vision claimed they were not aware of ISRA’s status before partnering with them and appeared to shift the blame for this incident to the United States government.3 World Vision articulated two main reasons why they believe the federal government bears responsibility in this incident. First, they claim that on two separate occasions, two different government agencies were notified that World Vision was working with ISRA and neither agency raised any concerns.4 Second, World Vision argues that the online search tool provided by the Treasury department made it difficult to ascertain whether or not ISRA was a sanctioned entity.5

This Committee was concerned with these allegations for two primary reasons: first, as the Committee of jurisdiction over all tax laws, we were concerned with the allegations that World Vision, a registered non-profit entity, is potentially engaging in transactions that affect U.S. national security. Second, as the Committee with primary jurisdiction over the Treasury Department, allegations raised by World Vision that the Treasury Department was not properly vetting applications and operating a faulty search tool were equally concerning. It should be noted that throughout this investigation, World Vision, the Treasury Department, and U.S. Agency for International Development fully cooperated with this Committee and provided well over a thousand pages of documents. World Vision staff also met with Committee staff on several occasions and provided in depth description of the events in question.

Organizational Background World Vision World Vision United States (World Vision), a subsidiary of World Vision International (WVI), is an Evangelical 501(c)(3) non-profit organization founded in 1950 to provide humanitarian aid and serve as missionaries to impoverished peoples in vulnerable areas.6 WVI has offices in more than 90 countries with international headquarters in the United Kingdom.7 Its United States headquarters are located in Monrovia, California.8 WVI currently provides emergency services and relief in more than 56 countries, mostly in Africa and Asia, but operates across six continents.9 United States Agency for International Development.

The United States Agency for International Development (USAID) is an independent agency within the federal government tasked primarily with administering foreign aid and developmental assistance.10 USAID seeks to advance U.S. interests and national security by promoting social and economic development across the globe.11 It operates in over 100 countries providing food and nutrition, healthcare, education and human resources development.12 USAID administers the international aid through a global network of partners including many private charities.13 As the world leader in humanitarian assistance, USAID provides billions of dollars yearly in foreign aid including over $20 billion in 2018.

Office of Foreign Assets Control.

When engaging in any financial transactions with any foreign person or entity, all U.S. persons must comply with all laws and regulations regarding U.S. sanctions of foreign entities.15 The Office of Foreign Assets Control (OFAC) is the office within the United States Department of the Treasury (Treasury) charged with the administration of the United States’ sanctions regime.16 Sanctions are placed on nations, entities, or persons based on foreign policy and national security goals.17 OFAC maintains a publicly available database online of all sanctioned entities and their aliases.18

Islamic African Relief Agency / Islamic Relief Agency

The Islamic Relief Agency (ISRA) is headquartered in Khartoum, Sudan and maintains over 40 offices worldwide.19 The United States government placed sanctions on ISRA in 2004 after they had funneled approximately $5 million to Maktab Al-Khidamat, the predecessor to Al-Qaeda controlled by Osama Bin Laden.20 ISRA’s leadership also engaged in discussions to help relocate Bin Laden to secure safe harbor for him.21 In the mid-2000’s, ISRA was responsible for moving funds to support a Palestinian terrorist.22 According to Treasury, when raising funds ISRA was known to display two “collection boxes marked ‘Allah’ and ‘Israel,’ signaling the funds would be directed towards attacks against Israelis.”23 Previously, there was a U.S. based branch of ISRA established in Columbia, Missouri in 1985 but it was closed in the early 2000’s.24

Timeline of Events

On January 21, 2014, World Vision United States (World Vision), a subsidiary of World Vision International (WVI), submitted a grant application to USAID to carry out their proposed Blue Nile Recovery Program to provide food security, sanitation equipment and health services to the conflict affected areas in the Blue Nile region of Sudan.25 World Vision was subsequently awarded a grant of $723,405 by USAID to carry out the program.26 On February 1, 2014, World Vision entered into an agreement with Islamic Relief Agency (ISRA) whereby ISRA would provide humanitarian services to certain parts of the Blue Nile Region on behalf of World Vision.27Prior to this, World Vision had worked with ISRA on several projects from 2013 through 2014.28

During the summer of 2014 – while the Blue Nile Recovery Program was in full swing –World Vision entered into talks with the International Organization for Migration (IOM) to work jointly on a separate humanitarian project in Sudan.29 During these conversations, IOM performed its due diligence by conducting a routine vetting of World Vision and its partners which, at the time, included ISRA.30 During this vetting procedure, IOM discovered that ISRA was in fact listed on the sanctioned entity list.31 IOM subsequently reached out to the Office of Foreign Assets Control (OFAC) Compliance Team to confirm that ISRA was indeed a sanctioned entity.32Following OFAC’s confirmation that ISRA was indeed a sanctioned entity, IOM rejected World Vision’s offer to work together on a subsequent humanitarian project.33

In late September 2014, World Vision’s legal department was notified of ISRA’s potential status as a sanctioned entity.34 World Vision immediately ceased all payments to ISRA and began investigating whether ISRA was indeed a sanctioned entity.35 On November 19, 2014, World Vision sent a letter to OFAC requesting clarification of ISRA’s status.36 The letter also includeda request for a temporary license to complete the existing contract with ISRA, despite their status,in the event that ISRA was indeed a sanctioned entity.37According to World Vision, OFAC took longer than expected to respond.38 During this time, World Vision’s field office in Sudan reported that ISRA and the Sudanese government were applying intense pressure on it to pay money owed for services performed.39 On January 20, 2015, two months after World Vision submitted its request for clarification to OFAC, World Vision General Counsel sent an email to OFAC informing them of World Vision’s intent to resume its 5 work with ISRA in a week’s time unless it received a response from OFAC confirming ISRA’s sanctioned status.40On January 23, 2015, Treasury responded to World Vision’s November inquiry and informed it that ISRA is indeed a sanctioned entity.41 Furthermore, in the same letter OFAC deniedWorld Vision’s request for a license to transact with ISRA, stating that authorizing further activities would be “inconsistent with OFAC policy.”42On February 19, 2015, World Vision again requested a license to transact with ISRA in order to pay them $125,000 for services rendered.43 In its request, World Vision stressed that it could face severe legal consequences and even expulsion from Sudan if it did not pay ISRA the monies owed.44 On May 4, 2015, the Obama Administration’s State Department recommended OFAC grant World Vision’s request for a license to pay ISRA $125,000 in monies owed.45 The following day, OFAC granted World Vision a specific license to pay ISRA $125,000 only for services rendered.46 On May 14, 2015, OFAC sent World Vision a “Cautionary Letter” notifyingit that the transactions they engaged in with ISRA appears to have violated the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594, in direct opposition of U.S. law and international sanctions.47

Findings
We did not find any evidence that World Vision intentionally sought to circumvent U.S. sanctions by partnering with ISRA. We also found no evidence that World Vision knew that ISRA was a sanctioned entity prior to receiving notice from Treasury. However, based on the evidence presented, we conclude that World Vision had access to the appropriate public information and should have known how, but failed to, properly vet ISRA as a sub-grantee, resulting in the transfer of U.S. taxpayer dollars to an organization with an extensive history of supporting terroristorganization and terrorists, including Osama Bin Laden. Our review demonstrates this failure occurred because World Vision’s system for vetting prospective sub-grantees was borderline negligent and ignored elementary level investigative procedures, such as failing to conduct basic secondary research that is widely available to the public on the internet via free search engines.48We arrive at these conclusions based on strong evidence that ISRA’s status was easily searchable, and Treasury provided appropriate resources to assist organizations in identifying sanctioned entities. ISRA’s Sanctioned Status and Ties to Terrorism Was Easily Searchable and ConfirmableOn October 12, 2004, OFAC placed ISRA on the Specially Designated Nationals List.49

Moreover, a subsequent press release by OFAC explained the reason for placing ISRA on the sanctioned entity list.50 This press release is public and still available and easily searchable on Treasury’s website.51 This information could have been easily uncovered if an elementary level of vetting of ISRA had been performed by World Vision. World Vision claims that they vetted ISRA by searching for the organization using a software program known as “Watchdog,” which automatically searches various databases including OFAC’s SDN list.52 World Vision claims that the Watchdog search resulted in a hit for ISRA due to their sanctioned status on OFAC’s SDN list; however, World Vision dismissed these findings because the OFAC SDN list identifies ISRA’s location as the State of Missouri instead of Khartoum, Sudan.53 Notably, however, OFAC also clearly states that “all [ISRA] offices worldwide” are sanctioned.54

Additionally, even after World Vision was notified of ISRA’s sanction status by the International Organization for Migration (IOM), it spent several weeks verifying the claim and
8 ultimately found that, despite the aforementioned evidence, it could not determine if ISRA was a sanctioned entity.55 In reaching this conclusion, World Vision relied on what could only be described as flawed logic. For example, World Vision states that during their second vetting process, it did not believe ISRA was sanctioned because it had previously listed ISRA as a sub-grantee in an earlier grant application submitted to USAID for the Blue Nile Project.56 World Vision states that they believed that USAID’s acceptance of the application proved ISRA was not a sanctioned entity.57Additionally, World Vision argued that it did not believe ISRA was a sanctioned entity because it had listed them as a prior sub-grantee when it renewed its general license with OFAC to work in Sudan.58 However, forms from both USAID’s and OFAC’s processes clearly state that it is the responsibility of the applicant to vet all sub-grantees.59 As a result, USAID and OFAC did not vet ISRA. Operating under the industry’s standard operating procedure both organizations presumed that World Vision had performed the required level of due diligence expected of applicants.In determining that World Vision bears the sole responsibility for their failure to properly vet ISRA, we note that IOM was able to quickly vet ISRA and determine their status as a sanctioned entity.60 Had World Vision employed the same due diligence and similar methods employed by IOM, taxpayer dollars would not have exchanged hands with an organization that is known to fund terrorist organizations. World Vision Did Not Take Advantage of Additional Free and Readily Available R esources Provided by Treasury Through the course of this investigation we discovered that World Vision has not been involved or engaged with relevant and helpful industry information and networking events sponsored and provided at no cost by the federal government.61 More specifically, World Vision was not taking advantage of all the tools provided by OFAC to ensure compliance – such as attending the yearly OFAC symposium, or reaching out to experts at OFAC for consultations.62Historically, Treasury hosted two (2) symposia per year, the OFAC Sanctions Symposium which was geared towards non-profit organizations and the OFAC Financial Symposium thatfocused on for-profit private sector companies. These conferences covered a wide range of relevant topics including, but not limited to, working within OFAC’s guidelines and regulations system when working with foreign entities and non-governmental organizations.

Currently OFAC hosts a single, larger Sanctions Symposium in Washington, D.C. which is open to bothaudiences at no cost. NGO representatives are encouraged and eligible to attend the Sanctions Symposium to keep current on the latest trends and topics of interest in the field of foreign dealings and activities. This event helps numerous entities similar to World Vision better understand and work within the framework of federal laws and regulations every year. Further, these events allow industry experts to meet in person to discuss current events, new procedures, and review real world OFAC cases and investigations in order to learn from the mistakes of others. According to Treasury, an inquiry into its OFAC registration records dating back to 2009 indicates that World Vision did not attended a single symposium.63 They did register for the 2014 OFAC Financial Symposium, but were not approved to attend the event, as seating was limited and World Vision is not a financial institution, a requirement for that particular symposium at the time.64 By operating in this space, and not availing themselves of all the resources provided by the government, World Vision continues to unnecessarily expose themselves to significant liability. Further, they are exposing taxpayer funds to potentially illicit uses that are counter to the national security interests of the United States. Equally important, OFAC strongly encourages communication with the public and even provides a hotline and additional points of contact for entities or people that have questions or concerns about compliance with OFAC regulations.65

Through these hotlines, individuals can speak with seasoned OFAC experts, gain a better understanding of how OFAC operates, and ask questions regarding potentially sanctioned groups. It is important to note that by utilizing these hotlines IOM was able to accurately determine ISRA’s sanctioned status in a period of just 18 days. On July 10, 2014 IOM enlisted USAID to contactTreasury and received a response on July 28, 2014.66World Vision’ s Response to Congressional Investigation In response to this incident, World Vision created additional screening methods in an effort to prevent future disbursements of US tax dollars to sanctioned entities. First, World Vision incorporated Blocked Party Screening training into the instruction for all staff receiving U.S. Government grant management training.67 Second, World Vision added several new countries to its list of places where mandatory country-level screening is conducted.68 Third, World Vision updated its vetting protocol by removing country designations/addresses from the initial screening process and disseminated the updates to all registered users of the Blocked Party Screening software.69 Lastly, World Vision revised its screening process by removing the discretion of first level screeners to clear certain types of potential matches, and now necessitates that such potential matches be escalated to an attorney for additional layer of review.70Despite the above changes, the Finance Committee staff has reservations concerningWorld Vision’s ability to avoid situations similar to the ISRA - Blue Nile Recovery Program incident in the future. World Vision’s posture during and after this episode gives the impression they have externalized the responsibility for vetting the groups and organizations with which they choose to affiliate. Consequently, we encourage World Vision to engage in the necessary lines of communication with OFAC and a robust screening process to prevent similar situations from occurring in the future. ConclusionWorld Vision is a multinational charitable organization that regularly generates more than $1 billion in revenue annually, largely via donations from churches around the country, individual believers of their causes, and federal grants. World Vision utilizes most of these funds in an effort to assist those in need. As a result, World Vision’s work takes it to some of the most impoverished and oftentimes dangerous, war torn locations in the world. Some of these locations, such as Sudan, are very active hotspots for terrorist activity. World Vision has a duty to ensure that funds acquired 11from the U.S. government or donated by Americans do not end up supporting terrorist activity. Particularly concerning to this Committee is World Vision’s attempt to shift the blame to the federal government for their own inability to properly vet a subcontractor. A more robust and fundamentally sound system of screening and vetting is needed to restore the public’s trust thatcontributions made to World Vision are not funding illicit organizations. Moreover, although we find no reason to doubt World Vision’s assertion that the funds in their entirety were used by ISRA for humanitarian purposes, that money inevitably aids their terrorist activities.