12-29-20 REPORT: Senate Investigation Finds Obama Admin Knowingly Funded al-Qaeda Affiliate

Posted by: on January 26, 2021

Charles E. Grassley
Oversight and Investigations Unit, Finance Committee
World Vision Financial Transactions
December 22, 2020
Memorandum

Introduction
In 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 Vision
contracted 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
1 Cliff Smith & Sam Westrop, Lost in Sudan: World Vision Worked with and for Terrorist-Funding Organizations, CHRISTIAN
POST (Nov. 3, 2018), https://www.christianpost.com/voice/lost-in-sudan-world-vision-worked-with-and-for-terrorist-fundingorganizations.html; Sam Westrop, Exclusive: Obama Administration Knowingly Funded a Designated al-Qaeda Affiliate, NAT’L
REV. (July 25, 2018), https://www.nationalreview.com/2018/07/obama-administration-al-qaeda-affiliate-knowingly-funded/
(stating that “ISRA officials even sought to help relocate [bin Laden] to secure safe harbor for him.” (internal quotation marks
omitted)).
2 Smith, supra note 1; Westrop, supra note 1. 3 Press Release, World Vision Int’l, World Vision Statement Regarding Our Past Engagement with Islamic Relief Agency in
Sudan (July 25, 2018), https://www.wvi.org/pressrelease/world-vision-statement-regarding-our-past-engagement-islamic-reliefagency-sudan. 4 Id.
5 Id.
2
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 2018.14
6 Our History: Going When No One Else Would, WORLD VISION INT’L, https://www.wvi.org/our-history (last visited Oct. 7,
2020).
7 All locations, WORLD VISION INT’L, https://www.wvi.org/locations (last visited Dec.17, 2020). 8 Contact us, WORLD VISION INT’L, https://www.wvi.org/contact-us last visited Dec. 17, 2020). 9 Impact, WORLD VISION INT’L, https://www.wvi.org/2017impact/ (last visited Dec. 17, 2020). 10 Emily M. Morgenstern, U.S. Agency for International Development: An Overview, Congressional Research Service (2020),
available at https://www.crs.gov/Reports/IF10261?source=search&guid=cf2fd8b02e5c4dc19cddaa201f57478c&index=4; see
also USAID.gov, Financial report 2019 ,available at
https://www.usaid.gov/sites/default/files/documents/1868/USAIDFY2019AFR_508R.pdf. 11 Id. 12 Id. 13 USAID programs are largely implemented by partners including, among others, nongovernmental organizations (NGOS),
international organizations, contractors, universities, private sector companies, and host-country governments. The Series 300
Chapters of the agency’s operational policy—referred to as the Automated Directive System (ADS)—governs the mechanisms
by which USAID works with these partners and offers guidance on how USAID decides among the various mechanisms before
issuing an award. USAID, ADS Series 300, Acquisition & Assistance, accessed October 14, 2020, https://www.usaid.gov/whowe-are/agency-policy/series-300 14 U.S. Foreign Aid by Agency: U.S. Agency for International Development, USAID (2018),
https://explorer.usaid.gov/agencies/?agency=1&measure=Obligations&year=2018.
3
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 AlQaeda 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
15 Letter from Frederick W. Vaughn, Deputy Assistant Sec’y, U.S. Dep’t of the Treasury, to Charles E. Grassley, Chairman,
Senate Fin. Comm. (June 17, 2019) (Appendix A); see also Office of Foreign Assets Control—Sanctions Programs and
Information, U.S. DEP’T OF THE TREASURY https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctionsprograms-and-information (last visited Oct. 7, 2020). 16 Id. 17 OFAC Consolidated Frequently Asked Questions, U.S. DEP’T OF THE TREASURY, https://home.treasury.gov/policyissues/financial-sanctions/frequently-asked-questions/ofac-consolidated-frequently-asked-questions (last visited Oct. 7, 2020). 18 Sanctions List Search Tool, U.S. DEP’T OF THE TREASURY, https://home.treasury.gov/policy-issues/financialsanctions/sanctions-list-search-tool (last visited Oct. 7, 2020). 19 Resource Center, Terrorism and Illicit Finance, Protecting Charitable Organizations—I, U.S. DEP’T OF THE TREASURY (last
updated Aug. 16, 2016), https://www.treasury.gov/resource-center/terrorist-illicit-finance/Pages/protectingcharities_execorder_13224-i.aspx. 20 See id. (providing “Additional Background Information on Charities Designated Under Executive Order 13224”). 21 Westrop, supra note 1 (stating that “ISRA officials even sought to help relocate [bin Laden] to secure safe harbor for him.”
(internal quotation marks omitted)).
22 See Resource Center, Terrorism and Illicit Finance, supra note 19. 23 Id. 24 Id.
4
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.27
Prior 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.32
Following 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 included
a 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.37
According 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
25 World Vision, Inc., Program Title: Blue Nile State Recovery Program (Jan. 21, 2014) (attached herein as appendix B). 26 Letter from Michael A. Clark, Agreement Officer, USAID, to Debebe Dawit, Program Mgmt. Officer, World Vision, Inc.
(Mar. 14, 2014) (attached herein as appendix C) 27 Islamic Relief Agency for the Purpose of Water Sanitation and Hygiene For Meeting Urgent Health and WASH Needs for
Conflict-Affected Communities in Blue Nile State, World Vision Int’l-Islamic Relief Agency, Feb. 1, 2014 (attached herein as
appendix D). 28 Letter from Tim Burgett, World Vision General Counsel and Steve McFarland, World Vision Chief Legal Officer to Charles
Grassley, U.S. Senator (Mar. 19, 2019) (attached herein as Appendix E) at pg. 6. 29 E-mails between Elizabeth H. Campbell, Matthew Harvey, et al., re: World Vision ISRA (Jan. 9, 2015) (on file with Comm). 30 (Letter from Luca Dall’Oglio Chief of Mission, International Organization for Migration (July 16, 2019) (attached herein as
Appendix F) 31 Id. 32 Id. 33 Id. 34 Supra 28 35 E-mails between Elizabeth H. Campbell, Matthew Harvey, et al., re: World Vision ISRA (Jan. 9, 2015) (on file with Comm). 36 Letter from Tim Burgett, World Vision General Counsel and Steve McFarland, World Vision Chief Legal Officer to Adam
Szubin Director, Office of Foreign assets Control (Nov. 19, 2014)(attached herein as Appendix G) 37 Id. 38 E-mails between Tim Burgett, Aydin Akgun, et al., re: World Vision, Urgent Clarification About Sudanese Partner (Jan. 20,
2015) (attached herein as Appendix H). 39 E-mails between Tim Burgett, Aydin Akgun, et al., re: World Vision Sudan, SDGT-2015-316891-1 (herein attached as
appendix I)., Letter Threatening Legal Action (May 2, 2015) (herein attached as appendix J).
5
work with ISRA in a week’s time unless it received a response from OFAC confirming ISRA’s
sanctioned status.
40
On 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 denied
World Vision’s request for a license to transact with ISRA, stating that authorizing further
activities would be “inconsistent with OFAC policy.”42
On 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” notifying
it 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 terrorist
organization 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.
48
We arrive at these conclusions based on strong evidence that ISRA’s status was easily searchable,
40 E-mails between Tim Burgett, Aydin Akgun, et al., re: World Vision, Urgent Clarification About Sudanese Partner (Jan. 20,
2015) (appendix H). 41 Letter from Davin J. Blackborow, Assistant Director for Licensing, U.S. Dep’t of the Treasury to Tim Burgett, Gen. Counsel,
World Vision Int’l, to (Jan. 23, 2015) (attached herein as appendix K) 42 Id. 43 Letter from Tim Burgett, Gen. Counsel, World Vision Int’l, to Davin J. Blackborow, Assistant Director for Licensing, U.S.
Dep’t of the Treasury (Feb. 19, 2015) (Appendix L). 44 Id. 45 Timeline (attached herein as appendix M) 46 U.S. Dep’t of the Treasury, Global Terrorism Sanctions Regulations, Sudanese Sanctions Regulations, License No. SDGT2015-316891-1 (May 5, 2015) (attached herein as appendix N). 47 Letter from Jeremy Sausser, Enf’t Section Chief, U.S. Dep’t of the Treasury, to Tim Burgett, Gen. Counsel, World Vision Int’l,
and Steven McFarland, Chief Legal Officer, World Vision, Inc. (May 14, 2015) (attached herein as appendix O). 48 GOOGLE.COM.
6
and Treasury provided appropriate resources to assist organizations in identifying sanctioned
entities.
ISRA’s Sanctioned Status and Ties to Terrorism
Was Easily Searchable and Confirmable
On 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
49 Press Release, U.S. Dep’t of the Treasury, Treasury Designates Global Network, Senior Officials of IARA for Supporting bin
Laden, Others (Oct. 13, 2014), https://www.treasury.gov/press-center/press-releases/Pages/js2025.aspx. 50 Id. 51 Id. 52 Letter from Steve Burgett and Steven McFarland, World Vision, to Charles E. Grassley, Chairman, Senate Fin. Comm. (Mar.
19, 2019) (Appendix E). 53 Id at pg. 8. 54 https://sanctionssearch.ofac.treas.gov/Details.aspx?id=1138
7
Additionally, OFAC’s website contains a brief description of ISRA which states that it is
headquartered in Khartoum, Sudan.
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.
57
Additionally, 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 Resources 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.
62
Historically, Treasury hosted two (2) symposia per year, the OFAC Sanctions Symposium
which was geared towards non-profit organizations and the OFAC Financial Symposium that
focused 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,
55 Letter from Steve Burgett and Steven McFarland, World Vision, to Charles E. Grassley, Chairman, Senate Fin. Comm. (Mar.
19, 2019) (Appendix E) at pg. 9. 56 Id. at pg. 2. 57 Id. 58 Id. 59 See appendix M; see also Letter from Richard C. Parker, Assistant Adm’r, USAID to Charles E. Grassley, Chairman, Senate
Finance Committee (June 24, 2019) (Appendix Q). 60 (Letter from Luca Dall’Oglio Chief of Mission, International Organization for Migration (July 16, 2019) (Appendix F) 61 Email from Frederick Vaughan to Committee staff (Oct. 24, 2019) (on file with Comm). 62 Email from Frederick Vaughan to Committee staff (Oct. 24, 2019) (on file with Comm).
9
OFAC hosts a single, larger Sanctions Symposium in Washington, D.C. which is open to both
audiences 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
63 Email from Frederick Vaughan to Committee staff (Oct. 24, 2019) (on file with Comm). 64 Email from Frederick Vaughan to Committee staff (Oct. 24, 2019) (on file with Comm). 65 Contact OFAC, U.S. DEP’T OF THE TREASURY, https://home.treasury.gov/policy-issues/financial-sanctions/contact-ofac (last
visited Oct. 8, 2020).
10
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 contact
Treasury and received a response on July 28, 2014.66
World 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.70
Despite the above changes, the Finance Committee staff has reservations concerning
World 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.
Conclusion
World 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
66 E-mails between Harold L. Cohen, Heather Epstein, re: Islamic Relief Agency World Vision, (July 28, 2014) (attached herein
as Appendix R). 67 Letter from Steve Burgett and Steven McFarland, World Vision, to Charles E. Grassley, Chairman, Senate Fin. Comm. (Aug.
20, 2019) (herein attached as appendix P). 68 Id. 69 Id.
70 Id.
11
from 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 that
contributions 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.