Researchers at the Center for the Study of Global Christianity, writing for the International Bulletin of Mission Research, estimate that $55 billion will be spent on foreign missions in 2023. That may seem like a lot, but the same researchers also estimate that Christian religious leaders will embezzle $62 billion in 2023.

Foreign mission organizations are notorious for their lack of transparency. Gospel for Asia, which raises millions of dollars to support missionaries,  doesn’t disclose to donors important financial information such as total annual revenue, total annual expenses or compensation for highly paid executives.

Compounding the problem, American tax laws are poorly understood and poorly enforced, often resulting in noncompliance. If a church operates a mission project in a foreign nation with a foreign bank account and the foreign account exceeds $10,000, the church is required by the Bank Secrecy Act to file a Report of Foreign Bank and Financial Accounts (FBAR).

To make matters worse, if a church or ministry reports a foreign bank account, the report is confidential and cannot be revealed to church or ministry donors. Corrupt religious leaders can engage in international money laundering and the existence of their foreign bank accounts are shielded by privacy laws.

Australian Charity Rules

Some countries such as Australia have stricter laws regarding foreign reporting and foreign expenditures for churches.

In 2022, Hillsong Church employee Natalie Moses turned whistleblower. Moses served as Fundraising & Governance Coordinator for Hillsong Global Corporate Group.

According to Moses’ statement of claim, Brian Houston, the founder and former senior pastor of Hillsong “announced that $10,000 would be given to persons who were his former interns and who had sought to start a ‘Hillsong’ Church in Bucharest, Romania.”

Moses responded by informing a supervisor the direct cash payments to individuals in Romania by Australian non-profit organizations was prohibited.

To avoid violating Australian law, Hillsong Global LLC (an American non-profit limited liability company) transferred the funds. Meanwhile, Hillsong Global does not file a Form 990 disclosing its foreign spending because American churches and church integrated auxiliaries are exempted from filing the non-profit information return.

Moses raised additional concerns that Hillsong was failing to comply with Australian laws.

Australia has adopted Four External Standards which regulate foreign non-profit spending and reporting. Australian churches are not exempt from these standards.

The Australian Charities and Not-for-Profits Commission requires foreign financial records to be “complete, accurate and legible.” Australian churches and ministries should compile a list of all foreign third-party organizations they collaborate with. Non-profit organizations are expected to document criminal and illegal activities committed by employees after misconduct is discovered.

Unfortunately for Australian Christians, these complete records are not available for church donors. Instead, they must be made available to government officials that request them.

The Australian Charities and Not-for-Profits Commission provides basic financial information for Australian churches and ministries, but good luck finding Hillsong Church’s foreign missions expenditures.

(Photo: Hillsong Church Ltd. reporting no foreign expenditures for 2021.)

Continue reading “Foreign Financial Reporting: When Church and Ministry Money Travels to Foreign Countries”

By Pete Evans and Barry Bowen

Trinity Foundation President Pete Evans delivered the following speech during the Corruption and Impunity in God’s Name forum at the International Anti-Corruption Conference 2022 held today in Washington, D.C. The conference is a project of Transparency International which is non-profit advocating for financial transparency on a global scale.

Thanks for your introduction Hazel, I’m Pete Evans, president of Trinity Foundation in Dallas, Texas and we’ve been investigating and exposing religious fraud and excess for over 3 decades now. I’ve been a licensed private investigator for most of that time and have worked undercover for months at a time in religious organizations on 3 occasions.  We regularly provide information to journalists and governmental agencies such as the exempt organization division of the IRS.

BUT, there is a veil of financial secrecy that shrouds and protects religious organizations.

Churches, Synagogues, Mosques, and other religious entities in America do not have to report any financial information either to the IRS, the public, or their own congregations.  This is known as “church status” and their financial disclosure is only voluntary.

We’ve seen this veil of secrecy lead to massive waste and extravagance, money laundering, bulk-cash smuggling, a tremendous indifference to the poor and downtrodden, and even rape, pedophilia, or sex-trafficking by televangelists, pastors, priests, and other church leaders—all in the name of God.

In 2007, cumulative reports from Trinity Foundation spurred Senator Charles Grassley of the US Senate Finance Committee to begin investigating religious fraud and self-dealing by requesting financial records and threatening numerous subpoenas to six prominent media ministries.

The threat of public testimony into abuses of the tax code before the senate scared the televangelists and heads of religious denominations.

So what became of the inquiry?  The Senate probe caused a momentary spike in awareness but was largely ignored by the US media and the investigation eventually went nowhere.

One of several reasons for the Senate’s failure to act was that the televangelists being investigated combined their resources to hire lawyers, lobbyists, and social media experts.

For publicity purposes, the suspected media ministries created a website that claimed religious persecution.  Of course, that was never the issue, it was always only about the misuse and extravagant waste of donor money.

What will it take to bring a wake-up call for transparency to religious organizations?

In 2008, Trent Huddleston, a former accountant at Oral Roberts University, America’s university of choice for charismatic and Pentecostal Christians, sued the university for discharging him “after fifteen months of intimidation and harassment.”

Huddleston alleged that university officials ordered him “to cook the books.” Buried on page 4 of the lawsuit was the most serious allegation: more than $1 billion US dollars flowed annually through an unrestricted account.

That should have spurred on an army of investigative reporters to follow the money. But nothing came of it. Aside from a couple of articles at the Tulsa World newspaper, journalists failed to explore the scandal.

Buried in government documents, inaccessible to journalists, there may exist Suspicious Activity Reports (or SARS) to verify allegations of money laundering at Oral Roberts University and prominent Christian media ministries.

Financial institutions are required to file Currency Transaction Reports when a person deposits or withdraws $10,000 or more in cash. When individuals attempt to avoid reporting requirements by making multiple deposits or withdrawals in a short amount of time, often called “structuring,” financial institutions are required to file these Suspicious Activity Reports (or SARS).

Unfortunately for investigative reporters and private investigators the Bank Secrecy Act prohibits the release of these reports to the public.

Additional allegations of massive money laundering involving religious organizations have surfaced with little media attention.

On May 3, 2000, the United States was preparing for a possible indictment of televangelist Benny Hinn for money laundering when the government’s main witness died of a suspicious heart attack.

Benny Hinn Ministries obtained a protective order to prevent disclosure of critical information.

But sometimes there are legal ways to obtain the truth. A Freedom of Information Act Request (or FOIA request) to the FBI revealed that Hinn’s former Chief Financial Officer Gene Polino allegedly embezzled $400,000 per week at one point.

One ideal way to smuggle dark money is via private aircraft, by boat, or similar means.  It’s typically called Bulk-Cash-Smuggling which Title 31 U.S.C. § 5332 “makes it a crime to smuggle or attempt to smuggle more than $10,000 in currency or monetary instruments into or out of the United States, with intent to evade U.S. currency reporting laws” (Also, see Title 31 U.S.C. §§ 5316 and 5317).

Trinity Foundation tracks televangelist jets daily with our Pastor Planes social media accounts (Instagram and Twitter). We’ve observed flights to the Bahamas, the Cayman Islands, Nevis, and other well-known tax haven nations over the years.

One of our informants has a nickname for televangelist jets—he calls them “laundry tubes.”  The televangelist he worked for smuggled stacks of cash from country to country and then back to the US on his jet—tons of money and jewels.  When offerings were taken in other countries, this particular televangelist would personally gather some of the money and the best of the jewelry to keep for himself.

On one occasion, the cash on this jet was stacked to the ceiling of the aircraft.  On another occasion, this particular televangelist smuggled a bunch of valuable red rubies from the offering plate out of Russia on his jet and our informant was detained and questioned by Russian authorities for three days about the rubies.

Another televangelist’s jet was reportedly used for bringing hundreds of thousands of dollars into the country illegally and on one occasion gunrunning of machine guns.

In the 1990s, a DEA informant reported a pallet stacked with cash in a Mexican airport destined for Haiti.  The cash was thinly covered by televangelist Robert Tilton’s brochures.

In 2015, our small organization expanded our investigations abroad.

Shortly prior to the COVID Pandemic, Trinity Foundation reported bulk cash smuggling to the FBI by one large multi-national church with hundreds of church locations in the Western Hemisphere funneling money overseas, out of the US.

On multiple occasions IRS officials have acknowledged the dark money problem in churches. In 2005, IRS Commissioner Mark Everson sent a letter to Senator Chuck Grassley claiming because churches were not required to file an informational return, “we have little ability to monitor their operations against diversion of assets.”

In recent years, some of America’s largest religious non-profit institutions have been reclassified as churches to avoid reporting requirements.

The Billy Graham Evangelistic Association, Gospel for Asia and CRU (formerly named Campus Crusade for Christ) no longer file a Form 990 which discloses compensation for ministry executives.

Back to Senator Grassley’s already weakened 2007 inquiry, in 2011 Grassley requested the Evangelical Council for Financial Accountability, known as ECFA for short, to establish a commission to study and offer solutions to abused tax code loopholes.

The ECFA requires its members to be financially transparent, but in practice, looks the other way and rarely enforces its requirements.

In this case, the ECFA commission became a textbook example of regulatory capture­­ (also called agency capture or state capture) whereby the organizations to be regulated take control of the process. Some CPAs and attorneys of the same six ministries under threat of subpoena were appointed to the ECFA task force, like foxes guarding the henhouse.

Meanwhile, the mainstream media never reported on the lobbying efforts that were taking place behind the scenes. Televangelist Benny Hinn would later tell his TV audience that he spent $5 million fighting the inquiry.

Hinn hired two former IRS Commissioners, Larry Gibbs and Fred Goldberg, to represent him during the inquiry.

Invariably, these unreported church funds make their way into the political process. Dark money buys influence.

Some televangelists also use church and ministry-owned jets to travel to political rallies and religious events with political campaigning overtones.

Last month, Kenneth Copeland flew on his church-owned jet to West Palm Beach, Florida to join Trump’s entourage in Trump’s jet flying to Pennsylvania where Copeland prayed at a campaign rally on behalf of Senate candidate Dr. Oz.

Should these aircraft receive a tax-exemption? The IRS needs to investigate and provide guidance on inappropriate uses of non-commercial aircraft.

Ministry’s dark money even reaches the politicians sometimes. According to one of our informants, a non-profit religious TV network would give money to employees to illegally donate to politicians.

So what can be done about the problems of church and ministry financial abuses?

Here’s a multi-prong approach necessary to address the growing decline of financial transparency and the increase of dark money in religious institutions.

1. Increase financial transparency in religious institutions.
2. Amend laws to provide greater access to financial data such as SARS.
3. Educate the public regarding donor responsibility.

Churches and ministries must be required to file a Form 990 which discloses total revenue, total expenses and the compensation of executives.

Congress should amend both the 1974 Privacy Act and Bank Secrecy Act to allow for the release of information in the public interest.  For example, both for-profit and not-for-profit corporations should be required to submit to increased scrutiny by the public—these are not private persons, they are man-made entities.

Additionally, non-profit companies should not be allowed to form shell companies, limited liability companies, or shadow companies.

Allow journalists to obtain Currency Transaction Reports and Suspicious Activity Reports by filing FOIA requests.

Law enforcement and regulatory agencies like the IRS should provide status reports to whistleblowers. Currently, when Trinity Foundation submits a complaint to the IRS, the IRS is prohibited from revealing if an audit or criminal investigation has been launched or closed.

In the rare cases the IRS revokes the tax-exempt status of a non-profit, the IRS sends the organization a revocation letter which is confidential. These letters should be available via FOIA requests so journalists and donors can see if the organization used donations to pay any penalties.

The United States Congress could also take a cue from Australia’s external standards for non-profit organizations. Australia requires non-profit organizations, including churches, to disclose how funds are spent when they are used in foreign countries.

After Hillsong Church’s Australian leadership was informed that sending cash to Romanian individuals would need to be reported, the church sent them money anyway from Hillsong Global LLC, an American church-related company. Hillsong Global does not file a 990 which would disclose this kind of transaction.

There is complete opacity, the system is broken down, it’s not working!

With these legal changes, greater transparency would reduce the ability of churches and ministries to launder money and illegally buy political influence. The time to act is now.

If anyone wants to talk about this, I’ve got lots of examples!

(End of Speech)

APPENDIX

Here are some recent examples:

In 2019, a private jet belonging to the international leader of the Philippine-based The Kingdom of Jesus Christ Church, Apollo Quiboloy was detained for bulk-cash smuggling.  His employee, Felina Salinas, was caught with a suitcase containing more than $300,000 in Hawaii. Apollo Quiboloy, a preacher that promotes himself on social media as “the Appointed Son of God” claims over 6 million followers in over 200 countries.

In November 2021, Quiboloy was indicted by a Federal Grand Jury and is on the FBI’s most wanted list for Sex Trafficking by Force, Fraud and Coercion, and Sex Trafficking of Children by Force, Fraud, and Coercion; Conspiracy; and Bulk Cash Smuggling.

We used to call televangelist Benny Hinn the “Teflon televangelist” because of his slippery avoidance of prosecution or tax revocation by the US government.  His ministry claims to be a church and has the secretive “church status”.

However, Brazilian televangelist Edir Macedo, may be the greasiest, slimiest tele-preacher.  Macedo, perhaps the wealthiest televangelist in the world, was arrested in August 2009 in Brazil for siphoning billions of dollars from mostly poor followers to buy TV stations, businesses, and jewelry for himself.    He was charged along with nine others for massive money laundering through fake companies but was never convicted.

Macedo’s church (but not Macedo) was accused again of money laundering in 2020.  According to Brazilian news site Poder360, in one fiscal year, May 2018 to April 2019, at least 5.9 billion reals–approximately $1.093 billion in US dollars–moved through church bank accounts in a questionable manner.

Malawi televangelist Shepherd Bushiri, who claims to walk on air, was arrested two years ago in South Africa for money laundering the equivalent of over $6 million dollars.  Bushiri skipped bail and fled to Malawi where he enjoys protection from the government. Pretoria, South Africa’s News 24 has reported the South African government faces a January 25, 2023 deadline to complete its investigation. Then  a final extradition hearing should be held.

 

More on Hinn

Hinn’s former attorney Larry Gibbs works for Miller & Chevalier, a law firm that specializes in “thwarting investigations.” It’s no joke, the law firm website says, “Given the stigma of being accused of criminal activity, clients seek our early and rapid intervention to thwart investigations before they become public.”

Hinn’s other former attorney Fred Goldberg was the IRS Commissioner that granted the Church of Scientology its tax exemption.

It’s likely that Gibbs or Goldberg met with Senator Grassley on Hinn’s behalf, but neither registered as lobbyists.

Hinn’s Ministry with its church status files no Form 990 and does not disclose how much money the organization spends on legal expenses.

Jim Bakker

While not a recent example, many people have forgotten that as televangelist Jim Bakker’s media empire collapsed, journalists reported the existence of two sets of books: The fictitious numbers and the real numbers.

More on Politics:

In 2020, TV preacher Robert Morris flew to Washington, D.C. in Daystar Television’s Gulfstream G5 jet for the National & Global Day of Prayer and repentance featuring a prayer proclamation from Donald Trump.

Daystar’s jet and televangelist James Robison’s jet traveled to California where Robison and Daystar president Marcus Lamb (and family) attended a political fundraising event at the Ritz Carlton in Dana Point.