Running head: NOT FOR PROFIT?

Not for Profit? Corruption and Fraud in Nonprofit Organizations

Abigail Wagner
First Colonial High School
Legal Studies Academy
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Abstract
This paper explores the causes, effects, and prevention methods regarding nonprofit fraud. It

dives into details about who the common ‘fraudster’ is, and how nonprofit organizations can help

alleviate their risk of fraud schemes. This paper will examine the various types of fraud and

specific cases of nonprofit fraud throughout the United States. It will analyze the overall problem

of fraud and give insight as to the laws governing nonprofit organizations in Virginia.

Keywords: fraudster, fraud, nonprofit organization

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Not for Profit? The History and Classifications of Nonprofits

The definition of a nonprofit organization is simply in its name. They are not run for

profit. The money accumulated by nonprofit organizations is used for the activities of the

organization and to distribute reasonable salaries to its employees. Each state has different laws

governing nonprofits. Nonprofits will get tax exemptions and breaks from the states if they are

helping the community. This is especially seen in nonprofits who are working for “religious,

charitable, scientific, public safety, literary, or educational purposes.The Internal Revenue

Service must approve the tax-exempt status of all nonprofit organizations except churches”

("Non-profit Law"). Workplace fraud is “the use of one’s occupation for personal enrichment

through the deliberate misuse or misapplication of the employing organization’s resources or

assets” (Menard, n.d.). Nonprofit organizations run by private donations and volunteer work

originated in the mid 1700s, and they were mainly religion based organizations. However, the

government started regulating these organizations in the 1900s (WP Admin, "Nonprofit

Organizations"). These organizations have yet to have sufficient regulations and requirements

that prevent them from fraudulent activities. Nonprofit organizations are more susceptible to

fraud. Not only do many of them consist of a team of volunteers who have access to private

information (Menard, n.d.), but these organizations are run by donations, so they don’t have as

much money for salaries which may provoke illegal actions. Current laws governing nonprofit

organizations allow for an abundance of fraud because they are far too vague.

Why Nonprofit Fraud Is Such A Big Issue

Nonprofit organizations employ 11 million people in the United States and another 110

million people are volunteers for these organizations. The average nonprofit organization “loses
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about 5% of annual revenues to fraud, which is equivalent to $3.5 trillion annually,

worldwide”(Neier, n.d.). According to the Association of Fraud Examiners 2012 Global Fraud

Survey, “The median loss caused by occupational fraud was $140,000 and reported frauds last

approximately 18 months before detection” in 2012 (Ay, 2014). Nonprofit fraud made up about

10% of the total fraud in the United States in 2013, which was an increase from 2012. Fraud is

much easier and more common when the unemployment rate is high. Not to mention, with the

development of technology, cybercrime is now an issue. Fraudsters can hack into computer and

banking systems of nonprofits. In order to stop the criminal from repeating the crime, the

organizations should report the fraud. However, if people hear about fraudulent activities being

associated with that organization, they might not be willing to donate. Nonprofit organizations

rely on donations. Therefore, fraud affects nonprofit organizations more than it seems, since they

usually don't have much money. Fraudsters are extremely technologically savvy and creative. It

is hard to avoid fraud, so it is best for nonprofits to catch and anticipate fraud early on (“Fraud

Risk Is on the Rise for Nonprofits--and the Impact Can Be Fatal,” 2015). Nonprofit organizations

have “excessive control placed in the founder, executive director, or substantial contributor and

frequently have all-volunteer boards of directors that cannot provide adequate financial

oversight,” which is why nonprofit fraud is such a big issue (Menard, n.d.). However, the issue is

often overlooked, because of the lack of media coverage. Nonprofits avoid reporting their

fraudulent experiences since that would give them a bad reputation. These organizations run off

of donations, and it could kill their success if they had any sort of fraudulent act associated with

their organization. Only about 65.2% of organizations who dealt with fraudulent activities

reported their case to law enforcement (Neier, n.d.).

When Fraud is More Likely to Occur

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Nonprofit fraud most commonly occurs when the country is facing overall financial

difficulty. Fraud schemes have become more and more common as time goes by because of the

advancement of technology. According to the Global Fraud Report, “fraud has continued to

increase, with three quarters (75%) of companies reporting they have fallen victim to a fraud

incident within the past year, an increase of 14 percentage points from just three years ago”

(Kroll, 2016). Since fraud is on the rise, if companies can recognize when fraud schemes might

occur, they are more likely to avoid or stop them from happening.

Where Is The Money Going

“Nonprofit organizations like the Breast Cancer Relief Fund have raised almost $64

million, and yet barely more than 2% of these donations raised were actually given to hospitals

and cancer victims”(Kandt, 2016). Many donors don’t realize where their money is actually

going. We never see nonprofit fraud on the media. These organizations cover up their scandals

so that people will keep donating. Fraudsters use the money for personal expenses such as

vacations, jewelry, and cars. Just because the organization is ‘nonprofit’, doesn’t necessarily

mean that they are following the rules. The laws governing nonprofit organizations are far too

vague, allowing for nonprofit organizations to stretch the boundaries and violate the laws without

media coverage.

Who Are The Perpetrators

According to the Association of Certified Fraud Examiners, the average fraud suspect

doesn’t have previous charges and hasn’t had any fraud convictions before (“Who Is Most Likely

to Commit Fraud at Your Company?,” 2010). Fraud suspects are most likely males between the

ages of 31 and 45. Interestingly, according to the Association of Certified Fraud Examiners’

2010 Report to the Nations on Occupational Fraud & Abuse, the older the perpetrator, the more
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money they are likely to fraudulently take from the organization. Janet Greenlee, an associate

professor of accounting at the University of Dayton, who has studied employee fraud in

nonprofit organizations, said “As the economy gets worse, you'll find there's more pressure, and

people who have the opportunity to commit fraud will find the rationalization to do it” (Frazier,

2009). Nonprofit organizations must be attentive during times of national economic hardship.

During troubled times, people are more likely to take risks to get rewards. When a nonprofit

organization starts cutting positions and giving people more responsibility and access, the risk of

fraud rises as well (Frazier, 2009). When an employee has access to more information and the

economic databases, they become more enticed to commit fraud. It is important for a nonprofit

organization to spread out the leadership in the organization so that they can have balance the

power. These organizations also must be more attentive to their employees’ economic activities

during times of national financial difficulty.

Common Schemes

There are five main schemes that frequently take place in nonprofit organizations: check

tampering, billing, expense reimbursement, corruption, and payroll. Check tampering is “a

fraudulent disbursement scheme in which the perpetrator steals the nonprofit’s funds by

intercepting, forging or altering a check drawn on one of the organization’s bank accounts”

(Bailey, 2017). For instance, if an employee of a nonprofit organization put his name on a blank

check from the company, that would be considered a check tampering scheme. The second

common scheme is billing. A billing scheme occurs when “the perpetrator causes the nonprofit

to issue a payment by submitting invoices for fictitious goods or services, inflated invoices or

invoices for personal purchases” (Bailey, 2017). If an organization’s employee bought a watch

for themselves and bill the nonprofit for it, that would be a billing scheme. The third main
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scheme is expense reimbursement, which is a scheme in which the offender files bogus or

inflated business expenses from the nonprofit for reimbursement. If an employee applied for

reimbursement for his hotel on a personal vacation, and he submitted a false expense report

saying that it was for business, than that would be an expense reimbursement scheme (“Insights,”

2014). The fourth main scheme occurring in nonprofit organizations is corruption: when an

employee violates rules of their job in the nonprofit to a gain direct or indirect benefit. A well-

known example is the Red Cross Scandal. “After the 2010 earthquake in Haiti, the American

Red Cross raised over half a billion dollars but built only six homes” (Kandt, 2016). The last

well known fraud scheme is payroll. Payroll occurs when “the perpetrator causes the nonprofit to

issue payment by making false claims for compensation” (Bailey, 2017). This commonly

happens when employees of a nonprofit organization claim that they worked overtime, but really

didn’t. Since there are so many ways that employees and outside donors can commit fraud, it is

sometimes difficult to make sure the organization is secure. With the rapid advancement of

technology, committing fraud is much more efficient and accessible. It is apparent that nonprofit

organizations must take the proper precautions to avoid these schemes.

Virginia Nonprofit Laws

“Any nonprofit group or organization located in Virginia, unless exempt, must register

with the Virginia Department of Agriculture and Consumer Services” (“Nonprofit Regulation in

Virginia,” n.d.). Only 32 states in the United States require nonprofits to register. Religious

groups, the Red Cross, and political groups don't have to register in Virginia and also don’t have

to file for exemption from taxes (“Nonprofit Regulation in Virginia,” n.d.). In Virginia, nonprofit

organizations are legally referred to as nonstock corporations. These nonstock corporations are

governed by the Virginia Nonstock Corporation Act, which “provides specific rules with regard
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to naming the corporation, adopting bylaws and holding organizational meetings” (Thomas,

n.d.). However, the Nonstock Corporation Act is unclear and easily manipulated. According to

development/executive director of Toby's Dream, Joan Steele, the laws governing nonprofits are

way too vague. She said, “Some nonprofits are created to be a tax shelter for individuals, where

others are created to actually provide a service for the community. I do believe the guidelines to

become a nonprofit should be adjusted” (J. Steele, Personal communication, November 3, 2017).

Joan Steele’s organization, Toby’s Dream, grants one last wish to children suffering from

terminal illnesses. Toby’s Dream has yet to experience financial fraud but is aware that it is

common. This nonprofit organization located in Virginia is one of the many that is at the risk for

fraud schemes. Stricter, more specific laws governing nonprofits are essential to the safety of the

organizations in Virginia.

Cases

It is important for nonprofit organizations to catch the fraudulent activities early on.

According to Report to the Nations on Occupational Fraud and Abuse, 2016 Global Fraud Study,

the median duration of fraud is 18 months (Reifschlager, 2017). If they catch the fraud late, by

that time the offender will have to serve years of jail time and most likely won’t be able to pay

the organization back for their losses. Sadly, in many cases, the organization struggles to recover

from their losses. In addition, charities are having to give back donations. Clawback, “when

organizations have been asked to return anywhere from a couple thousand dollars to millions of

dollars each in response to government efforts to take back ill-gotten gains from financial

frauds”, is a recurring calamity in our world today (Blum, 2011). Organizations often are paying

the price twice when it comes to fraudulent donations. Not only are they sometimes getting the

word fraud associated with their organization, but they also have to give back the donations that
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they might have already put to use. Fraud can make a tremendous impact on a nonprofit

organization.

On October 13, 2017, Lucina Marie Stapleton went to court for creating a fictitious

nonprofit organization for a lady whose son has cancer. Only a small portion of the funds

generated from her organization went to efforts for the boy ("Woman Facing Fraud Charge after

Allegedly Creating Fake Nonprofit for Boy with Cancer," 2017). She used the money to pay cell

phone bills and is facing charges of fraudulent schemes, theft and forgery (Press, 2017). Our

society underestimates the capabilities of the “average joe.” People like Lucina make themselves

seem like good samaritans. Fraudsters are smart. They cover up their schemes and keep their

secrets to themselves. Lucina made it seem as if she was giving to others, while at the same time

she was keeping the money for herself. Fraudsters are selfish, deceitful, and unpredictable.

Unfortunately, many fraud cases involve stolen money in the hundred thousands, not just the

thousands. This makes it painfully difficult for these nonprofit organizations to recover from the

fraud schemes.

Lola Jean Amorin, a 69 year old female accountant, was charged in September for

reportedly stealing $6 million from a Hawaii nonprofit organization that helps people with

developmental and intellectual disabilities. She had been embezzling this money from late 2006

to early 2017. She formerly was employed as the senior accountant by the nonprofit organization

that she stole money from: The Arc in Hawaii (Nagaoka, 2017). Nonprofit organizations,

therefore, need to take precautions in making sure their employees are being genuine in their

work. When employees like Lola have access to the organization’s financial records, it makes it

easier for them to violate the terms and rules of their job by embezzling money. It may be

arduous to catch employees stealing money from the organization since an abundance of trust
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has been put in them to carry out their duties faithfully. Even though fraudsters commonly have

no previous offenses, it is immensely important for organizations to keep an eye on each

employee and donor with background checks and other remedies. It is also crucial for nonprofit

organizations to have a balance of power. If one individual holds too much power, they can take

advantage of the organization and possible get involved in a fraud scheme. Frequently with

nonprofit fraud cases, the fraudster is involved in the organization.

Bill Davis, former CEO of Community Action of Minneapolis, a nonprofit organization

aimed to help low-income people, pleaded guilty in June of 2016 to 16 counts of theft and fraud.

Between 2009 and 2014, Davis had been stealing $4,000-$6,000 each month from the

organization for personal expenses. Between 2011 and 2013, he misspent $800,000 on vacations,

golf, and car loans (Matos, 2016). Sometimes the least expected leader of the organization will

be the one to disrespect its integrity. Often times in nonprofit fraud schemes, the CEO of the

organization is the fraudster. They hold so much power in the organization that they can easily

cover up illegal activities. Furthermore, the CEO of a nonprofit organization would be the least

expected to embezzle money from a good cause, especially their own organization. Bill Davis

used money that should have been going to low-income people to fund his luxurious life. He

used the stolen money to fund a vacation to the Bahamas, purchase a new car, and for other

personal commodities.

In October of 2017, Cesar Tavera was sentenced to more than five years for embezzling

money from a nonprofit organization in New Jersey. Like most others, Tavera was involved in

the organization, Nueva Vida Behavioral Health Center of New Jersey. In fact, he was the

executive director of a community health center which provides mental health services for the

city’s unprivileged residents. Not only did Cesar Tavera steal more than $1.5 million from the
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organization for gambling and personal vacations, but his wife also pleaded guilty in June to

embezzling $40,000 from the nonprofit (Moran & Boyer, 2017). That is a ton of money. The

state laws that govern nonprofit organizations are far too broad, allowing for employees of

organizations to easily embezzle money and lots of it. People take advantage of these laws as

well as the tax exempt status of their organization. There should be more specific and strict

requirements for organizations to be deemed as “nonprofit” and for them to redeem the tax

exemptions. It is necessary for nonprofits to take proper precautions to prevent fraud schemes

such as the Tavera’s, Bill Davis’s, Lucina Stapleton’s, and Lola Amorin’s.

How To Prevent Fraudulent Activities

Nonprofit organizations have more of a financial risk. They are easy targets for

fraudulent activities. Therefore, nonprofit organizations must take all possible preventative

measures to ensure financial safety. The flexible laws that govern nonprofit organizations call for

each organization to take their own precautions to prevent and stop embezzlement from

occurring. The Jitasa Nonprofit Blog suggests the following:

The person who requisitions the purchase of goods or services should not be the person

who approves the purchase. The person who approves the purchase of goods or services

should not be the person who reconciles the monthly financial reports.The person who

approves the purchase of goods or services should not be able to obtain custody of

checks. The person who maintains and reconciles the accounting records should not be

able to obtain custody of checks. The person who opens the mail and prepares a listing of

checks received should not be the person who makes the deposit. The person who opens

the mail and prepares a listing of checks received should not be the person who maintains
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the accounts receivable accounting records. (2014)

If every nonprofit organization took these steps to avoid fraudulent activities, fraud schemes for

nonprofits would be a lot less common and recognized early on. It is important to get feedback

from trustees after accepting a large amount of money (Blum, 2011). Another way to avoid

troubled gifts is to “adopt a solid and comprehensive policy for accepting gifts that require

criminal checks of donors for gifts of a certain size as well as other efforts to know more about

where a donation is coming from” ( Blum, 2011). In addition, employees should be required to

take vacation time regularly (Frazier, 2009). If employees are saying ‘no’ to taking vacations or

never leaving, they might be staying there to cover up a fraud scheme. The six main strategies

for fraud prevention include “knowing your employees, making employees aware/setting up a

reporting system, implementing internal controls, monitoring vacation balances, and living the

corporate culture”(CGMA, 2014). It is important to consistently observe and listen to your

employees. Getting to know your employees on a personal level will make them feel more

respected and valuable to the organization. If an employee feels valued by the organization, they

are less likely to commit fraud. Employees and everyone involved in the nonprofit organization

should also be aware of the consequences of such offenses. If they are informed on the severe

consequences of stealing money from the organization, they might be more convinced to follow

the policies and stay loyal to the organization. Even though all the employees may be

trustworthy, internal controls are necessary for every nonprofit organization. Internal controls

deter and detect fraud. Organizations should separate the power and make sure that employees

are checking over their co-workerś work. Each transaction and donation must be documented in

order to ensure protection from fraud schemes. In addition, jobs should be rotated to different
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employees. This way, they can recognize and look over the job done by the previous employee

and catch any unusual behavior or transactions. Hiring experts in the fraud feild can help

organizations better their internal controls. An environment where employees feel comfortable to

communicate and share their accomplishments is essential. Therefore, it is easier for people to

tell when someone is acting different or odd (CGMA, 2014).

Conclusion

Nonprofit organizations put much more trust into their employees than their ‘peers’

(Reifschlager, 2017). They run off of donations from outside donors and have tax exemptions

since they are run for the benefit of the community. Nonprofit organizations are much easier to

manipulate because the laws governing them are unclear and ill-defined. The five main types of

fraud schemes that frequently occur in nonprofit organizations, check tampering, billing, expense

reimbursement, corruption, and payroll, with the rapid advancement of technology, allow for

employees and donors to embezzle large amounts of money from organizations over long

periods of time (Bailey, 2017). In the United States, there are 1,424,918 tax-exempt

organizations (Neier, n.d.). Globally, nonprofit organizations lose $3.5 trillion (Neier, n.d.).

However, this issue is rarely highlighted on the news and other media outlets. Nonprofit

organizations are afraid to report the financial schemes occuring in their organization because

they don’t want to create a negative reputation for themselves. These organizations rely on

donations, so they hide fraud schemes to continue receiving money from outside donors. Most

fraudsters are college educated with no previous convictions. Therefore, it is even more difficult

to spot the crime before it is committed. Nonprofit organizations put a lot of trust into their

employees, often giving a few people almost all of the power and say in the financial decisions
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and transactions of the organization. This makes embezzling money highly accessible to the

employees of the nonprofit. Non only are nonprofit organizations susceptible to fraud, but it is

even harder for them to recover from these losses. They commonly have to pay back the money

that an outsider has stolen from their organization. Evidence and statistics show that nonprofit

fraud is a key issue in our world today. In order to resolve and alleviate this issue, the laws

governing nonprofit organizations need to be much more clear and concise. Nowadays, it is easy

to stretch the laws in place. Nonprofits can also take action to prevent fraud by applying internal

controls and checking the power of their employees. It would also be beneficial to our

community if it were more difficult to become a tax-exempt organization. Many organizations

take advantage of the tax-exempt status and violate fraud policies. If the current laws are

hindered to create clear and strict policies for nonprofit organizations, the amount of annual

fraud cases would decrease significantly.

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