Gospel for Asia’s Canadian Funds Given for Activities in India Don’t Show Up in Indian Reporting Documents

Canadian law requires charities to file information on their activities with the Canadian Revenue Agency. Gospel for Asia has a Canadian affiliate and that organization took in just over $17 million in 2013. The CRA requires charities to complete Form T3010 which captures disclosure of where and how donations are spent. In the case of Gospel for Asia, the T3010 shows that GFA’s Canadian affiliate sent $ 15,172,204 to India in 2013. The webpage showing this information is captured below:

GFA Canada to India
As I will demonstrate below, none of these funds show up in GFA India’s reports to the Indian government. In other words, if one just looked at what GFA in India reports to the India government, one would not know anyone in Canada donated $15 million Canadian dollars to the work of GFA in India.  

The activities to be carried out with those funds are listed in the T3010 form:

Ongoing programs:
Providing education to children of the Dalits and untouchables of India. Medical missions – treating the poor and needy in rural areas on the Indian subcontinent. Providing assistance in the slums. Literacy programs for illiterate adults. Disaster relief for natural disasters. Providing water for undeveloped communities. Sharing the love of God by meeting the basic needs for those below the poverty line. Sheltering street children.
According to Magali Deussing, Media Relations Advisor and Spokesperson for the Canadian Revenue Agency, Canadian charities, by law, “can only use its resources (for example, funds, staff, and property) in two ways, whether inside or outside Canada.” Those two ways are:
  • on its own activities (those which are directly under the charity’s control and supervision, and for which it can account for any resources used); and
  • on gifts to qualified donees.

Deussing added:

A registered Canadian charity is required to report annually to the Canada Revenue Agency (CRA) on its expenditures, and maintain adequate books and records so that the CRA can validate whether the charity’s funds are being appropriately applied to its own charitable activities (whether inside or outside Canada), or on gifts to other qualified donees. If a charity reports to the CRA that it has spent its resources on a certain program or activity, it is incumbent upon the charity to validate that expenditure or allocation of resources.

Form T301o lists “qualified donees” and Gospel for Asia International is not one of them.

Charitable funds may only be used if the activities are “directly under the charity’s control and supervision” and “can account for any resources used.” Canadian rules are specific about what control and supervision mean:

The CRA recommends adopting the following types of measures to direct and control the use of a charity’s resources:

  • Create a written agreement, and implement its terms and provisions.

  • Communicate a clear, complete, and detailed description of the activity to the intermediary.

  • Monitor and supervise the activity.

  • Provide clear, complete, and detailed instructions to the intermediary on an ongoing basis.

  • Arrange for the intermediary to keep the charity’s funds separate from its own, and to keep separate books and records.

  • Make periodic transfers of resources, based on demonstrated performance.

If a charity simply takes donations and funnels them to another organization, the Canadian charity might be considered a conduit — which is illegal in Canada. The CRA defines a conduit:

5.5 What is a conduit?

For this guidance, a conduit is a registered charity that receives donations from Canadians, issues tax-deductible receipts, and funnels money without direction or control to an organization to which a Canadian taxpayer could not make a gift and acquire tax relief.

One way that transferring money to an organization overseas does not of necessity create a conduit is if the money goes to a “head body” outside of Canada. In the case of GFA, the Indian operation mighr be considered a “head body.” The CRA website addresses this question:

Appendix C – What if a charity has a head body outside Canada?

Some charities are registered as the Canadian representatives or offshoots of a larger organization, often located outside Canada. These head bodies sometimes require payments from their Canadian charities, in the form of tithes, royalties, memberships, or similar transfers.

The same requirements for the direction and control of resources apply to charities that are offshoots of head bodies outside Canada. In other words, a charity may not simply send gifts of money to a non-qualified donee, even if that non-qualified donee is the charity’s head body.

However, having the head body act as an intermediary for a charity is also often not practical, since the nature of the relationship may prevent the charity from instructing its head body in how to use the money. In these cases, the charities must be sure they are receiving goods and services equivalent in value to the amounts they are sending.

For example, a head body might provide a Canadian charity with any of the following:

  • training
  • accounting services
  • literature for distribution
  • use of a name, trademark, or copyright material

The CRA will generally accept that a charity with a head body outside Canada usually benefits from access to useful resources from that head body such as policies, communications, and training material. If a charity transfers small amounts to a head body, and the charity has access to internationally produced material, we will not require additional evidence of benefits to the charity.

For these purposes, we will probably consider a small amount to be whichever amount is less—5% of the charity’s total expenditures in the year or $5,000.

I wonder what Canada is getting from GFA International that is worth $15 million. Note this line:

In other words, a charity may not simply send gifts of money to a non-qualified donee, even if that non-qualified donee is the charity’s head body.

Canadian Donations Don’t Show Up in Indian Reports
According to the Canadian report, GFA Canada sent the lion’s share of donations from Canadians to do work in India. However, in Indian public charity documents (yearly FC-6 forms), GFA Canada doesn’t show up.

On the website where Indian charities record their activities, Gospel for Asia is required to indicate the source country of donated funds. In the image below, source countries are reported for 2013-2014 (see pdf of page):
GFACountries20132014
GFA: Canadian Funds Are Combined with U.S. Funds in India
Canada does not show up. I checked the other three entities controlled by GFA (Believers’ Church (pdf), Last Hour Ministries (pdf), and Love India Ministries (pdf)) and found no reference to Canada as a source for those funds. I asked GFA COO David Carroll about the absence of Canada and he told me:

The Canadian funds were combined with U.S. funds by our auditor in India for various accounting reasons. There is no requirement that they be reported separately.

I wrote back to ask for the auditor’s rationale and Carroll declined to address the question.

According to Canadian law, Canadian charities must retain control of the funds, must keep separate books and records, and must be able to show that the funds were spent on the charity’s mission. Perhaps GFA in Canada can do that. However, on the Indian side, there is no way to verify it.

What seems odd about Carroll’s explanation is that the Indian website requires the donors of those funds to be identified. For instance, in 2013-2014, the following donors were identified by GFA.
GFADonorSourcesIndia20132014
Note that there are donor GFA organizations from Germany, Australia, New Zealand and the USA. Canadian law requires that the funds donated in Canada be spent for the charitable purpose intended by donors. This report in India seems tailor made to comply with that mandate. However, in the part of the form where GFA could account for where Canadian donations were spent, they fail to identify the activities paid for by those funds.

According to COO David Carroll, the $15 million Canadian dollars were lumped in with the United States for accounting reasons. However, no recognition of the funds as having come from Canada shows up. All of the groups listed there are GFA affiliate organizations (e.g., Road to Peace, Grace in Action are LLCs controlled by GFA) so it seems odd that GFA of Canada doesn’t show up. Given the Canadian guidelines, it seems as though the funds coming from Canada should be identified for the very reason David Carroll says they weren’t: “for various accounting reasons.”

The Numbers Don’t Add Up
Note: the figures are in Indian Rupees. As I have pointed out before, the funds the U. S. GFA says they sent to India don’t show up on the Indian reports. The situation is worse if we take into account David Carroll’s claim that the Canadian funds are lumped in with U.S. funds in India. If Canada sent just over $15 million Canadian dollars ($14,183,700 in U.S. dollars on December 31, 2013) to India for calendar year 2013, and the U.S. sent $58,542,900 (from their 2013 U.S. audited financial statement) that adds up to $72,726,600 sent to India from the two countries. However, according to reports of foreign contributions in India, the U.S. GFA is only credited with sending $6 million during 2013. If one adds up all of the funds sent by GFA – US to Indian organizations in FY 2013 (GFA -India, Believers’ Church, Love India Ministries, Last Hour Ministries), we still only get to $37,097,750. The bottom line is that there is a massive difference in what the U.S. and Canada report that they send and what the Indian GFA organizations report to the Indian government. 

It is possible that the excess is sitting in an account somewhere and is being reported in some other manner in a way that is not publicly available. I freely admit I am not an accountant and that I don’t know all of the auditing rules which may apply. However, these reports are provided in the U.S., Canada, and India so that an informed person can evaluate whether or not a charity is being accountable with donated funds. Using the reports available, I believe GFA has many questions to address. Where is the money that doesn’t show up on the Indian reports? GFA’s silence does not inspire confidence.

*I used the exchange rate from March 31, 2014.

Documentation of Former Gospel for Asia Staff Concerns is Now Public

GFADIaspora LogoIn a prior post, I disclosed that a dispute existed between a group of over 80 former Gospel for Asia staff and the GFA leadership. GFA former staff claims that GFA leaders engage in unbiblical practices. In response, GFA leaders claim that a board member’s investigation failed to find serious problems. Currently, an impasse exists.
Until recently, most of the documentation of these concerns was unavailable to the public because the main website of the former staff group (called the GFA Diaspora) was on a password protected website. That has changed. The website — GFA Diaspora — is now available to the public.
On the website, you can find rationale for the five major problems observed by the former GFA staff, a communications history regarding efforts to bring GFA leaders into reconciliation talks, a review of specific evidence including the K.P. Yohannan ring kissing video, and numerous personal testimonies of former staff which support their overall list of concerns.
I was initially leaked materials from this website by former donors to GFA who believed the efforts of the staff to effect dialogue and change were not being taken seriously by GFA leaders. Since the first post, I have provided several other reports of information about GFA which I believe deserve greater awareness among evangelical supporters of missions. GFA has now ceased all responses to my questions and have failed to answer questions from one other new source — Christian Today.
Perhaps open access to this material will bring matters such undeclared cash carrying, misrepresentation of ecclesiastical practices, massive cash reserves, and other concerns into greater public conversation.

Gospel for Asia Reveals Financial Information on Evangelical Council for Financial Accountability Page

In a major departure from past practice, Gospel for Asia changed their ECFA page to include their U.S. financial information. Citing security concerns, GFA has declined to reveal this information on the web, but instead required interested parties to request it by mail. Up until now, the ECFA has allowed charter member GFA to be exempt from usual practice.
ECFA page old
Now the page looks like this:
ECFA page new
 
In a prior post, I noted that GFA sent $58 million to India but the FC-6 forms there show only a little over $6 million received from the U.S. Perhaps, GFA is moving toward more transparency. If so, the organization still has a long way to go to explain this discrepancy, as well as the money exporting to India, and discrepancies in the Bridge of Hope program reporting. Clearly, the organization is raising massive amounts of cash but has yet to explain why so much is sitting in Indian banks.
Given this change, perhaps the ECFA has been in talks with GFA and is privately working to bring GFA into compliance with ECFA guidelines. If this is true, don’t expect ECFA to alert the donating public. If the ECFA and GFA don’t see things the same way, my guess is that GFA will quietly give up their membership with no explanation.

How Hard is it for Gospel for Asia to Get Money to the Field?

CashIn a staff meeting on May 14, COO of Gospel for Asia David Carroll said it was getting hard to send money into India.

We’re always looking for ways to get money into India because the reality is that it’s getting more difficult to do that, and we are looking for other ways that we’re able to do that.

Given other information provided by GFA, this is a confusing statement.
On GFA’s frequently asked questions page, GFA addresses financial integrity and tells donors that everything is ethical. On that page, GFA promises financial accountability:
GFAfinancial
 
The sentence underlined in red says: “Some of those systems include transferring funds only through approved banking channels.” Carrying cash in backpacks is not an approved banking channel. As I have reported, money smurfing is a violation of both federal law and this website promise to donors. So hard or easy, moving money is only supposed to be done through banks.
I have to also question if it is difficult to get money into India via legitimate means. According to the audited financial statement for 2012 and 2013, GFA started creating limited liability companies in 2009 to aid transfers of money to India. They now report 12 of them.
A quick review of the Indian FC-6 forms (e.g., GFA’s 2013-2014 FC-6) shows that GFA transfers money frequently. In fact, GFA decided to transfer $9 million to India just to get better interest rates. Apparently, any difficulty was worth it. See the relevant section of the financial statement in the image below:
GFA LLC AFS
 
GFA took $9 million which they needed for their new home office and transferred to that money to India for about a year to get better interest rates. Then they transferred it back. GFA was willing to place $9 million at risk; so how hard could it be to move money back and forth?
GFA has admitted money smurfing but to my knowledge, there has been no explanation to staff about why the students and money was put at risk. I am aware that staff are very concerned about it as they should be.
I encourage anyone who was asked by GFA to move cash on a trip to India (or elsewhere) to contact me at my email address (click the link). If you have questions about the matter, please feel free to contact me.

Gospel for Asia Reports One Thing in American Audit, Another in Indian Reports

In addition to the usual income and expenses data, Gospel for Asia’s audited financial statement discloses related party transactions. As you can see from the image below, the direction of the transaction is from the U.S. to GFA affiliates in Asian countries with 96% going to India. In addition to GFA India, GFA in the U.S. claims contributions to GFA affiliates in Myanmar, Sr Lanka, Bangladesh and Nepal. See below:
GFA Related Party Transactions 2013GFA reports contributions to five related non-profits. However, in the Indian FC-6 report, three other charities — Believers’ Church, Love India Ministries, and Last Hour Ministries — report receiving contributions from GFA in America. In the audited financial statement above, GFA reports to Americans that the organization gave $58,542,900 to GFA India in calendar year 2013. However, in the FC-6 form filed to the Indian government, GFA – India reported that much less than $58 million was received. Just from the U.S., GFA – India reported that they received INR 404,638,271 which converts to $9,170,270 million USD during the period between April 1, 2013 and March 31, 2014 (see line 5 below).*
GFA FC6 Countries
GFA said in the audited financial statement over $58 million was sent to GFA India, but GFA in India reported only a little over $9 million being received (actually more like $6 million, see the last note below).**** So where is the rest of the money?
As I reported in a prior post, GFA in America also sent money to at least three other charities in India: Believers’ Church (INR 909,041,794 = $20,601,500), Love India Ministries (INR 162173900 = $3,675,330) and Last Hour Ministries (INR 161084820 = $3,650,650) (click the links for their FC-6 forms).  Looking at what came from the United States to all four of these entities, the total is $37,097,750 which still does not get us to the $58 million GFA claims came from the U.S.** It is possible that GFA – U.S. contributes to other ministries in India that have not been disclosed or discovered yet. However, just taking these reports at face value (what GFA says in the audited statement and what GFA tells the Indian government, there appears to be a significant discrepancy.
It is worth asking what Love India Ministries and Last Hour Ministries do. I can’t find a viable web presence for either entity and as far as I can determine, GFA does not mention them in their materials. They may be shell companies operating in name only, much like the 12 limited liability corporations in Texas mentioned in the audited financial statement which exist just to transfer money to the field.***
Thus, at least two problems emerge for GFA’s credibility. One, GFA claimed in the audited financial statement that it only contributed to “five related non-profit organizations.” However, GFA in the U.S. uses 12 LLCs to send money to at least three additional registered charities in India (Believers’ Church, Love India Ministries and Last Hour Ministries) which are not disclosed in the audited financial statement. Two, the amounts GFA says they send to GFA in India comes nowhere close to matching what GFA – India reports to the Indian government.
Thus far, GFA has remained silent in the face of questions regarding cash smurfing to India, video of Believers’ Church bishops bowing and kissing the ring of GFA president K.P. Yohannan in contradiction to Yohannan’s denials of the ritual, discrepancies in Bridge of Hope giving requests and spending, and cash hoarding in Indian bank accounts. These discrepancies being reported today now call into question the accuracy of the American audited financial statement. Silence may be a good PR strategy but it seems ill-suited for a Christian ministry.
 
*It seems very unlikely that the different reporting years explains the $ million difference. Both methods of accounting cover 12 month periods which report consistent monthly giving totals year over year.
**Contributions to GFA-India, Believers’ Church, Love India Ministries and Last Hour Ministries from all foreign sources (including interest on foreign contributions) totaled $54, 550,683 for fiscal year ending March 31, 2014, still less than the $58 million to India reported on the audited financial statement.
***As an aside, it is worth asking again why sending cash to India in student backpacks was ever done. GFA told students it is a way to get cash into India. As one can see from the financial statement, GFA set up 12 LLCs to transfer money, and even transferred $9 million at one point just to get better interest payments. There appears to be no problem getting money back and forth from India. 
****I remembered after doing the post that India’s FC-6 forms require a charity to record when the contributions are received. Thus, I was able to discern the amount sent during the calendar year 2013 but looking at the reports for the fiscal years 2012-2013 and 2013-2014. The situation is actually worse than I first reported. GFA – India reported that they received only $6 million in calendar year 2013. The American audit says GFA U.S. sent $58 million to GFA India in the calendar year but GFA India only reported $6 million in the same time span.

According to U.S. Customs and Border Protection, Smurfing – Dividing Cash Transfers Over $10k to Avoid Detection – Violates U.S. Law

CashOn May 14, I wrote that several Gospel for Asia staff and students had reported to me that they were asked to carry envelopes of cash to India without declaring that cash to U.S. customs. I then reported audio of Gospel of Asia leaders telling staff and School of Discipleship students in a May 14 staff meeting that GFA leaders planned to discontinue the practice of having groups of students take large sums of cash to India in their pack backs or suitcases on group trips. In that staff meeting, a student raised the issue with a question about why GFA leaders required each student on a mission trip to carry an envelope of $4500 cash to India. Amounts ranging from $45,000 to $135,00o (possibly more, I have not interviewed individuals from groups larger than 30) have allegedly been taken to India in this manner. GFA gave no specific reason for asking students to do this, but said their Texas auditor Bland Garvey approved the plan.
However, any cash transfer over $10,000 must be declared via a customs form when leaving the U.S. None of my sources filed any forms on their trips. In addition, GFA on the organization website denies using such means to carry funds to the field, saying (see the underlined sentence):
GFAfinancial
Obviously and by their own admission, GFA leaders did not follow this guideline.
Wanting to understand more about the law relating to cash transfers out of the country, I contacted by phone and email the media relations department of the Customs and Border Protection agency within the Department of Homeland Security.  To the CBP media office, I posed the exact scenario just as the GFA students explained it to me. In response, a CBP spokesperson wrote in an email to describe the relevant U.S. law:

If an individual transports, attempts to transport, or causes to be transported (including by mail or other means) currency or other monetary instruments in an aggregate amount exceeding $10,000 (or its foreign equivalent) at one time from the United States to any foreign place, or into the United States from any foreign place, they must file a report with U.S. Customs and Border Protection (CBP).
This requirement is cited in 31 USC 5316; 31 C.F.R. 103.23 and the Bank Secrecy Act (BSA) of 1970, which identifies the source, volume, and movement of currency and monetary instruments being transported into or out of the United States or being deposited in financial institutions.  The BSA aids law enforcement officials in the detection and investigation of criminal, tax, and regulatory violations.
CBP widely publicizes the currency reporting requirements on its website and through other means in order for travelers to be aware of the requirement to file a FinCen Form 105, Report of International Transportation of Currency or Monetary Instruments (CMIR).  If unreported currency or monetary instruments are discovered on a person or in his carry-on luggage while boarding a departing aircraft this would constitute a CMIR violation.
Dividing currency amongst travelers requires the filing of a CMIR for the entire amount as intentionally aggregating currency exceeding $10,000 to evade reporting is against the law.
As a result of international drug trafficking, the United States and much of the world strengthened currency reporting requirements by enacting laws to counter money laundering schemes such as “Smurfing”.  Smurfing is a form of structuring, or dividing large amounts of currency or monetary instruments between individuals within an organization, with each person or package carrying an amount under $10,000 to circumvent reporting requirements.  Structuring, including “smurfing”, is a violation of 31 USC 5324. (emphasis added)

I then asked the public affairs office at Immigration and Customs Enforcement how their office handles such crimes. A spokesperson told me that no information could be given about current investigations, but persons who wish to pass along information can use the ICE tip linehttp://www.ice.gov/tipline.
I also request that former/current staff, students or others who carried cash for GFA contact me via email (click the link).
 

How Much Does it Really Cost to Sponsor a Child with Gospel for Asia?

Yesterday, I pointed out that the expenditure of foreign funds by GFA in the fiscal year ending on March 31, 2014 for the support of children enrolled in the Bridge of Hope program seemed quite low, estimated at around $105 per year. Today, I want to point out that GFA’s request for child sponsorship in India is about one-third of what it is here in the U.S. and that the actual costs are even lower than that.
On the U.S. website, GFA requests $35/month to sponsor a child:

It only takes $35 a month to give a child everything they need—school supplies, a daily meal, medical checkups and more—to attend a Bridge of Hope Center. 100% of your sponsorship is sent to the field to support your child.

However, on the GFA/Believers’ Church Indian website, the cost is INR 800/month or about $12.50 in U.S. dollars per month. That’s quite a discount. The sponsorship page promises:

Your sponsorship of Rs. 800 per month provides [child’s name]:

  • An Education
  • A nutritious meal each day
  • A yearly medical checkup
  • Basic school & hygiene needs

I have also seen GFA budget documents which tell a more surprising story.* The actual cost during fiscal year ending 2014 to support one child in a GFA Bridge of Hope center in India was just under INR 500 or around $8.20 per month per child. This paid for the administration of the program, food purchases, and all child services. In fact, the actual items given to each child (school supplies, clothes, hygiene supplies and gifts) only cost INR 140 per child or $2.20 per month.
At that rate, Americans who send $35/month to GFA for a child sponsorship could actually support 4 children. Or GFA could keep the excess in a bank and draw interest on the balance as they appear to be doing. As I noted yesterday, GFA spent over $6 million in foreign contributions on Bridge of Hope expenses in FYE 2014 but had in the neighborhood of $25 million designated for “the welfare of children” sitting in a bank drawing interest at the same time.
GFA has to report that interest (the banks do as well) and all four GFA controlled organizations accumulated $4.2 million on the money in savings accounts by the end of FY 2014.
GFA says “100% of your sponsorship is sent to the field to support your child.” Perhaps this statement should be reworded. The money is sent to the field but a lot of it apparently ends up in a bank on the field.
It is past time for GFA to end the silence and address this matter as well as others which have come out in recent weeks.
 
*I have the documents but don’t have permission to publish them.

Gospel for Asia Appears to be Saving for a Very Rainy Day

In a recent staff meeting (May 14, 2015), Gospel for Asia leaders told staff that they had $7 million in cash balance in India. Responding to a question from a staffer about why GFA is sitting on so much cash in India, COO David Carroll answered:

That account will tend to build up over the year, it will ebb and it will flow and it will go down as money is spent. Currently, is there 94 million dollars in there or someone asked is there $150 million dollar fund on the field? No, currently the balances from what I understand from India are around 7 million dollars in that particular, those particular accounts. The reason that they are there is because we have to report all foreign contributions that come in. Money will swell and as we spend the money the money will go. We cannot spend the money until we can spend it on the project for which it was designated.

This puzzled me because it seems to contradict the financial contribution reports filed with the Indian government every year. Something isn’t adding up when one compares Carroll’s information to what is filed with the Indian government.  According to the most recent report showing GFA’s use of foreign contributions for the Indian fiscal year ending March 31, 2014, GFA alone had $54,929,800 listed as a cash balance. If you include the other entities that receive money from U.S. based GFA controlled limited liability corporations, the balance swells to $158,165,400.*

GFA and Believers’ Church both receive money from several LLCs with Texas addresses (e.g., see this list). Two other groups do as well: Last Hour Ministry, and Love India Ministry. The image below shows the cash balances for each of those organizations in India. These numbers do not include U.S. operations, which are likewise substantial.
FYE2014CashBalancesGFA
Carroll is correct that funds designated for a particular purpose cannot be used for another purpose and so if GFA receives a lot of money for something that is not needed on the field, then they have to wait until they need it to spend it. The report filed with the Indian government provides a reasonable amount of detail about where funds have been and are designated to be spent (see the entire report here). See below:
gfa2014FYEbalance
Note the red boxes on the right side of this chart. The cash balance GFA reported to the Indian government was (in rupees) 3,288,264,488.79. Using the exchange rate on  March 31, 2014, this converts to $54, 929,800. Similar calculations led to the image above showing over $150 million. Also note that the previous balance was (in rupees) 2,984251885.50. At the March 31, 2013 exchange rate, that converts to $54,601,600 as a cash balance in 2013.

Donors might have a lot of questions after reviewing this information. For instance, what is a Corpus Fund, and why was $21,512,100 sitting in it as of March 31, 2014? It doesn’t appear that any foreign funds were spent on welfare of widows and orphans. There may be perfectly good explanations for all of the questions raised by these reports. However, given GFA’s promises, the massive amounts of money involved, and the other issues identified of late, there is no reason the public and staff shouldn’t ask.

To explore these reports, go to the foreign contributions portal, and then click on the years of interest. All data are not available for 2014-2015 as yet, so click 2013-2014 for the most recent data. Then also click on “Kerala” for the state and hit submit. There you will see all of the charities operating in Kerala. Find Gospel for Asia, Believers’ Church, Love India Ministry, and Last Hour Ministry. Historical exchange rates can be found here.

*I am using exchange rates from March 31, 2014.

Gospel for Asia Tells Staff Carrying Cash to India is Legal But They Won't Do it Anymore

Cash
Image courtesy of sheelamohan at FreeDigitalPhotos.net

Last week, I reported the testimony of several former Gospel for Asia students and staffers who told me that GFA asked them to carry envelopes of cash into India.Some groups may have carried as much as $135,000 in cash to India via individual envelopes of cash packed in luggage or backpacks. According to U.S. law, more than $10,000 leaving or entering the country must be declared and cannot be split up among co-travelers to evade declaration. No source I spoke with filled out any customs forms to declare the cash as required by law.
I asked GFA COO David Carroll for comment or explanation before that article was published with no response. I have reached out again this week but have not heard back.
In the mean time, I was given audio of a staff meeting which took place last week after my article was published where GFA leaders Carroll, KP Yohannan, and Danny Yohannan answered a staff question about the practice of various GFA travelers carrying money to India. In the meeting, the leaders acknowledged that students, pastors and staff had carried cash to India. Even though staff have complained for months, the staff were just informed last week that GFA leaders have decided to discontinue it. Listen to the segment in response to a question from a female staffer:
(Author’s note: During the week of November 13, 2015, GFA, through attorneys, demanded the removal of the audio from this post. Even though the use of the audio is in keeping with fair use of the material, I decided to post a link to the audio rather than embed it.)
Listen to the segment of the May 14, 2015 staff meeting (click the link)
Transcript:

Female staffer: Ok, so the money regarding the students taken over to India, you know we have to carry the money over. How is that audited? Because if I lost my backpack, all that money would have been lost, and that’s money from sponsors and donors. So why is that put in place, and if it was lost, how would you track that?
David Carroll: That’s a good question and actually that was going to be one of the next questions that we answered because someone wrote a very emotional question about that and said why we were endangering students by having them carry the money to India, and I just want to say that for whoever asked the question that I’m sorry we’ve given you, truly sorry that we’ve given you the impression that we were endangering students. A couples things you should know we would never endanger students or anyone else, we’ve had pastors carry money, we’ve had staff carry money, we’re always looking for ways to get money into India because the reality is that it’s getting more difficult to do that, and we are looking for other ways that we’re able to do that. But we checked with our auditors before we ever would allow such a practice. We actually called Bland Garvey, they’re our audit firm and said this is what we’re planning to do, this is what we are intending to do, and they told us how we get it receipted they said it’s completely legal, you’re under all limits, you need to get receipts, there need to be receipts here, there need to be receipts there which Lori has receipts from here. The Indian side also account for that money as received. If you were to lose it, they couldn’t receive it, and in that case, we would say it’s lost basically. We would have to tell the auditors we gave it and it didn’t get to the other side and I’m sure they wouldn’t be very happy, but is it receipted on the other side as received, and accounted for? Yes, it is on the other side of the pond.
So, we have stopped that practice, we feel that it put more emotional burden on people than we realized and then we wanted to and so…
KP Yohannan: It is a perception problem also. Like when I go to Burma and Nepal, I carry quite a lot of travelers checks and get into the country and cash it into local currency and I give it and then the border department, they account for that money in the local Burmese currency or wherever I’ve been to so (?). It’s a legal thing, you cannot carry any more than $5000 and not declare it but when you get India, Nepal, Burma, you can cash it, you can burn it, you can eat it, you can throw it away, you can give it, it is a local currency you are giving it and so receipts are accounted in the book are reported to the government (?) and that is an absolute thing because what I am trying to say, it’s not trying to be under the radar, or illegal smuggling money into the country, nothing like that.  
Carroll: We had heard that one explanation you were given was that the tax rate is high, which would indicate that we’re trying to avoid tax on the money and that’s not the case. I’m sorry if that got skewed but that’s not the case. It’s actually reported on the other side legally so we can do everything we’re supposed to do in reporting that money to the Indian government.
Yohannan: But we don’t do that anymore.
Carroll: We’ve stopped the practice.
Danny Yohannan: We are always looking for legal ways to bring resources into the ministry, but also over there we’re trying to be as responsible to even raise funds on that side…

Shorter GFA: We did nothing wrong and we won’t do it again.
Several questions come to mind. If GFA is not trying to be “under the radar” then why are students given $4500 each? In India, customs would need to be informed in individuals bring in $5000 or more. Clearly, more than $5000 at a time was sent from Texas to India (the smallest group I have heard about so far is 10 people = $45,000; largest was 30 – $135,000). Thus, structuring the transfer among the students to avoid informing the Indian officials seems to be flying under the radar. Furthermore, on the U.S. side, the law requires aggregate amounts more than $10,000 to be declared. If there is no desire to hide the full amount being sent from Texas to India, then why give each member of the group $4500? Why give cash to students, ministry partners and pastors at all? Why not have the GFA staffer in charge simply declare the entire amount when leaving the U.S. and when arriving in India?
It is hard to understand the reason that GFA needs to get money to India. GFA sends millions to India through established channels. It seems hard to understand why donor funds have been risked in this manner.
None of my sources recall getting receipts in India.
A new source told me that a group of between 20-30 people traveled to India in April, each carrying $4500. If GFA has discontinued the practice, it happened just recently. At this point, very little of the explanation given by GFA can be verified. Emails to Bland Garvey and David Carroll have gone unanswered. However, it is now clear that GFA has been moving large amounts of cash from Texas to India via students, staff and pastors.
 

Gospel for Asia Faces Allegations of Misconduct; GFA Board Investigation Found No Wrongdoing (UPDATED)

GFA LOGOGospel for Asia is a large missionary organization which supports direct evangelism, child sponsorships, Bible colleges, education, disaster relief and several other ministries. Their assets are substantial but, at their request, I am not going to address how much money they take in.* The 990s are not available on Guidestar and so it is very difficult to find out specific information about the financial situation.

GFA describes itself as a missionary organization and a church. What GFA calls The Believer’s Church is based in Wills Point, TX and apparently consists of the various churches planted around the world. According to the church website, the church has “over 2.4 million members scattered throughout 14 nations.”

According to the organization website, GFA was founded by K.P. Yohannan. Yohannan is the head of GFA and The Believers’ Church and uses the title Metropolitan Bishop of Believers’ Church.

Dr. K.P. Yohannan, the Metropolitan Bishop of Believers Church, was born and brought up in Niranam, Kerala. Niranam has immense historical significance in the tradition of Saint Thomas, a disciple of Jesus Christ who planted the first church there in AD 52.

In June of 2014, a group of 30 former employees sent a letter to Gospel for Asia with five allegations. The full letter is linked here. According to the former staff group, GFA replied with a defensive and, to my eye, threatening letter. In September 2014, a follow up letter was sent, this time with nearly 80 signatures. GFA responded again on March 26, 2015 with results of an investigation. In short, they considered the matter closed.

In summary, the five basic allegations are below.
1. GFA leadership practices and teaches a false view of spiritual authority.

2. GFA leadership prioritizes ministry over family, and teaches the same.

3. GFA leaders lie or intentionally deceive people in order to “protect” the ministry.

4. GFA practices unbiblical shunning.

5. GFA prohibits or discourages staff involvement in bible studies, small groups and local churches.

My purpose with this post is simply to report that there has been an ongoing effort by nearly 80 former employees to communicate these charges to Gospel for Asia since June 2014. According to GFA, an investigation found no wrongdoing but this response from GFA has not been sufficient for the former staffers.

I was alerted to this matter by a former donor earlier this month. Since then, two more donors have contacted me with similar concerns.

Apparently, during April, some GFA leaders have contacted individuals in the former GFA staff group (GFA Diaspora) with offers to talk about personal matters. J.D., the Diaspora’s spokesperson, said that no apology has come officially from GFA. According to the spokesperson, a more systematic response from GFA is needed to fully address the problems. Even so, the former employees do not wish to harm GFA. Speaking for the entire group, J.D. said:

It is not our intention to harm GFA or its staff in any way. From the beginning, our hope in addressing these matters has been to see repentance and change.

In response to my inquiry, GFA Chief Operating Officer, David Carroll, sent the following statement.

Gospel for Asia was disheartened to receive a letter dated June 17, 2014 from a group of former employees expressing concerns with our leadership team. We value the well-being of our staff and don’t take criticism lightly. After unsuccessfully trying to seek biblical reconciliation with every signer of the letter, our board launched a formal inquiry into the complaints outlined by the former employees. Gospel for Asia President and Board Chair K. P. Yohannan and his family members, also members of the board, recused themselves from participating in the investigation to ensure a fair and unbiased process. At the same time, our leadership team examined our HR policies and procedures, making improvements wherever possible, and affirmed the freedoms afforded to those called to the work of Gospel for Asia. While the board investigation concluded that there was no wrongdoing on the part of leadership, we recognize that, as humans, our leadership is not always going to be perfect. At the same time, our motivation has always been to reach as many people as possible in Asia with the Gospel of Jesus Christ and grow in our ability to reflect the character of Christ in our own organization. Regarding those former employees with unresolved concerns, it is our ministry’s desire to reconcile when possible and disagree in love when necessary, so that we might stand together in our commitment to spreading the Gospel throughout Asia.
— Gospel for Asia COO David Carroll, on behalf of the leadership team

As is clear from the letter, some of the concerns expressed over the past 10 months relate to GFA’s accountability to donors. In the coming days, I will report more information regarding transparency and the concerns of donors.

*Gospel for Asia is a charter member of the Evangelical Council for Financial Accountability. On the ECFA GFA page, this caption tells why the financial information isn’t available:

Due to international security concerns, Gospel for Asia has requested that their financial information not be posted on the Internet. To receive a copy of their audited financial statements, please contact Gospel for Asia directly.

I did contact GFA directly and received a copy of an audited financial statement.

UPDATE: In 2015, former board member Gayle Erwin allowed me to publish his unedited report of his investigation of Diaspora’s concerns. His report contradicts the statement from GFA.