Kerala-based evangelist and self-consecrated archbishop Dr K P Yohannan has hit the headlines yet again, as the state government has recently issued orders to take over three estates his church body owns illegally. According to the government of India website, Gospel for Asia (GFA) – a Texas based charitable organisation – is funding ‘Believers Church’ for the purpose of charity to improve the condition of orphan children. Interestingly, both GFA and Believers Church are headed by Yohannan. The funds sent by GFA were used to purchase these estates instead of putting it to use for charity purposes.
I have been curious about perception in India regarding GFA’s purchase of land for commercial purposes. The writer of this article takes the position that the foreign contributions were used to buy commercial properties rather than for the intended purpose. This is a serious charge and one which GFA should address.
However, it has been learnt that Yohannan and his trust had spent Rs 300 crores on the plantation property. With the government now taking over the land, BC will in all probability face losses on their investments in these estates. Moreover, BC would possibly be ineligible for any compensation as Harrison Malayalam sold the property to BC when the former had no right to sell the property. After the purchase, however, the property was mutated in the name of the Believers’ Church and tax was being paid by the BC itself under the Plantation Tax Act.
Instead of $14.3 million, as I reported earlier, this article claims the price was much higher — $68.5 million. However, no source was given for the information which makes it impossible to verify.
An implication of this report is that a massive amount of donor funds may be lost due to the purchase of this property. Although GFA in India may have believed it had the better legal case, it is a legitimate question whether or not donor money should have been risked in this manner.
GFA has remained silent about a number of concerns recently raised by donors, former staff and students. Prominent among them is the report by former students that they were told to carry cash in backpacks and suitcases to India, seemingly at odds with American and possibly Indian law.
On 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):
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 line: http://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).
Although not your usual ministry tool, in 2005 Believers’ Church (which is synonymous with Gospel for Asia in India) acquired a working rubber plantation called Cheruvally Estate. The 2263 acre estate was purported to be a money making venture to help make Believers’ Church self-sufficient and according to reports in the Indian press cost just over $14.3 million.
Today, the Indian government is poised to take control of three properties once belonging to Harrison Malayalam, India’s largest producer of rubber. One of those properties is the Cheruvally Estate. It is not clear what if any compensation Gospel for Asia will receive. The government claims that Harriason Malayalam never had the right to sell the land in the first place.
The property has been in dispute since it was first acquired.
Although not normally of interest to me, I took a look at the hush money charges against former Speaker Dennis Hastert because of the additional wrinkle that he structured his bank withdrawals to avoid federal requirements to report those actions.
Such structuring is illegal whether one is an misguided creation science proponent, as in the case of Kent Hovind, or a mission organization moving over $10,000 out of the country without declaring it at customs, as former and current students and staff at Gospel for Asia have alleged.
I have learned a new term for using multiple people to move money to evade declaration – “smurfing.” Papa smurf arranges for all the little smurfs to carry the load, in the case of GFA envelopes of cash in their backpacks or suitcases, until they arrive at their destination.
Watch for more on this…
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]:
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 otherswhich have come out in recent weeks.
*I have the documents but don’t have permission to publish them.
Each year registered charities in India are required by law to disclose how they spend foreign contributions. Out of curiosity, I examined Gospel for Asia’s FC-6 report for the fiscal year that ended on March 31, 2014 (most recent data available). Below is a chart that combines the money spent from contributions from GFA (U.S., Germany, Australia, New Zealand, etc.) in U.S. dollars to GFA-India, Believers’ Church, Love India Ministries and Last Hour Ministries.* GFA also sends funds to affiliates in Nepal, Myanmar, Sri Lanka, and Bangladesh. According to GFA’s financial statement ending in 2013, India receives 96% of the contributions from the U.S.
The largest expense is construction and administration of Believers’ Church Medical College Hospital. According the hospital website, “Believers Church Medical College Hospital is a healthcare project of Believers Church. The Church is dynamically involved in various nation-building social and educational projects, healthcare initiatives, charitable activities, community development programs, rehabilitation projects and relief works. Dr. K.P. Yohannan, Metropolitan of Believers Church is the patron of the hospital and Dr. George Chandy is leading the project.”
About $1.9 million for the BCMCH came from GFA affiliates in Germany, Australia, and the UK, with the rest coming from GFA in the U.S.
If one includes the hospital, two-thirds of the funds — just over $35 million — are spent on support for ministries of Believers’ Church in India. At least one pastor recently announced that he gave up his support for GFA because he learned that he was really supporting a church he didn’t feel comfortable supporting.
A prominent expense is for welfare of children which includes school fees, food, and funding for the Bridge of Hope program. According to GFA’s most recent financial statement, they claim that 60,000 children are enrolled in the BoH program.
That works out to only $105 per child per year.
According to the forms filed with the Indian government, there is a combined balance of just over $23.5 million designated for “welfare of children” sitting in GFA-related accounts. I cannot understand why so much money is sitting in accounts when GFA claims the need is so great (and I have no reason to doubt that the need is great).
GFA promises that “Gospel for Asia sends 100 percent of the money you donate for work on the mission field to the field. Nothing is taken out for administrative expenses.” While that may be true for those working in administration in the U.S., it is not true for GFA, Believers’ Church, Love India Ministries, and Last Hour Ministries.
As I noted in a prior post, GFA has stopped replying to my questions. However, I extend an ongoing invitation to correct anything I write which they believe to be incorrect. There is a link in the footnote below if readers want to check these figures, and I am open to any additional evidence.
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.
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:
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 issuesidentified 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.
In one of my early communications with Gospel for Asia’s COO David Carroll I asked:
Can you confirm that the reason GFA organizes as an episcopal type church is related to Indian law. I have been told that Indian law requires GFA to register as a church and assume a governance structure similar to the officially recognized Catholic Church and the United Church of India. That means an episcopal structure (with bishops, etc.) is required. Thus KP Yohannan is officially the Metropolitan (archbishop) of the Believers Church. Is this why allegiance to KP Yohannan and kissing his ring is involved?
In regard to Gospel for Asia’s structure, while we are thoroughly evangelical, our organization and church structure is specific and unique to the areas where we work most heavily. Additionally, K.P. Yohannan’s title is understood in the countries where we work to refer to the senior leader of the organization. In regard to your question about kissing K.P.’s ring, I haven’t seen it, nor am I aware, that it has ever happened.
On ring kissing, David Carroll needs to see this video: [youtube]https://youtu.be/rfHoh6xMEkM[/youtube]
The man seated is K.P. Yohannan and the men coming forward are being ordained into the Believers’ Church. They very clearly are kissing Yohannan’s hand, and at times, it seems clear that they are kissing his ring.
The allegations that GFA and Believers’ Church have evolved from an evangelical ministry to a self-contained episcopal type denomination have dogged GFA for about a decade. This video was taken at an ordination service. According to my source, the service took place in 2009 in India at one of the Believers’ Church seminaries.
One former leader in India told me that the pastors were taught several years ago to kiss Yohannan’s ring, which has the Believers’ Church emblem on it. However, many felt awkward with practice and the leaders revised the ritual to include bowing low before Yohannan before he touched a person’s forehead with his signet ring. In any case, these rituals seem to place significant emphasis on allegiance to the Metropolitan.
As recently as April of this year, Yohannan denied remembering it. In a staff meeting, in response to a question about it, Yohannan said:
Did anybody ever kiss my hand or my ring? In memory I cannot ever recall I allowed it to happen or if they did it. Because we never teach it. We never promote it. That is not our doctrine, I am not a god, anything, but if people who talk about it and say this, they saw it, what can I do.
What have I done to you or to anyone here to promote me? When I took the ring on my hand, as God Almighty my witness, I was going to a death chamber. I never asked anyone to kiss my ring, I never allowed it to happen. We never teach it, we never promote it.
The audio is hard to make out but the first quote above is first on the audio followed by the second quote.
Of course, none of this means that Gospel for Asia is ineffective in ministry to the poor or in service to others. However, the practice of structuring cash transfers to India in ways which evade detection by customs officials and now the double talk on their ecclesiastical practices raises many questions about the organization’s other claims. GFA has asked for and received a significant exception to financial reporting requirements from the Evangelical Council for Financial Accountability. Prominent pastors like Francis Chan claim that GFA’s practices are clean. However, perhaps GFA should respond to these recent concerns with increased transparency rather than silence as they have in the past two weeks.
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)
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 sponsors frequent “vision trips” to India. These trips help inspire donors and prospective ministry workers to give time and money to the work of GFA. In Texas, GFA runs a School of Discipleship and the students at the school often go as a group to India as a part of their work. According to some former GFA travelers, they pack more than cameras and a toothbrush.
For over two years, some GFA travelers to India have been packing envelopes of cash designed to be taken into India and given unopened to GFA headquarters in Kerala, India. According to my sources, GFA staff in Texas have on multiple occasions given GFA travelers sealed envelopes filled with cash and said that the envelope contained $4500. The travelers — who were traveling together in groups of various sizes — were told the figure of $4500 was designed to avoid the need to declare the cash in India. Amounts of $5000 or more must be declared upon arrival. According to federal law, any amount of cash may be taken out of the country, but amounts of $10,000 or more must be declared when leaving or entering the U.S. According to my sources, the GFA groups were carrying far more than $10,000 per trip.
Over the last several days, I have spoken to five GFA travelers* who carried money to India in this manner and have examined GFA source information which described the practice. The sources said that most if not all members of their groups carried the envelopes filled with $4500. For instance, a group of ten people carried $45,000. I asked GFA COO David Carroll for comment but he has not replied. Pushing the Envelope
One individual told me that a GFA leader told a group of travelers that taxes were high in India and by taking undeclared cash, the ministry would benefit. According to all sources, each individual in the GFA groups received a sealed envelope from GFA leaders in Texas. I was told that one group had ten people carrying cash ($45,000 at one time) and another source said there were 30 travelers in a group (a maximum of $135,000). The travelers were told that each package contained $4500 and that each member of the group would turn in the envelope to a GFA leader in Kerala, India. The money did not belong to the travelers and was not to be used for expenses. The envelopes were to remain sealed and turned over to a GFA leader at headquarters or a Synod office for the Believers Church. Some specifically named Siny Punnose, who works in finance for GFA in India. Some groups consisted of students, some of ministry partners, and at times, pastors have been asked to carry funds.
All sources felt odd about taking the money. One person said fear of losing it or having it stolen was a constant preoccupation. They worried they were doing something that didn’t sound right. Even though the leaders assured them that the practice was fine, it still didn’t seem right.
And, in fact, the travelers may have been right to worry. Currency Structuring
One may leave or enter the United States with any amount of cash. However, a person who has $10,000 or more must declare it on a form designed by Customs and Border Protection when leaving or entering the U.S. As a recent CBP press release says, one may not split it up and have others carry it for you. In this case, GFA asked the travelers to carry much more than the $10,000 limit in total.
If travelers have someone else carry the currency or monetary instrument for them, they must file a currency report for the entire amount with CBP. Failure to report may result in seizure of the currency and/or arrest.
Another CBP press release tells of an Italian man who attempted to come into the country with more than $10k along with “co-travelers.”
During a secondary inspection, the man, who arrived from Italy, reported possessing $11,700. It was later discovered that the man had given money to two co-travelers in order to evade currency reporting requirements, an illegal practice known as currency structuring. In total the cash added up to $24,644. CBP officers seized the money, issued the man a $1,000 penalty, and then returned the remaining cash back to the man.
International travelers who arrive or depart the United States in possession of more than $10,000 or equivalent foreign currency are required to report all currency to CBP officers and complete a Treasury Department Financial Crimes Enforcement Network (FinCEN) form. (emphasis added)
Federal law appears to forbid such undeclared money moves without declaration. None of my sources report any forms filed. Note that the relevant federal law forbids aiding, commanding, or requesting such moves in the aggregate:
§ 103.23Reports of transportation of currency or monetary instruments.
(a)Each person who physically transports, mails, or ships, or causes to be physically transported, mailed, or shipped, or attempts to physically transport, mail or ship, or attempts to cause to be physically transported, mailed or shipped, currency or other monetary instruments in an aggregate amount exceeding $10,000 at one timefrom the United States to any place outside the United States, or into the United States from any place outside the United States, shall make a report thereof. A person is deemed to have caused such transportation, mailing or shipping when he aids, abets, counsels, commands, procures, or requests it to be done by a financial institution or any other person. (emphasis added)
(b)Each person who receives in the U.S. currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time which have been transported, mailed, or shipped to such person from any place outside the United States with respect to which a report has not been filed under paragraph (a) of this section, whether or not required to be filed thereunder, shall make a report thereof, stating the amount, the date of receipt, the form of monetary instruments, and the person from whom received.
I am not an attorney and realize that there may be some unknown facts which make this all fine. However, it seems strange to me. GFA can wire money to India and does so frequently. There are many other ways to get money to the field which can be verified transparently. If these travelers are accurate in their reports, GFA is causing hundreds of thousands of dollars in cash to be transported without declaration. This practice seems risky and fraught with many negatives and potentials for abuse.
I want to repeat that on Tuesday I asked GFA’s David Carroll for comment and explanation.
*All sources spoke on condition of anonymity for fear of retaliation from GFA. None of the people I spoke with are affiliated with the GFA Diaspora.