Secret Internal Audit of Clinton Foundation: Legal Nightmare Waiting to Happen


The Clinton Foundation lacked controls and basic policies required by federal laws which could lead to “significant legal and reputational risks,” according to an internal 2008 audit released by Wikileaks.

The audit’s findings are alarming:

  • Foundation not in compliance with federal, New York regulations for corporate filings
  • Foundation has no compliance staff or structure in place
  • No record retention policy
  • No risk management policy
  • Finance Dept. policies inefficient
  • Management “by fear”
  • Crony management had no non-profit experience
  • Managers had no real other management experience either
  • Poor and low pay compared to other non profits
  • Micro managing was prevalent
  • Whistle blowing frowned upon, ignored
  • No written employee policies or procedures
  • No corporate or non-profit training
  • Employees not held accountable for performance
  • Favoritism employed by managers
  • Little oversight by legal dept paid to government filings


And It gets worse.

There are members of the staff who are paid by the President/his office and the Foundation, which may cause apparent or real conflicts of interest.

For example, a senior staff member being paid by the President, the government, and the Foundation allowed the Foundation to host what may have been (or may have been viewed as) a political event, apparently, without official pre-approval from the Foundation’s legal department and without regard, before the fact, to the impact of that decision on the Foundation’s tax exempt status.

 It has been reported to me that a senior staff member has attempted to have (and perhaps succeeded in having) her travel paid for by the Foundation when traveling with the President on mixed trips, even though her presence may not have been needed for the Foundation.

It is not apparent how staff members paid through various sources (which means, presumably, having more than one full-time job) are able to fulfill their responsibilities and duties to the Foundation given the amount of work associated with those responsibilities and duties.

The audit would have likely shut any other legitimate company down. But not the Clinton Foundation. A copy of the full audit can be read at Wikileaks after downloading the email’s attachment.


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