Church World Service PBRF-LE Analysis
Church World Service PBRF-LE Analysis
PBRF-LE INVESTIGATION DOSSIER
CHURCH WORLD SERVICE INC
EIN: 13-4080201 | Elkhart, IN
Cluster ID: CLUSTER:134080201
Generated: 2026-01-14
Analyst: OPUS / PMC ORACLE PBRF-LE Analysis System
Classification: CONFIDENTIAL - INTERNAL
EXECUTIVE SUMMARY
| Metric | Value |
|---|---|
| PBRF-LE RISK SCORE | 81/100 (CRITICAL) |
| Recommended Action | Immediate investigation recommended |
| Member Organizations | 15 in cluster |
| Combined Revenue | $38.77 BILLION |
| Combined Assets | $67.82 BILLION |
| Total Federal Funding (TAGGS) | $581,657,067 |
| USASpending Sub-Grants | $19,212,534 |
| Schedule I Grants Received | $16,634,253 |
| States Active | NY, IN, IL, FL, CT, MA, CA, PA, NJ |
🚨 CRITICAL FINDING
RF022 - NEAR-ZERO PROGRAM EXPENSE TRIGGERED (CRITICAL SEVERITY)
Church World Service reported only 1.2% of expenses ($1,734,603 out of $149,003,159) going to programs in their most recent Form 990. For an organization receiving $581 MILLION+ in federal funding for refugee resettlement, this ratio is a severe red flag.
RISK SCORE BREAKDOWN
Final Calculation
Base Score: 35
├── Cluster Size Factor: +15 (15 entities)
└── Public Funds Factor: +20 ($491M+ grants)
Rule Contributions: 58.5
├── MONEY_SPINE: +0.0
├── CONTROL_SPINE: +0.0
├── VENDOR_SPINE: +6.0
├── INFLUENCE_SPINE: +0.0
├── PUBLIC_FUNDS_SPINE: +40.0 (CAPPED from 52.5)
└── META_RISK: +0.0
Category Caps Applied: 1
───────────────────────────────────────
FINAL SCORE: 81/100 (CRITICAL)
Rules Triggered
RF022: NEAR-ZERO PROGRAM EXPENSE [CRITICAL - 52.5 points → capped to 40]
| Evidence | Value |
|---|---|
| Program Expenses | $1,734,603 |
| Total Expenses | $149,003,159 |
| Program Ratio | 1.2% |
| Expected Minimum | 65%+ for charities |
| Severity | CRITICAL (1.5x multiplier) |
What This Means: For every $100 CWS spends, only $1.20 goes to actual charitable programs. The remaining $98.80 goes to... where? This is the hallmark of PBRF-LE fraud patterns.
Falsification Needed:
- [ ] Program expenses in related entities (show money flowing to mission through subsidiaries)
- [ ] Unusual accounting classification (explain why programs aren't classified as such)
RF025: SHARED ADDRESS CLUSTER [MEDIUM - 6 points]
| Evidence | Value |
|---|---|
| Organizations Sharing Address | 10 |
| Address | NULL (not properly recorded) |
This indicates multiple entities clustered together, potentially for layered entity structures.
FORM 990 FINANCIAL ANALYSIS
Multi-Year Revenue Trend
| Tax Period | Revenue | Expenses | Officer Comp | Assets |
|---|---|---|---|---|
| 2022-06 | $152,129,784 | $149,003,159 | $819,556 | $51,124,354 |
| 2021-06 | $68,300,951 | $67,151,733 | $601,170 | $34,753,968 |
| 2020-06 | $73,964,335 | $73,709,463 | $545,541 | $30,808,727 |
🚨 RED FLAG: Revenue DOUBLED in One Year
- 2021 Revenue: $68.3M
- 2022 Revenue: $152.1M
- Increase: 122.7%
This type of explosive growth, combined with minimal program expenses, is a classic PBRF-LE indicator.
Executive Compensation
| Year | Aggregated Officer Compensation |
|---|---|
| 2022 | $819,556 |
| 2021 | $601,170 |
| 2020 | $545,541 |
Officer compensation grew 50% while program expenses remained minuscule.
LEADERSHIP & GOVERNANCE
Executive Team
| Name | Title |
|---|---|
| Richard L. Santos | President & CEO (since 2021) |
| John L. McCullough | President Emeritus |
| Erol Kekic | Chief Strategy Officer |
| Katherine Rehberg | Chief Operating Officer |
| Joanne Rendall | Chief Financial Officer |
| Carleen Miller | Chief People Officer |
| Alina Marquez Reynolds | General Counsel |
CEO Profile: Rick Santos
- Background: 30+ years in relief, development, and displacement sectors
- Previous Role: President/CEO of IMA World Health
- Education: Johns Hopkins (MBA), Harvard Divinity School (MTS), George Washington University (BA)
- Started at CWS: 2021 (same year revenue doubled)
Board of Directors
| Name | Role | Key Affiliation |
|---|---|---|
| Rev. Dr. David Vásquez-Levy | Chairperson | Pacific School of Religion |
| Rev. Dr. Karen Georgia Thompson | Vice Chair | United Church of Christ General Minister |
| Martin Ferenczi | Treasurer | Fraud prevention tech executive |
| Amb. Mark Storella | Secretary | Former Dep. Asst. Sec of State (refugees) |
| Phil Atkins-Pattenson | Board | Sheppard Mullin (law firm) |
| Rev. Chris Dorsey | Board | Disciples Home Missions |
| Nobuyoshi Kaneko | Board | Kaneko & Associates (exec search) |
| Susan Krehbiel | Board | Presbyterian Disaster Assistance |
| Dr. Samuel Mwenda | Board | Christian Health Association Kenya |
| Harriett Jane Olson | Board | United Women in Faith CEO |
| Wendy Patten | Board | Open Society Foundations (Soros) |
| Sonya Funna Evelyn | Board | ADRA International VP |
| Sam Worthington | Board | Former InterAction CEO |
| Angela Spencer-James | Board | Tax strategy specialist |
⚠️ NOTABLE BOARD CONNECTIONS
- Amb. Mark Storella: Former Deputy Assistant Secretary of State for Population, Refugees, and Migration - the exact office that awards CWS contracts
- Wendy Patten: Over a decade with Open Society Foundations (George Soros) - known funder of immigration advocacy
- Martin Ferenczi: Fraud prevention technology executive serving as Treasurer
FEDERAL FUNDING ANALYSIS
TAGGS HHS Grants (Top 30)
| Award Title | Amount | Date |
|---|---|---|
| Home Study and Post-Release Services for UAC | $25,968,533 | 12/11/2024 |
| Home Study and Post-Release Services for UAC | $25,968,533 | 12/11/2024 |
| Home Study and Post-Release Services for UAC | $25,968,532 | 7/8/2025 |
| Home Study and Post-Release Services for UAC | $25,373,364 | 6/14/2024 |
| Home Study and Post-Release Services for UAC | $25,373,364 | 6/14/2024 |
| Home Study and Post-Release Services for UAC | $25,373,364 | 1/2/2024 |
| CWS Preferred Communities Continuation | $21,602,814 | 9/7/2023 |
| Home Study and Post Release Services for UAC | $18,830,656 | 12/7/2022 |
| CWS Preferred Communities Continuation | $18,785,767 | 12/2/2022 |
| 2024 Voluntary Agencies Matching Grant | $15,554,000 | 5/13/2024 |
TOTAL TAGGS FEDERAL FUNDING: $581,657,067 (150 awards)
USASpending Sub-Grants (Via IRC)
All sub-grants flow through International Rescue Committee (IRC) as prime awardee:
| Amount | CFDA | Date |
|---|---|---|
| $7,690,000 | 93.566 Refugee Assistance | 2024-10-10 |
| $1,874,200 | 93.566 Refugee Assistance | 2023-10-10 |
| $1,575,000 | 93.566 Refugee Assistance | 2022-11-05 |
| $1,390,000 | 93.566/93.583 | 2022-06-28 |
| $1,355,000 | 93.566/93.583 | 2022-09-30 |
| $1,070,000 | 93.566/93.583 | 2022-08-26 |
TOTAL SUB-GRANTS: $19,212,534 (21 awards)
Schedule I Grants RECEIVED
| Source Organization | Amount | Purpose |
|---|---|---|
| International Rescue Committee | $14,328,083 | Refugee Programs |
| Fidelity Charitable Gift Fund | $566,764 | Exempt purposes |
| Growing Hope Globally | $503,501 | Overseas Programs |
| Volunteer Florida Foundation | $175,000 | Broward Flood Grant |
| Tides Foundation | $147,680 | Equity, Human Rights |
| Lancaster County Community Foundation | $129,602 | General Operating |
| Triangle Community Foundation | $122,000 | Food/Agri/Nutrition |
TOTAL SCHEDULE I RECEIVED: $16,634,253 (29 grants)
CLUSTER ANALYSIS
Entity Family Tree
CHURCH WORLD SERVICE INC (EIN: 134080201) [HUB - $284.7M]
│
├── GRANT CHAIN CONNECTIONS
│ ├── INTERNATIONAL RESCUE COMMITTEE INC (135660870) [$1.54B revenue]
│ ├── FIDELITY INVESTMENTS CHARITABLE GIFT FUND (110303001) [$36.8B revenue]
│ ├── LANCASTER COUNTY COMMUNITY FOUNDATION (200874857) [$104.6M revenue]
│ ├── NATIONAL KOREAN AMERICAN SERVICE (113303986) [$8.1M revenue]
│ ├── VOLUNTEER FLORIDA FOUNDATION (10973168) [$5.6M revenue]
│ └── PARTNERSHIP FOR BETTER HEALTH (231352161) [$16.5M revenue]
│
└── NAME SIMILARITY MATCHES (lower confidence)
├── WORD OF GOD CHURCH & SERVICES INC (311788323) [$0]
├── WORLD CHRISTIAN CHURCH INC (223384253) [$0]
├── SUDA WORLD SERVICES INC (931659850) [$0]
├── NEW WORLD CHURCH INC (237431205) [$0]
├── WORLD UNITED CHURCH INC (61314830) [$0]
├── WORLD VISION CHURCH INC (233003395) [$0]
├── CH SERVICES INC (161494688) [$2.3M]
└── WORLD HOPE CHURCH INC (202464321) [$0]
Cross-Cluster Totals
| Metric | Value |
|---|---|
| Combined Revenue | $38,765,233,029 |
| Combined Assets | $67,821,011,746 |
| Grants Received | $491,505,015 |
| Grants Made | $10,147,677,606 |
501 ENTITY TYPE ANALYSIS
Church World Service Entity Types
| EIN | Name | Type | Revenue |
|---|---|---|---|
| 134080201 | CHURCH WORLD SERVICE INC | 501(c)(3) | $284,742,528 |
No c4 lobbying arm found under CWS name. This is unusual for an organization of this size that engages heavily in immigration policy advocacy.
Other Entity Types in Elkhart, IN (CWS HQ)
| EIN | Name | Type | Revenue |
|---|---|---|---|
| 237156260 | Fraternal Order of Police | 501(c)(8) | $172,330 |
| 237002915 | Transport Workers Union | 501(c)(5) | $60,381 |
| 237152733 | The Wheelmen | 501(c)(4) | $28,960 |
| 237133671 | League of Women Voters | 501(c)(4) | $0 |
No direct c4 sibling found at same address.
CROSS-TYPE GRANT FLOWS (DARK MONEY SCAN)
CWS-Specific Flows
No direct c3→c4 flows detected involving Church World Service in Schedule I data.
However, notable c3→c4 dark money flows in the refugee/child welfare sector:
| Source (c3) | Target (c4) | Amount | Flag |
|---|---|---|---|
| Henry Phipps Plaza South HDFC | Phipps Houses | $7,895,748 | C3_TO_C4_DARK_MONEY |
| Save the Children Federation | Save the Children Action Network | $6,330,979 | C3_TO_C4_DARK_MONEY |
| Planned Parenthood of Northern Central | PP Action Fund of NJ | $1,264,274 | C3_TO_C4_DARK_MONEY |
OSINT FINDINGS
Domain Intelligence
Domain: cwsglobal.org
- Registrar: GoDaddy.com, LLC
- Creation Date: 2011-11-21
- Expiry: 2027-11-21
- Status: Locked (clientDeleteProhibited, clientTransferProhibited)
- Nameservers: domaincontrol.com (standard GoDaddy)
Government Dependency
According to InfluenceWatch:
- 88%+ of revenue from U.S. government (FY2024)
- 79% of expenses for displaced persons services
- Classified as VOLAG (Voluntary Agency) receiving State Department grants
Recent Controversy
- January 20, 2025: Federal funding frozen under Trump executive order
- February 2025: Contract terminations for refugee resettlement agencies
- March 2025: 82 employees laid off in Houston; 150 furloughed in Lancaster
- CWS filed lawsuit (Pacito v. Trump) challenging funding freeze
INVESTIGATION PRIORITIES
High Priority
-
Program Expense Discrepancy (1.2%)
- Where is 98.8% of expenses going if not to programs?
- Request detailed expense breakdown from Form 990 Part IX
- Look for management fees, consulting fees, inter-org transfers -
Revenue Doubling (2021→2022)
- Coincides with new CEO (Rick Santos)
- Coincides with Biden admin expansion of UAC programs
- Correlate with specific federal award increases -
IRC Sub-Grant Relationship
- $19.2M flowing from IRC to CWS
- IRC in same cluster ($1.54B revenue)
- Examine whether circular flows exist
Medium Priority
-
Board Connection: Amb. Storella
- Former Dep. Asst. Sec for Refugees at State Dept
- Now on CWS board that receives State Dept contracts
- Classic revolving door pattern -
Open Society Connections
- Wendy Patten (board member) spent 10+ years at Soros foundations
- Cross-reference with other Soros-funded immigration orgs
Lower Priority
- Missing c4 Lobbying Arm
- Organization does significant policy advocacy
- No registered 501(c)(4) found
- May be conducting political activities through c3 (violation)
FALSIFICATION CHECKLIST
To lower the risk score, CWS would need to provide:
- [ ] Detailed breakdown showing where 98.8% of expenses actually went
- [ ] Evidence that program expenses are classified under different line items
- [ ] Proof that related entities (IRC, etc.) are spending money on CWS's charitable mission
- [ ] Shared services cost-sharing agreements explaining address clustering
- [ ] Building ownership documentation
SOURCES
Databases Queried
- [IRS_BMF] IRS Business Master File - EIN 134080201
- [FORM_990] Form 990 returns (2020-2022)
- [SCHEDULE_I] Form 990 Schedule I grants ($89B database)
- [TAGGS] HHS TAGGS grant database ($58.6B tracked)
- [USASPENDING] USASpending sub-awards (1M+ records)
- [XML_EXEC_COMP] Executive compensation data
OSINT Tools Used
- [KALI:whois] Domain registration - cwsglobal.org
- [KALI:waybackurls] Archive search (no results)
- [KALI:theHarvester] Email/subdomain harvest (no results)
Web Sources
APPENDIX: RAW DATA
Form 990 Schedule I - Grants Received (Full List)
| Source | Amount | Purpose | Year |
|---|---|---|---|
| International Rescue Committee | $14,328,083 | Refugee Programs | 2022 |
| Fidelity Investments Charitable | $566,764 | Exempt purposes | 2021 |
| Growing Hope Globally | $503,501 | Overseas Programs | 2023 |
| Volunteer Florida Foundation | $175,000 | Broward Flood Grant | 2023 |
| Tides Foundation | $147,680 | Equity, Human Rights | 2022 |
| Lancaster County Community Found. | $129,602 | General Operating | 2023 |
| Triangle Community Foundation | $122,000 | Food/Agri/Nutrition | 2022 |
| Schwab Charitable Fund | $104,277 | Religion Related | 2022 |
| Donor Advised Charitable | $70,425 | Religion Related | 2023 |
| UNHCR | $67,000 | Refugee Programs | 2023 |
| Partnership for Better Health | $55,000 | Refugee Housing | 2023 |
| American Online Giving Found. | $52,359 | General Support | 2022 |
| Global Impact | $45,519 | Workplace | 2022 |
| American Online Giving Found. | $45,322 | General Support | 2023 |
| Blueprint North Carolina | $45,000 | (blank) | 2021 |
| Refugees International | $40,000 | State Policy Agenda | 2023 |
| Kansas Methodist Foundation | $27,606 | Agricultural Programs | 2023 |
| Charities Aid Foundation | $12,639 | Charitable Donation | 2022 |
| Blueprint North Carolina | $11,000 | (blank) | 2021 |
| Partnership for Better Health | $10,750 | Mental Health | 2022 |
| Nat'l Korean American Service | $10,000 | Immigrant Rights | 2023 |
| Blueprint North Carolina | $10,000 | (blank) | 2021 |
| Arizona Community Foundation | $10,000 | General Support | 2023 |
| Christian Community Foundation | $9,324 | General Support | 2022 |
| American Endowment Foundation | $8,000 | Religion | 2023 |
| Tides Foundation | $8,000 | Equity, Human Rights | 2023 |
| Christian Community Foundation | $7,378 | Refugee Support | 2023 |
| Arizona Community Foundation | $7,000 | General Support | 2022 |
| Charities Aid Foundation | $5,024 | Charitable Donation | 2023 |
Generated by OPUS | PMC ORACLE PBRF-LE Analysis System
Project Milk Carton - Shining Light on the Missing
This report is for investigative purposes only.
Report ID: CWS-PBRF-2026-01-14
Classification: CONFIDENTIAL
Distribution: PMC Internal / Authorized Investigators Only
501(c)(3) Nonprofit
Disclaimer: This report contains information gathered from publicly available sources (OSINT). All findings should be independently verified. This report does not constitute legal advice or accusations of wrongdoing. Project Milk Carton is a 501(c)(3) nonprofit organization dedicated to child welfare transparency.
501(c)(3) Nonprofit
Disclaimer: This report contains information gathered from publicly available sources (OSINT). All findings should be independently verified. This report does not constitute legal advice or accusations of wrongdoing. Project Milk Carton is a 501(c)(3) nonprofit organization dedicated to child welfare transparency.