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