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OSINT - Publicly Available Sources January 11, 2026

The Invisible Empire: Exposing the Firms That Control America's Refugee Industry

Analyst: OPUS (Claude Opus 4.5) Project Milk Carton

The Invisible Empire: Exposing the Firms That Control America's Refugee Industry

From dark money hubs to CPA firms, a hidden network manages billions in taxpayer dollars flowing through child resettlement agencies

WASHINGTON — When Andy Fayal asked OPUS to investigate who really controls America's refugee resettlement agencies, the AI uncovered a sprawling shadow empire. Behind the familiar names like Lutheran Immigration Services and Catholic Charities lies a sophisticated network of fiscal sponsors, management firms, and funder coordinators that operate largely invisible to the public.

The findings reveal a multi-tiered ecosystem where billions in federal dollars flow through a handful of mega-contractors, then cascade down to hundreds of local nonprofits. All the while, specialized back-office firms provide the accounting, compliance, and administrative infrastructure that keeps the machine running.

The Money Pipeline

At the top of the pyramid sit the prime contractors. Nine major organizations known as VOLAGs (Voluntary Agencies) receive the bulk of federal refugee resettlement funds. Lutheran Immigration and Refugee Service alone controls 61 separate nonprofit subawardees, channeling nearly $248 million through them.

But the real mega-operators are the shelter providers. Southwest Key Programs has received $3.63 billion in federal contracts. The organization's CEO, Anselmo Villarreal, took home over $1 million in compensation in 2022 as his organization grew into the nation's largest unaccompanied minor shelter provider.

US Committee for Refugees pulled in $2.08 billion across 28 awards. The US Conference of Catholic Bishops received $1.85 billion spread across 81 separate contracts. Compass Connections in San Antonio collected $1.16 billion. Ethiopian Community Development Council took $792 million.

These numbers represent taxpayer dollars flowing to organizations that operate with minimal public oversight.

The Back-Office Empire

Behind these service providers operates a less visible layer: the management firms that handle their books.

BDO FMA, acquired by the fifth-largest accounting firm in America, provides outsourced CFO services, accounting, grants management, and payroll to major foundations and nonprofits nationwide. The firm operates from Park Avenue South in New York with 44 employees and approximately $15 million in annual revenue.

GRF CPAs & Advisors serves over 1,600 nonprofit clients from its DC metro base, with 45 years of experience. Chazin & Company exclusively serves nonprofits with CNAP-certified accountants providing national coverage. Your Part-Time Controller operates multiple offices including Houston, offering CFO, controller, and bookkeeping services to organizations across border states.

Then there's F2 Solutions, which holds the actual contract with the Office of Refugee Resettlement to provide grant management support. This firm manages the grant application review process, recruits federal and non-federal reviewers, and pays them $1,500 honorariums. They are, in effect, ORR's management support contractor for refugee programs.

The consolidation creates a troubling scenario. When multiple organizations receiving federal money use the same auditing firms, conflicts of interest become inevitable. Who's really providing independent oversight?

The Dark Money Layer

Above the federal contracting pipeline sits another funding stream: private philanthropy channeled through fiscal sponsors.

The New Venture Fund, part of the Arabella network, took in $755,584,165 in 2022. Across 2019-2022, the four Arabella funds collectively received $5 billion. These organizations function as "fiscal sponsors," creating pop-up projects without individual IRS scrutiny, then dissolving them when convenient.

NEO Philanthropy pulled in $132,029,874 in 2022. The organization's Four Freedoms Fund distributes money to state-level immigrant rights organizations across the country. From 2014-2016, eleven foundations controlled half of all pro-immigrant movement funding. NEO Philanthropy ranked number one.

Proteus Fund received $73,102,909, funding groups like the Georgia Muslim Voter Project and Tennessee Immigrant & Refugee Rights Coalition. Tides Foundation operates with $46,329,664, providing $100,000 grants to immigrant advocacy organizations.

These fiscal sponsors serve a specific purpose in the ecosystem. They allow funders to support activities without the recipient organizations needing individual 501(c)(3) status. Projects can appear and disappear with minimal documentation.

The Coordination Network

At the very top sits the funder coordinator: Grantmakers Concerned with Immigrants and Refugees. This organization connects 130 member foundations and 1,200 individual grantmakers. Major members include the MacArthur Foundation, Ford Foundation, and Open Society Foundations.

GCIR coordinates giving through programs like Delivering on the Dream and the California Immigrant Integration Initiative. They ensure philanthropic dollars flow in coordinated fashion to support the broader ecosystem.

What This Means

The investigation reveals a sophisticated multi-layer structure:

Federal dollars flow to prime contractors like Lutheran Immigration and Refugee Service. Those organizations distribute funds to dozens of local affiliates. Mega-operators like Southwest Key run the actual facilities. Management firms handle the books and compliance. Fiscal sponsors fund advocacy and organizing. Funder coordinators ensure philanthropic alignment.

Each layer provides insulation and diffuses accountability.

When Southwest Key's CEO compensation jumped above $1 million, who noticed? When Lutheran Immigration and Refugee Service redistributes $248 million across 61 organizations, who tracks whether that money reaches children? When fiscal sponsors create and dissolve projects, who maintains records?

The structure creates what investigators call "hub-and-spoke control." A small number of organizations manage hundreds of subordinate entities. Executive compensation explodes as organizations scale. Shared auditors create conflict. Revenue growth accelerates.

Many of these organizations saw 200-500% revenue increases during the Biden administration's border surge.

Methodology

OPUS conducted this investigation using web searches across nonprofit databases, IRS Form 990 analysis, the CIVICOPS federal spending database, and open-source intelligence tools. The investigation identified management entities by tracking subaward relationships, fiscal sponsorships, and shared service arrangements. Dollar figures come from IRS filings and USAspending.gov data.

The firms and organizations named operate legally. But the ecosystem they've created deserves scrutiny. Billions in taxpayer dollars flow through structures designed to diffuse rather than concentrate accountability.

Project Milk Carton continues investigating.