The Investigative Journal’s weekly review of Form 990 filings, charity enforcement actions and philanthropic money flows. All figures below are drawn from public records; links to source documents are provided throughout.
Three weeks out from the close of the summer enforcement calendar, the clearest signal in the nonprofit sector is a widening gap between two kinds of tax-exempt organization. On one side sit operating charities whose finance chiefs are being sentenced to federal prison over sums measured in the hundreds of thousands. On the other sit politically active social welfare groups moving eight-figure sums into federal campaigns with no donor disclosure at all. Both are 501(c) entities. Only one category is being policed with any regularity.
1. Dark money network’s super PAC contributions top $33 million
An analysis published August 11 by Citizens for Responsibility and Ethics in Washington (CREW) — a left-leaning watchdog whose findings TIJ reports here with that affiliation disclosed — found that a cluster of 13 connected nonprofits has directed more than $33.1 million to 31 federally registered super PACs in the 2026 cycle. Federal Election Commission records cited in the analysis put the same network’s giving at more than $14.6 million in the 2024 cycle and more than $22 million in the 2022 midterms.
The single largest concentration was the Kentucky Senate primary, where filings indicate more than $14.5 million flowed through five of the nonprofits. Keep America Great PAC, Inc. reported raising more than $16 million through June 30, 2026, of which $10.64 million came from three network entities: American Jobs and Growth Fund, Conservative Agenda for America and Defend US, Inc. A second super PAC that ran ads against a primary opponent drew $3.85 million from a fourth group. In Texas, America Works Fund — formerly Ohio Works, Inc. — contributed $8.9 million to a super PAC supporting Sen. John Cornyn’s unsuccessful primary bid.
The structural detail matters more than any single number. Form 990 filings for these organizations, available through ProPublica’s Nonprofit Explorer, show minimal staffing, single-member boards and shared vendors. American Jobs and Security reported raising and spending more than $9.8 million in 2024 while listing no employees and a sole board member devoting roughly two hours per week. Across the 13 entities, the most recent returns disclose 30 directly controlled disregarded entities — subsidiaries that carry separate trade names but file no separate return. Because 501(c)(4) organizations may engage in political spending without disclosing donors so long as social welfare remains their primary purpose, the money’s origin is not a matter of public record. Nothing in the filings establishes illegality; a prior FEC matter touching one predecessor entity has been closed.
2. A $2.1 million theft from a $15 million charity — on a $131,000 salary
Jeffrey Scott Keehn, 55, the former chief financial officer of Dallas-based Family and Child Guidance Centers, was sentenced in the last week of August to 60 months in federal prison after pleading guilty to one count of wire fraud. Prosecutors in the Northern District of Texas said he forged the signatures of the organization’s chief executive and chief operating officer on charity checks between September 2016 and January 2023 and deposited them into personal accounts using the remote deposit capture features of two banks’ mobile apps.
The organization’s own Form 990 supplies the context that makes the case instructive. For the fiscal year ending March 2023, the charity — which provides mental and behavioral health services in North Texas — reported $15,440,787 in revenue against $15,134,889 in expenses, with 98.9 percent of revenue coming from program services. Keehn’s reported compensation that year was $130,987, placing him third among key employees behind a chief executive at $147,380. The amount he is alleged to have taken, roughly $2.1 million over about six years, is close to three times his total reported pay across the period.
Court filings indicate he kept individual checks below $10,000 to avoid triggering a second required signature and recorded them in QuickBooks as vendor and medical-provider payments. Restitution was set at approximately $1.8 million to the charity and about $260,000 to two insurers. The threshold detail — a dollar figure chosen to sit just under an internal control — is the sort of finding that ordinary 990 review will never surface, and it argues for boards setting signature thresholds well below round numbers.
3. Iowa program director sentenced over $426,837 in false reimbursements
On August 25, Jodi Dyan Spargur-Tate, 55, of Colfax, Iowa, was sentenced to 18 months in federal prison and ordered to pay $426,837.11 in restitution for stealing from Children and Families of Iowa. According to the U.S. Attorney’s Office for the Southern District of Iowa, she served as a program director overseeing youth, adult and dislocated worker programs between 2015 and 2022, and submitted hundreds of fraudulent reimbursement requests supported by falsified invoices and receipts, while diverting more than one hundred payments to herself and family members.
The funds at issue originated with the U.S. Department of Labor, and the department’s Office of Inspector General investigated alongside Des Moines police. Children and Families of Iowa reported revenue of $15,190,221 for the fiscal year ending June 2025, with $3,364,877 in contributions and net assets of $25,018,557; its chief executive was compensated at $200,380. The theft represents under 3 percent of a single year’s revenue — small enough to disappear inside a program budget, which is precisely why grant-funded reimbursement lines warrant sampling by auditors rather than aggregate review.
4. New York sues a purported veterans’ charity over Airbnb proceeds
New York Attorney General Letitia James filed suit on August 12 against Healing for Heroes – A Disabled Veteran’s Retreat and Wooded Oasis, Inc., alleging that the Chautauqua County organization solicited donations for free retreats for disabled veterans it did not meaningfully provide. These are allegations in a pending civil matter; no court has ruled, and the defendants have not been found liable.
The petition alleges that since the organization’s 2024 founding it hosted four retreats, all attended by board members and their families and friends; that its two principals rented the 30-acre property on Airbnb at least 32 times across 2024 and 2025 while representing that proceeds would go to the charity, and retained $33,312.16 personally; and that nearly half of roughly $100,000 in donations went to property improvements, meals, shopping and vehicle expenses. The office also alleges solicitation began before the entity registered as a charity in New York. The state seeks dissolution, distribution of remaining assets to organizations serving disabled veterans, officer bars, damages, and penalties of $1,000 per charities-law violation and $5,000 per violation of the state’s FAIR Business Practices Act. TIJ sought comment through counsel of record; no response had been received at publication.
5. Executive pay: the bonus line is where the story is
CharityWatch’s 2026 tabulation of nonprofit compensation packages of $1 million or more, drawn from Form 990 disclosures, is a useful benchmark against which this week’s fraud cases can be read. Memorial Sloan Kettering Cancer Center president and chief executive Selwyn Vickers, M.D., topped the list at $6,979,162 for the year ending December 2024 — a figure that includes $3,475,000 in bonus and incentive compensation. City of Hope’s Robert W. Stone followed at $5,460,799, including $2,198,672 in bonus and incentive pay and $1,627,785 in retirement and deferred compensation. American Heart Association chief executive Nancy Brown reported $4,563,563 for the year ending June 2025, of which $3,247,122 was bonus and incentive compensation.
Two observations follow from the data rather than from sentiment. First, in the largest packages the variable component now routinely exceeds base salary, which shifts the governance question from “is the salary defensible” to “what metrics trigger the bonus, and who sets them.” Second, several of the largest single-year figures are one-time supplemental executive retirement plan payouts — $2,911,877 of Shriners Hospitals for Children executive vice president John McCabe’s $4,000,753, for instance — meaning a headline number can reflect two decades of accrual rather than one year of pay. CharityWatch itself cautions that high compensation does not by itself indicate inefficiency. Against these figures, the median operating charity looks very different: the two organizations victimized in this week’s federal cases each reported roughly $15 million in revenue with top executives paid between $147,000 and $200,000.
6. Foundation payout stays welded to 5 percent
Candid’s 2026 Foundation Giving Forecast Survey, published July 6, drew 542 responses. It found 44.3 percent of foundations expecting to increase giving in fiscal 2026, up from 23 percent in 2023, with 46.9 percent expecting flat giving. But the payout rate — qualifying distributions as a share of assets — has not moved. Among 288 independent foundations reporting a rate, the median has held at 5 percent for five consecutive years, with 62 percent reporting no change. Aggregate giving among 466 respondents was flat at $19.4 billion in both fiscal 2024 and 2025, though the median foundation increased giving 5.8 percent, or 3.1 percent after inflation. Community foundations posted the largest median gain at 14.1 percent.
One respondent quoted in the survey described the calculation candidly: the rate is “backed into” from the statutory minimum and the prior year’s Form 990-PF, not chosen strategically. Candid’s own framing — that the IRS floor “effectively functions as a 5% ceiling” — is supported by the distribution. This sits against a sector that, per Giving USA 2026, saw total American charitable giving reach $617.2 billion in 2025, up 5.7 percent in current dollars and 3.0 percent after inflation, with $79.05 billion of that flowing into grantmaking foundations rather than out of them.
7. Colorado’s tuition-invoice settlement
A smaller Colorado matter resolved earlier this year deserves a note for its structure. Attorney General Phil Weiser announced a consent judgment with Lindsay Salas, former executive director of Court Appointed Special Advocates of Adams and Broomfield Counties, after an investigation found she submitted falsified graduate-school tuition invoices to the organization. The charity paid them and sought reimbursement from a donor; because her university account carried a zero balance, the school refunded roughly $99,000 directly to her. She will pay $66,000 over six years, with a $125,000 judgment suspended pending compliance, and is barred for five years from financial or fundraising roles at charitable organizations. The mechanism — a legitimate donor-designated benefit converted into cash through a third-party refund — is one that few nonprofit internal control frameworks anticipate.
8. Regulatory watch
With the November 3 general election approaching, practitioner guidance published this year is consistent that the Johnson Amendment remains in force: 501(c)(3) organizations, including churches, may not endorse or oppose candidates. A federal court dismissed National Religious Broadcasters v. Bessent on March 31, 2026, so the proposed settlement that would have carved out internal faith-based campaign speech never took effect. Treasury and the IRS have signaled forthcoming guidance; until it issues, the existing prohibition applies in full. Separately, tax practitioners reviewing Revenue Procedure 2026-8 report that it reopened and overhauled the group exemption program effective January 20, 2026, replacing rules dating to 1980 and opening a transition period that closes January 22, 2027. Under that reading, central organizations holding preexisting group rulings will need to review their structures and file the new Form 15644. TIJ has not independently reviewed the revenue procedure text; organizations affected should confirm the requirements with counsel.
On the TIJ radar
Three threads warrant deeper reporting. First, the disregarded-entity layer beneath the politically active 501(c)(4) network: 30 subsidiaries across 13 organizations, none filing separately, several operating under names that read as independent state-level advocacy groups. Second, the recurrence of the finance-officer control gap — in both federal cases resolved this month, a single trusted employee controlled disbursement, reconciliation and the representations made to auditors. Third, the payout question: with foundation assets rising and grantee financial distress documented across multiple 2026 surveys, the persistence of a 5 percent median is the sector’s most consequential unexamined default.
Sources: CREW, “Dark money network spending more than ever in 2026 cycle” (Aug. 11, 2026); ProPublica Nonprofit Explorer filings for American Jobs and Growth Fund, Conservative Agenda for America, Defend US, Inc. and American Jobs and Security; Family and Child Guidance Centers (EIN 75-0800630) on Nonprofit Explorer; CFO Dive on the Keehn sentencing; U.S. Attorney’s Office, Southern District of Iowa (Aug. 27, 2026); Children and Families of Iowa (EIN 42-0680416) on Nonprofit Explorer; New York Attorney General press release and petition (Aug. 12, 2026); CharityWatch 2026 compensation update; Candid, 2026 Foundation Giving Forecast Survey; Giving USA 2026 summary; Colorado Attorney General consent judgment; 2026 election-year guidance on religious organizations and political activity; IRS Exempt Organizations Update.
Every factual assertion above is drawn from a public filing, court record or agency release linked in this article. Matters described as allegations remain pending and no findings of liability have been entered. Organizations and individuals named in pending matters are invited to respond; TIJ will publish corrections and replies.