Module 6: Citizen Action Card, Catch the Slip
How to Audit a Foreign-Principal Pass-Through in Five Minutes
Shadow Patriots Action Library · Project Milk Carton
Pairs with Module 6: “The Slip” — Foreign Principal Pass-Through
You now know what a foreign-principal pass-through is — a U.S. 501(c)(3) that accepts donor-deductible American contributions and routes a substantial share of them to a foreign counterpart organization that directs or produces the U.S. nonprofit’s program activity — all without ever registering under the Foreign Agents Registration Act (FARA).
This card teaches you how to take any U.S. 501(c)(3) with foreign operations and, in five minutes, estimate the likelihood that the organization is operating as an unregistered foreign-principal agent.
What a Pass-Through Looks Like on Paper
A pass-through leaves its paper trail across four public sources. You need all four to see the pattern.
Secondary sources that sharpen the picture:
Foreign nonprofit registry. If the foreign counterpart is an Israeli Amuta, search the Israeli registrar of Amutot. If it is a U.K. charity, the Charity Commission for England and Wales. If German — the Bundesanzeiger. Each jurisdiction publishes its own nonprofit disclosures, often in English translation.
Officer biographies. Public biographies, LinkedIn profiles, and published interviews of each senior officer.
News archives and DOJ press releases. Historical advisory opinions, enforcement actions, and news coverage of the named entities.
The 5-Minute Foreign-Principal Audit
Step 1 — Pull the 990 from ProPublica Nonprofit Explorer
Go to projects.propublica.org/nonprofits/ and search for the U.S. 501(c)(3) you are auditing. Pull the most recent 990 PDF.
Look at Part I — Summary at the top:
Line 12 — Total revenue. Note this figure.
Line 18 — Total expenses. Note this figure.
Line 14 — Benefits paid to or for members. Note this figure.
Then look at Part IX, Line 3 — Grants and other assistance to foreign organizations. Note this figure.
Initial ratio: Part IX Line 3 (foreign grants) ÷ Line 18 (total expenses). If that ratio exceeds 30%, the organization’s program is substantially foreign. If it exceeds 50%, the organization is running its program through a foreign counterpart — not the other way around.
Step 2 — Read Schedule F
Schedule F is the annex to the 990 that discloses foreign grants, foreign programs, and foreign activities. It has four parts.
Part I — total dollars, by world region, that the organization spent outside the United States.
Part II — grants of $5,000 or more to specific foreign organizations. This is the key part.
Part III — grants to foreign individuals.
Part IV — governance certifications about foreign activities.
In Part II, note:
The name and country of each foreign recipient organization.
The purpose of the grant (the narrative text).
The dollar amount.
Pass-through signal: A single foreign recipient receiving the majority of the U.S. nonprofit’s foreign-grant dollars, especially in a single country, and described in generic terms (“general operating support,” “program support,” “media activities”) rather than specific charitable purpose.
If the foreign recipient is itself a nonprofit association (an Israeli Amuta, a U.K. CIO, a German eingetragener Verein, a Swiss Verein, etc.) — that pattern, by itself, is a principal signal.
Step 3 — Cross-Check the DOJ FARA Database
Go to efile.fara.gov. Search three ways:
By the name of the U.S. 501(c)(3). Is the U.S. organization itself registered under FARA? (Most are not, which is the point of the module.)
By the name of the foreign counterpart organization. Is the foreign entity itself registered as a foreign principal whose U.S. agent files with FARA?
By the name of each senior officer of the U.S. 501(c)(3). Has any senior officer, past or present, filed FARA documents for any foreign principal?
An absence of FARA filings for all three of these searches — combined with Schedule F evidence of a single-foreign-counterpart majority expense share — is the strongest pass-through signal the public record affords.
Step 4 — Walk the Officer Biographies
Open Part VII of the 990 (Compensation of Officers, Directors, Key Employees, etc.). Note every name listed.
For each name, spend ~30 seconds on:
The senior officer’s own public biography on the U.S. nonprofit’s website.
The senior officer’s LinkedIn profile (if public).
Any published interviews, op-eds, or media appearances — a simple web search on the officer’s name will surface most of these.
Look specifically for:
Concurrent or recent service in a foreign government, a foreign-government-funded program, a foreign-government-endorsed institution, a foreign embassy, or a foreign state-affiliated cultural or public-relations entity.
Cross-border movement between a career in the foreign government/adjacent sector and the U.S. nonprofit leadership role.
Public statements by the officer characterizing the U.S. nonprofit’s mission as operationally supporting a foreign entity or foreign state interest.
A governance-overlap signal is three or more senior officers with documented ties to the same foreign-government-adjacent institutional sphere.
Step 5 — Check the Foreign Counterpart’s Own Registry
For the foreign counterpart organization identified in Schedule F (Step 2):
If the foreign counterpart is an Israeli Amuta — search the Israeli registrar of Amutot by registration number or organization name.
If the foreign counterpart is a U.K. charity — search the Charity Commission for England and Wales.
If the foreign counterpart is in any EU jurisdiction — search that country’s public nonprofit registry.
If the foreign counterpart is in a jurisdiction without a public nonprofit registry — document that fact; the absence of counterpart disclosure itself is a signal.
Cross-reference: the named leaders of the foreign counterpart, and their stated program activities, should align structurally with what the U.S. 501(c)(3) reports. If the U.S. nonprofit’s “media monitoring platform” and the foreign Amuta’s “research center” are describing the same deliverable — that is the content pipeline. Document the parallel.
Calculate the Pass-Through Score
Count these five signals. Each one is worth one point:
Foreign-expense concentration. The U.S. 501(c)(3) routes more than 50% of its expenses to a single foreign country, and more than 33% to a single foreign organization. (+1)
Anonymized inbound revenue. More than 15% of the U.S. 501(c)(3)’s revenue comes from donor-advised funds, private foundations, or anonymous donor vehicles. (+1)
Governance overlap. Three or more senior officers of the U.S. 501(c)(3) have documented service in a foreign government, a foreign-government-endorsed institution, or a foreign-state-adjacent program. (+1)
Content pipeline. The U.S. 501(c)(3)’s principal public deliverable is identifiably produced by, or branded for, the foreign counterpart — based on each entity’s own public materials. (+1)
No FARA filing. Neither the U.S. 501(c)(3), the foreign counterpart, nor any senior officer appears in the DOJ FARA database. (+1)
0–1: Routine foreign-operations charity. No pass-through signal. 2–3: Worth a closer look. Some pass-through signals present; may be legitimate international operations with overlap. 4–5: Likely foreign-principal pass-through running on autopilot. Most of the U.S. nonprofit’s program activity is being run through, or under the direction of, the foreign counterpart — without a FARA filing.
Quick Reference: Pass-Through Red Flags (Not Proof — Questions Worth Asking)
Your Assignment
Pick ONE of these:
Option A — The Pass-Through Walk. Pick any U.S. 501(c)(3) you have seen in the news in the last twelve months whose work concerns a specific foreign country, foreign-policy question, or foreign information environment. Pull its most recent 990 from ProPublica. Run the full 5-step audit. Calculate the Pass-Through Score. Report what you find.
Option B — The Foreign-Counterpart Walk. Pick any foreign nonprofit, foreign policy institute, or foreign media-monitoring organization you are familiar with. Search the DOJ FARA database for it. Search for any U.S. 501(c)(3) that lists it on Schedule F. If you find a U.S. nonprofit counterpart, run the 5-step audit on the U.S. entity.
Option C — The Reverse Walk. Pick any politically-active issue-advocacy brand in the U.S. whose content consistently advocates for a specific foreign government’s interests — in either direction, across any region. Look at the brand’s footer or “About” page to identify the sponsoring 501(c)(3). Pull that 501(c)(3)’s 990. Check Schedule F and the FARA database. Report what you find.
Option D — The Regulator Letter. If your audit returns a score of 4 or 5 out of 5, and you are comfortable doing so, draft a letter to (a) the DOJ FARA Unit at efile.fara.gov, and/or (b) your state attorney general’s charitable registration office, summarizing the publicly documented structural facts. Do not allege. Summarize the public record. Ask whether a FARA advisory opinion is warranted. The DOJ FARA Unit responds to citizen inquiries of this kind.
Report what you find. Post it in the comments. Tag us. Every citizen who catches a slip makes the architecture one step more visible.
Shadow Patriots Action Library · Module 6 · Project Milk Carton · 501(c)(3) · EIN 33-1323547
