Module 9: Three Hats, One Head

How the Same Fifty People Run Three Hundred Nominally Independent Nonprofits — and Why No Regulator Sees the Diagram

Shadow Patriots · Module 9 · Project Milk Carton · 501(c)(3) · EIN 33-1323547

Module 8 showed you how a 501(c)(3) “educational” classification hides the purpose of an operation — the four-letter credential does the work of validating content that no regulator ever audits.

Module 9 is the sister problem, and arguably the more structural one. Because where Module 8 hides the purpose of a single entity, Module 9 hides the coordination between ostensibly independent entities. Not by concealment. By distribution.

When prosecutors or reporters ask, “Did these organizations coordinate?” — the answer from each organization’s counsel is the same. “We had no contact with that organization. We have no formal relationship.” Both statements are usually true. Neither is the relevant one.

Because the coordination is not happening between the organizations. It is happening inside the shared heads of the people who run them.

This module teaches you how to read Form 990 Part VII, Schedule L, and Schedule R against one another; identify the personnel patterns that connect nominally independent 501(c)(3)s, 501(c)(4)s, 527s, Delaware LLCs, and private foundations; and — in fifteen minutes per organization — score the density of the interlock. The diagram is public. The public has simply never been given the pen.

Part I — Why the Pattern Is Structural

Interlocking directorates are not new and not illegal.

The doctrine is more than a century old. The Clayton Antitrust Act of 1914, Section 8 prohibited the same person from sitting on the boards of directly competing corporations above a certain size — a rule written specifically to prevent coordination by overlap in the Gilded Age rail and steel industries. It has been refined repeatedly in the for-profit world.

For nonprofits, no such rule exists.

A single individual can sit on the board of a 501(c)(3) educational foundation, a 501(c)(4) advocacy group, a 527 political committee, a Delaware LLC, a private family foundation, and a state-registered charitable trust — simultaneously, as long as each entity’s internal bylaws permit it.

And inside the rules we have spent eight modules examining, each of those entity types answers to a different regulator. The IRS looks at the 501(c)(3). The FEC looks at the 527. The state attorney general looks at the charitable trust. The Delaware Secretary of State looks at the LLC. The 501(c)(4) answers largely to nobody.

When the same person is the connecting tissue across all six — and there is no shared regulator with authority to look at that person as the unit of analysis — the overlap itself becomes the coordination architecture.

This is the part the tax code does not name.

Part II — The Three-Document Spine

Every 501(c)(3) in America files the same form. Form 990. Publicly available on ProPublica Nonprofit Explorer. Every year.

Three sections of Form 990, read in sequence, give you the personnel-overlap picture on any nonprofit. We are going to walk them in order.

Part VII — Officers, Directors, Trustees, and Key Employees

Part VII is the personnel census. Every officer, director, and key employee above a compensation threshold must be listed by name. Next to each name: title, hours per week, and compensation from the organization. Next to that: compensation from “related organizations.”

That last column is the hinge.

If a director of a 501(c)(3) is also compensated by a related entity — a for-profit consulting firm, a foundation, an LLC — Part VII is where that appears. It is not always complete. It is not always honest. But when it is filled out, it is the roadmap.

Schedule L — Transactions with Interested Persons

Schedule L is the related-party transactions disclosure. Part I covers excess-benefit transactions. Part II covers loans to or from interested persons. Part III covers grants to interested persons. Part IV covers business transactions involving interested persons.

If the nonprofit paid the board chair’s consulting LLC $240,000 for “strategic advisory services,” that transaction is supposed to appear in Part IV.

If it does not appear in Part IV but the LLC is real, the problem is not disclosure. The problem is, structurally, a conflicted board approving payments to its own members’ companies — and the public cannot see the edge without Schedule L completing the loop.

Schedule R — Related Organizations and Unrelated Partnerships

Schedule R is the organizational-family tree. It names every related tax-exempt organization, every related taxable entity, every partnership the nonprofit is invested in.

Schedule R is where the fiscal-sponsor umbrella (Module 5) appears. Where the 501(c)(3) / 501(c)(4) pair appears. Where the Delaware LLC affiliate (Module 7) appears.

Part VII gives you the people. Schedule L gives you the edges. Schedule R gives you the organizations. All three together give you the network.

One document is a list. Three documents are a diagram.

Part III — Case A: The Institutional Nexus (Red-Coded)

Every case study in this module is drawn only from public records — Form 990 Part VII, state corporate filings, counsel-of-record dockets, published board rosters. No claims require access to private information. Every reader with a laptop can verify every claim below.

Case A is an institutional concentration on the political right. The organizations involved include the America First Policy Institute, the Kash Patel Foundation, and the Binnall Law Group. The individual sitting at the center of the overlap is Alexis Wilkins, listed publicly as a Senior Fellow at the America First Policy Institute.

Here is the interlock as it appears on public filings, described strictly by edge:

• Wilkins holds a Senior Fellow affiliation at the America First Policy Institute (AFPI), a 501(c)(3) whose Form 990 appears on ProPublica Nonprofit Explorer. The senior fellowship is a paid affiliation.

• The Binnall Law Group, an Alexandria, Virginia law firm, is Wilkins’s counsel of record in publicly filed defamation litigation including Wilkins v. Schaffer in the Southern District of Florida. Binnall Law Group’s counsel-of-record status is public docket information.

• The Kash Patel Foundation is a 501(c)(3) whose Form 990 is publicly available. Binnall Law Group’s engagement with Kash Foundation-adjacent matters is reflected in public press and litigation filings.

• Kash Patel has publicly served as the Foundation’s principal, and — as confirmed in public filings and press — held simultaneous roles across multiple America First-adjacent 501(c)(3)s and affiliated consulting entities during the 2021–2024 period.

We are not alleging coordination between these entities. We are mapping publicly filed affiliations.

The structural observation is this. A single network of counsel, foundation officers, and senior fellowships connects an individual, a think-tank affiliation, a law firm, and a foundation — across four legally distinct entities, each answerable to a different regulator. Under the letter of the rules we have spent eight modules examining, there is nothing to file, nothing to disclose, nothing to report. The same person with three hats, answering to no single regulator wearing all three.

A reader who wants to verify the edges we have listed can pull each entity’s Form 990 on ProPublica, pull each federal court docket on CourtListener, and trace the counsel-of-record entries.

The names are on paper. The edges are on paper. The diagram is not.

Part IV — Case B: The Umbrella Interlock (Blue-Coded)

Case B is the same move in a different political coat. On the political left, the cleanest public example of the interlocking-directorate pattern is the Arabella Advisors cluster.

Arabella Advisors is a for-profit management firm headquartered in Washington, D.C. It provides back-office services — accounting, grant administration, compliance — to a group of large fiscal-sponsor 501(c)(3)s. The cluster’s principal tax-exempt entities include:

• New Venture Fund (501(c)(3) — fiscal sponsor)

• Sixteen Thirty Fund (501(c)(4) — sister advocacy vehicle)

• Hopewell Fund (501(c)(3) — fiscal sponsor)

• Windward Fund (501(c)(3) — fiscal sponsor, environment-focused)

• North Fund (501(c)(4) — more recent, smaller)

Each of these entities files its own Form 990. Each has its own board. Each is legally distinct.

Schedule R, filed by each of them, is where the pattern becomes structural.

On Schedule R, each of these funds lists the others as “related organizations.” On Part VII, the boards overlap — individuals sit on multiple of them simultaneously. On Schedule L, the back-office management contracts with Arabella Advisors show up as related-party transactions.

The D.C. Attorney General opened a public investigation in 2023 into the self-dealing question specifically arising from this structure — whether Arabella Advisors’ back-office fees to its own sponsored nonprofits constitute improper related-party transactions. That investigation is a matter of public record.

We take no position on the D.C. AG’s ultimate finding. The structural observation is identical to Case A. The same people, across nominally independent entities, each answerable to a different regulator, no single authority looking at the network as the unit.

Part V — Cross-Example: Four Hats in Public View

A shorter illustration, worked through at speed, will help. It comes from the COUNTRY 404 analytical record.

Jared Craig is an attorney publicly associated with Veterans for America First (VFAF). Public filings and reporting show Craig holding multiple simultaneous roles across the VFAF ecosystem during the 2022–2024 period, including operational and counsel-of-record functions. Public state registration and Delaware LLC filings show Craig’s name on L-Strategies — a consulting-shell LLC — simultaneous with the VFAF roles.

We are not asserting improper conduct. We are making the same structural observation we made in Cases A and B: one person, four hats, each hat attached to a different entity answerable to a different regulator.

The number of hats is not the story. The structure is the story. Once you know what column to read on Form 990 Part VII, and which state to pull the LLC filings from, the hats become countable. And once they are countable, the “we had no contact with that organization” answer becomes a narrower claim than it sounds.

Part VI — What the Regulators Cannot See

Why does this move work?

Because every regulator has a narrow jurisdictional lens.

• The IRS looks at 501(c)(3) compliance and exempt purpose. It does not look at whether a director of the (c)(3) is also a principal of a Delaware LLC that receives the (c)(3)’s consulting fees — unless Schedule L is complete, which is self-reported.

• The state attorney general looks at charitable trust law in a single state. It does not look at the 527 in the next state, the LLC in Delaware, or the foundation in Virginia.

• The FEC looks at electoral activity of 527s and PACs. It does not look at the 501(c)(3) senior fellowships or the think-tank program officer seat.

• The Delaware Secretary of State registers the LLC and nothing more. There is no content review.

• The bar association licenses the attorney — but a counsel-of-record relationship across four affiliated entities is not, by itself, an ethics question.

No single regulator sees the diagram. There is no regulator whose job description even includes the diagram.

The diagram is a citizen responsibility.

Part VII — Why the Diagram Matters

Sophisticated readers will object. “Rotating personnel is how expertise works. A policy expert will naturally serve on several boards in their field. You are describing normal life.”

That objection is true on its face — and insufficient.

A diagram of a single person’s four-seat board portfolio is descriptive. A diagram of the same fifty people rotating across three hundred nominally independent entities is something else. It is the coordination architecture of a sector. And it is visible only when the edges are counted, at scale, across the three-document spine of Form 990.

That is why this module ships with an audit. Not because any single overlap is illegal or even improper. Because the density of the overlap, measured on any well-funded sector, is the single best measure of whether “nominally independent” is actually a claim the sector can defend.

The mechanism is not illegal. The mechanism is knowable. The knowing is the citizen move.

Part VIII — What You Can Do: The 15-Minute Personnel-Overlap Audit

The audit below is the citizen-facing companion to this article. It takes fifteen minutes per 501(c)(3) and tells you whether a sector of ostensibly independent nonprofits is, structurally, the same fifty people wearing three hats each.

Step 1 — Pull the Form 990. Go to ProPublica Nonprofit Explorer (projects.propublica.org/nonprofits) or the IRS Tax Exempt Organization Search. Enter the organization’s name or EIN. Download the most recent publicly filed Form 990.

Step 2 — Read Part VII, Officers, Directors, Trustees, and Key Employees. Every officer, director, and key employee above the compensation threshold is listed by name. Write down every name, the title, and the number in the “compensation from related organizations” column. That column is the hinge: it tells you which officers are paid by more than one entity in the family.

Step 3 — Read Schedule L, Transactions with Interested Persons. Part IV (business transactions involving interested persons) is where a director’s consulting LLC being paid by the nonprofit is supposed to appear. Note the counterparty, the amount, and the nature of the interest.

Step 4 — Read Schedule R, Related Organizations. Schedule R is the organizational family tree. Part I lists related tax-exempt organizations. Part II lists related taxable entities. Write down every related entity, its EIN, and its tax status. This is where the fiscal-sponsor umbrella, the 501(c)(3)/501(c)(4) pair, and the Delaware LLC affiliate surface.

Step 5 — Cross-reference the Part VII names on LinkedIn. For each named officer, director, or key employee, search the name plus the organization on LinkedIn. Record every other organization the person lists as a current affiliation — board seats, senior-fellow or visiting-scholar posts at think tanks, for-profit consulting LLCs where they are listed as principal, government appointments, political-campaign roles.

The result is an edge list. Count the edges. Score the interlock density on the five-point scale in the citizen action card. A score of 4 or 5 is a structural interlocking directorate — a sector that is not a collection of nominally independent organizations, but the same fifty people wearing three hats each.

No new law. No hidden database. No subpoena. Free public data, fifteen minutes per organization, arithmetic. The classification does not distinguish. The public filing does not draw the diagram. You do.

Part IX — The Next Move

The game has nine moves. You have now seen seven.

Module 9: Citizen Action Card, Count the Seats

M3 taught you the Anonymous Donor — DAF stacking. M4 taught you the Russian Doll — entity laddering. M5 taught you Fiscal Sponsorship — borrowed (c)(3) status. M6 taught you the Foreign Principal Pass-Through. M7 taught you Delaware LLC Opacity — the corporate ghost. M8 taught you “Educational” Classification Abuse — the purpose laundering. M9, this one, teaches you Personnel Overlap Coordination — the interlocking directorate.

Module 10 — Schedule B Black Hole. How the IRS Form 990 Schedule B — the donor-identity schedule that was supposed to be the public-benefit audit trail — was made non-public for public charities in 2018, closing the last disclosure path that would have connected money, mechanism, and name. The vault closes.

Once you can read personnel, you can read the whole system. Once you can read Schedule B, you can read who is paying for it.

Sources and Citations

1. Clayton Antitrust Act of 1914, Section 8 — interlocking-directorate prohibition for competing for-profit corporations above statutory thresholds.

2. IRS Form 990 — Part VII (Officers, Directors, Trustees, and Key Employees), Schedule L (Transactions with Interested Persons), Schedule R (Related Organizations and Unrelated Partnerships).

3. ProPublica Nonprofit Explorer — projects.propublica.org/nonprofits.

4. IRS Tax Exempt Organization Search — apps.irs.gov/app/eos/.

5. CourtListener — federal court dockets, free.law/courtlistener.

6. District of Columbia Attorney General — public investigations archive, oag.dc.gov.

7. State corporate registration records — Delaware Secretary of State (icis.corp.delaware.gov), Virginia SCC, California Secretary of State, etc.

8. Form 990 filings cited in case studies — America First Policy Institute, Kash Patel Foundation, New Venture Fund (EIN 20-5806345), Hopewell Fund (EIN 47-5425626), Windward Fund (EIN 46-4950519), Sixteen Thirty Fund, North Fund.

Shadow Patriots · Module 9 · Project Milk Carton · 501(c)(3) · EIN 33-1323547

This article is the journalism deliverable for Module 9. For the citizen audit toolkit — how to walk the three-document spine and score the interlock yourself — see the companion Citizen Action Card in the Shadow Patriots section.

Evidence standard: every factual claim in this article is verifiable through Form 990 filings on ProPublica Nonprofit Explorer, federal court dockets on CourtListener, state corporate registration records, or the D.C. Attorney General’s public filings. PMC does not allege coordination or misconduct; it maps public records.

Bipartisan firewall: Case A (America First network), Case B (Arabella Advisors cluster), Cross-example (Veterans for America First / L-Strategies). The mechanism is the story. The party is not.