Gospel for Asia – Page 51 – Warren Throckmorton

According to U.S. Customs and Border Protection, Smurfing – Dividing Cash Transfers Over $10k to Avoid Detection – Violates U.S. Law

On May 14, I wrote that several Gospel for Asia staff and students had reported to me that they were asked to carry envelopes of cash to India without declaring that cash to U.S. customs. I then reported audio of Gospel of Asia leaders telling staff and School of Discipleship students in a May 14 staff meeting that GFA leaders planned to discontinue the practice of having groups of students take large sums of cash to India in their pack backs or suitcases on group trips. In that staff meeting, a student raised the issue with a question about why GFA leaders required each student on a mission trip to carry an envelope of $4500 cash to India. Amounts ranging from $45,000 to $135,00o (possibly more, I have not interviewed individuals from groups larger than 30) have allegedly been taken to India in this manner. GFA gave no specific reason for asking students to do this, but said their Texas auditor Bland Garvey approved the plan.
However, any cash transfer over $10,000 must be declared via a customs form when leaving the U.S. None of my sources filed any forms on their trips. In addition, GFA on the organization website denies using such means to carry funds to the field, saying (see the underlined sentence):

Obviously and by their own admission, GFA leaders did not follow this guideline.
Wanting to understand more about the law relating to cash transfers out of the country, I contacted by phone and email the media relations department of the Customs and Border Protection agency within the Department of Homeland Security. To the CBP media office, I posed the exact scenario just as the GFA students explained it to me. In response, a CBP spokesperson wrote in an email to describe the relevant U.S. law:

If an individual transports, attempts to transport, or causes to be transported (including by mail or other means) currency or other monetary instruments in an aggregate amount exceeding $10,000 (or its foreign equivalent) at one time from the United States to any foreign place, or into the United States from any foreign place, they must file a report with U.S. Customs and Border Protection (CBP).
This requirement is cited in 31 USC 5316; 31 C.F.R. 103.23 and the Bank Secrecy Act (BSA) of 1970, which identifies the source, volume, and movement of currency and monetary instruments being transported into or out of the United States or being deposited in financial institutions. The BSA aids law enforcement officials in the detection and investigation of criminal, tax, and regulatory violations.
CBP widely publicizes the currency reporting requirements on its website and through other means in order for travelers to be aware of the requirement to file a FinCen Form 105, Report of International Transportation of Currency or Monetary Instruments (CMIR). If unreported currency or monetary instruments are discovered on a person or in his carry-on luggage while boarding a departing aircraft this would constitute a CMIR violation.
Dividing currency amongst travelers requires the filing of a CMIR for the entire amount as intentionally aggregating currency exceeding $10,000 to evade reporting is against the law.
As a result of international drug trafficking, the United States and much of the world strengthened currency reporting requirements by enacting laws to counter money laundering schemes such as “Smurfing”. Smurfing is a form of structuring, or dividing large amounts of currency or monetary instruments between individuals within an organization, with each person or package carrying an amount under $10,000 to circumvent reporting requirements. Structuring, including “smurfing”, is a violation of 31 USC 5324. (emphasis added)

I then asked the public affairs office at Immigration and Customs Enforcement how their office handles such crimes. A spokesperson told me that no information could be given about current investigations, but persons who wish to pass along information can use the ICE tip line: http://www.ice.gov/tipline.
I also request that former/current staff, students or others who carried cash for GFA contact me via email (click the link).

Believers' Church/Gospel for Asia May Lose Possession of Indian Rubber Plantation

Although not your usual ministry tool, in 2005 Believers’ Church (which is synonymous with Gospel for Asia in India) acquired a working rubber plantation called Cheruvally Estate. The 2263 acre estate was purported to be a money making venture to help make Believers’ Church self-sufficient and according to reports in the Indian press cost just over $14.3 million.
Today, the Indian government is poised to take control of three properties once belonging to Harrison Malayalam, India’s largest producer of rubber. One of those properties is the Cheruvally Estate. It is not clear what if any compensation Gospel for Asia will receive. The government claims that Harriason Malayalam never had the right to sell the land in the first place.
The property has been in dispute since it was first acquired.

Former Speaker of the House Dennis Hastert Charged with Structuring Payments

Although not normally of interest to me, I took a look at the hush money charges against former Speaker Dennis Hastert because of the additional wrinkle that he structured his bank withdrawals to avoid federal requirements to report those actions.
Such structuring is illegal whether one is an misguided creation science proponent, as in the case of Kent Hovind, or a mission organization moving over $10,000 out of the country without declaring it at customs, as former and current students and staff at Gospel for Asia have alleged.
I have learned a new term for using multiple people to move money to evade declaration – “smurfing.” Papa smurf arranges for all the little smurfs to carry the load, in the case of GFA envelopes of cash in their backpacks or suitcases, until they arrive at their destination.
Watch for more on this…

How Much Does it Really Cost to Sponsor a Child with Gospel for Asia?

Yesterday, I pointed out that the expenditure of foreign funds by GFA in the fiscal year ending on March 31, 2014 for the support of children enrolled in the Bridge of Hope program seemed quite low, estimated at around $105 per year. Today, I want to point out that GFA’s request for child sponsorship in India is about one-third of what it is here in the U.S. and that the actual costs are even lower than that.
On the U.S. website, GFA requests $35/month to sponsor a child:

It only takes $35 a month to give a child everything they need—school supplies, a daily meal, medical checkups and more—to attend a Bridge of Hope Center. 100% of your sponsorship is sent to the field to support your child.

However, on the GFA/Believers’ Church Indian website, the cost is INR 800/month or about $12.50 in U.S. dollars per month. That’s quite a discount. The sponsorship page promises:

Your sponsorship of Rs. 800 per month provides [child’s name]:

An Education

A nutritious meal each day

A yearly medical checkup

Basic school & hygiene needs

I have also seen GFA budget documents which tell a more surprising story.* The actual cost during fiscal year ending 2014 to support one child in a GFA Bridge of Hope center in India was just under INR 500 or around $8.20 per month per child. This paid for the administration of the program, food purchases, and all child services. In fact, the actual items given to each child (school supplies, clothes, hygiene supplies and gifts) only cost INR 140 per child or $2.20 per month.
At that rate, Americans who send $35/month to GFA for a child sponsorship could actually support 4 children. Or GFA could keep the excess in a bank and draw interest on the balance as they appear to be doing. As I noted yesterday, GFA spent over $6 million in foreign contributions on Bridge of Hope expenses in FYE 2014 but had in the neighborhood of $25 million designated for “the welfare of children” sitting in a bank drawing interest at the same time.
GFA has to report that interest (the banks do as well) and all four GFA controlled organizations accumulated $4.2 million on the money in savings accounts by the end of FY 2014.
GFA says “100% of your sponsorship is sent to the field to support your child.” Perhaps this statement should be reworded. The money is sent to the field but a lot of it apparently ends up in a bank on the field.
It is past time for GFA to end the silence and address this matter as well as others which have come out in recent weeks.

*I have the documents but don’t have permission to publish them.

How Gospel for Asia in India Spent Foreign Contributions in FYE 2014

Each year registered charities in India are required by law to disclose how they spend foreign contributions. Out of curiosity, I examined Gospel for Asia’s FC-6 report for the fiscal year that ended on March 31, 2014 (most recent data available). Below is a chart that combines the money spent from contributions from GFA (U.S., Germany, Australia, New Zealand, etc.) in U.S. dollars to GFA-India, Believers’ Church, Love India Ministries and Last Hour Ministries.* GFA also sends funds to affiliates in Nepal, Myanmar, Sri Lanka, and Bangladesh. According to GFA’s financial statement ending in 2013, India receives 96% of the contributions from the U.S.

The largest expense is construction and administration of Believers’ Church Medical College Hospital. According the hospital website, “Believers Church Medical College Hospital is a healthcare project of Believers Church. The Church is dynamically involved in various nation-building social and educational projects, healthcare initiatives, charitable activities, community development programs, rehabilitation projects and relief works. Dr. K.P. Yohannan, Metropolitan of Believers Church is the patron of the hospital and Dr. George Chandy is leading the project.”
About $1.9 million for the BCMCH came from GFA affiliates in Germany, Australia, and the UK, with the rest coming from GFA in the U.S.
If one includes the hospital, two-thirds of the funds — just over $35 million — are spent on support for ministries of Believers’ Church in India. At least one pastor recently announced that he gave up his support for GFA because he learned that he was really supporting a church he didn’t feel comfortable supporting.

A prominent expense is for welfare of children which includes school fees, food, and funding for the Bridge of Hope program. According to GFA’s most recent financial statement, they claim that 60,000 children are enrolled in the BoH program.

That works out to only $105 per child per year.

According to the forms filed with the Indian government, there is a combined balance of just over $23.5 million designated for “welfare of children” sitting in GFA-related accounts. I cannot understand why so much money is sitting in accounts when GFA claims the need is so great (and I have no reason to doubt that the need is great).

GFA promises that “Gospel for Asia sends 100 percent of the money you donate for work on the mission field to the field. Nothing is taken out for administrative expenses.” While that may be true for those working in administration in the U.S., it is not true for GFA, Believers’ Church, Love India Ministries, and Last Hour Ministries.

As I noted in a prior post, GFA has stopped replying to my questions. However, I extend an ongoing invitation to correct anything I write which they believe to be incorrect. There is a link in the footnote below if readers want to check these figures, and I am open to any additional evidence.

*These reports are available online (enter year and the state of Kerala). These four charities were chosen because they all received money from Gospel for Asia’s Texas organizations. To see pdfs of each page, click the links: Gospel for Asia, Believers’ Church, Last Hour Ministries, Love India Ministries. Historical exchange rates can be found at Oanda.com.