When Your Charity Dollars Go Overseas, Can You Follow the Money?
Sep 24, 2026
An earthquake devastates a community. A hurricane leaves thousands of families without homes. War forces people to flee with little more than what they can carry. Or you see a photograph of a hungry child accompanied by an appeal explaining how your donation can provide food, medicine, clean water, or a safe place to sleep.
You want to help. So you donate.
Maybe you give $25 or $50. Maybe you make a much larger contribution. Either way, you gave that money for a reason, and you should be able to find out enough about where it went to make an informed decision about whether to give to that charity again.
If your donation supports charitable work outside the United States, however, following your dollars can become surprisingly difficult.
The IRS requires charities with certain foreign activities to file Schedule F with their annual Form 990. The schedule is intended to provide information about activities conducted outside the United States, including grants and other assistance provided to foreign organizations.
You might reasonably assume that if a U.S. charity sends a large grant to an organization overseas, its public tax filing would tell you two basic things: What country did the money go to, and what organization received it?
In most cases, Schedule F tells you neither.
A charity can transfer millions of dollars overseas and report that money as going to a broadly defined geographic region for a generally described charitable purpose without publicly identifying the organization that received it or even the country where that organization is located.
So you may be able to learn that millions of dollars went somewhere in “Sub-Saharan Africa,” “East Asia and the Pacific,” or “Europe.” But you may not be able to determine who actually received the money.
And if you don’t know who received it, how are you supposed to find out what happened to it?
You Can’t Research an Organization You Can’t Identify
This is where what might sound like an obscure tax-reporting issue becomes a very practical problem for you as a donor.
If you know the identity of an organization receiving a substantial charitable grant, you can research it. You may be able to learn who runs it, how it spends its money, whether it publishes audited financial statements, whether it has relationships with the U.S. charity that funded it, or whether it has been the subject of regulatory or legal action.
Journalists, researchers, charity watchdogs, and regulators can do the same thing.
But you cannot research an organization whose identity you don’t know.
Schedule F requires charities to report certain information about grants and other assistance to foreign organizations. For each organization receiving more than $5,000 in reportable grants or assistance during the year, the charity generally reports information including the geographic region, amount and purpose of the grant, manner of cash disbursement, and certain information concerning noncash assistance.
The IRS instructions, however, specifically tell charities not to complete the columns for the recipient organization’s name and identifying information.
Even the country is not necessarily disclosed because Schedule F uses broad geographic regions rather than requiring country-level reporting.
That can leave you knowing that a substantial amount of charitable money left the United States without knowing where it actually landed.
Congress Is Looking at Nonprofit Transparency Again
There are signs that Congress is taking a renewed interest in making financial activity involving tax-exempt organizations more transparent.
In 2026, the House Ways and Means Committee advanced the Foreign Funding Transparency Act, legislation that would require tax-exempt organizations to report additional information about contributions they receive from foreign nationals. The Committee also advanced separate legislation requiring greater disclosure of certain fiscal sponsorship arrangements.
These proposals address different transparency problems than the one you encounter when trying to follow a U.S. charity’s grants to organizations overseas. But the underlying principle is similar: when money moves into or through tax-exempt organizations, sufficient information should be available to understand where that money came from, where it went, and who ultimately controlled or benefited from it.
Congress has considered the foreign-grant side of this problem before.
In 2024, the House Ways and Means Committee unanimously advanced the Foreign Grant Reporting Act by a vote of 38–0. The legislation would have required tax-exempt organizations to disclose significantly more information about grants and other assistance provided to foreign entities, including the recipient’s name and address, the aggregate amount it received during the year, and information concerning its charitable status.
The legislation did not ultimately become law.
CharityWatch believes the current congressional focus on nonprofit financial transparency makes this a particularly good time to revisit it.
If Congress believes the public needs better information about foreign money flowing into U.S. tax-exempt organizations and about money moving through fiscal sponsorship arrangements, it is reasonable to ask why you should not also have better information about charitable dollars raised in the United States and sent to organizations overseas.
The goal should not be disclosure for disclosure’s sake. Legitimate security concerns involving foreign recipients still need to be protected. But the current system often leaves you with too little information to follow substantial charitable grants after they leave the United States.
Congress has already considered one potential solution. It may be time to take another look.
What If the Organization That Receives the Money Isn’t the One That Spends It?
There is another complication you may never have considered.
The first foreign organization receiving your charity’s money may not be the organization that ultimately uses it to provide charitable services.
Imagine that a U.S. charity raises $5 million from donors like you and transfers it to an international affiliate. That organization transfers the money to a regional organization. The regional organization then makes grants to local organizations that actually provide food, medical care, shelter, education, or other services.
Where did your donation go?
Knowing that $5 million left the U.S. charity is only the beginning of the answer.
You would probably also want to know where it went next, whether another organization took a portion of it before passing the remainder along, and which organizations ultimately used the money to carry out the charitable work you intended to support.
The existing Schedule F reporting framework may give you very little ability to follow that chain.
This is especially important when you donate to a U.S. charity that functions primarily or substantially as a fundraising organization and then transfers significant resources to a foreign organization, affiliate, or international network.
CharityWatch may be able to analyze how efficiently the U.S. charity raises your donation and determine how much money it transfers overseas. But if we cannot identify the organizations ultimately receiving and spending those funds, there are limits to what we can independently tell you about how efficiently your donation was ultimately used.
This Chart Reflects Nonprofits That Function Primarily As Fundraising Arms
For Their Related Organizations
To see CharityWatch’s detailed explanation for why we deemed a particular organization “Not Ratable,” click on the nonprofit’s name and navigate to the Analysts’ Notes section.
| Charity | CharityWatch | Charity Navigator | Candid Transparency Seal |
|---|---|---|---|
| ActionAid USA | Not Ratable | 88% / 3 Stars | Platinum |
| Against Malaria Foundation | Not Ratable | 91% / 4 Stars | No Seal |
| American Brain Foundation | Not Ratable | 96% / 4 Stars | Platinum |
| American Friends of Magen David Adom | Not Ratable | 100% / 4 Stars | No Seal |
| Christian Advocates Serving Evangelism | Not Ratable | 86% / 3 Stars | Silver |
| Disabled American Veterans (DAV) Charitable Service Trust | Not Ratable | 96% / 4 Stars | Platinum |
| Disabled American Veterans (DAV) National Service Foundation | Not Ratable | Not Rated | Gold |
| GlobalGiving Foundation | Not Ratable | 96% / 4 Stars | No Seal |
| Greenpeace Fund | ? / Warning: See Analysts’ Notes | 65% / 2 Stars; Increased Caution | Gold |
| Humanity & Inclusion | Not Ratable | 85% / 3 Stars | Platinum |
| League of Conservation Voters Education Fund | Not Ratable | 84% / 3 Stars | No Seal |
| Plan International USA | Not Ratable | 97% / 4 Stars | Platinum |
| United States Association for UNHCR (USA for UNHCR) | Not Ratable | 92% / 4 Stars | No Seal |
| USA for UNFPA | ? / Warning: See Analysts’ Notes | 95% / 4 Stars | Platinum |
| Veterans of Foreign Wars Foundation | Not Ratable | 97% / 4 Stars | Platinum |
| World Animal Protection | Not Ratable | 93% / 4 Stars | Platinum |
| World Food Program USA | Not Ratable | 92% / 4 Stars | Gold |
| World Jewish Congress (American Section) | Not Ratable | 87% / 3 Stars | Gold |
| World Villages for Children | Not Ratable | 93% / 4 Stars | Platinum |
The chart above contains select examples of nonprofits to which CharityWatch (CW) has assigned “Not Ratable” ratings as of September 24th, 2026 based on our criteria. Charity Navigator’s (CN) ratings and Candid’s (Guidestar’s) seals were retrieved from those websites in September 2026 and reflect each nonprofit’s current rating or transparency seal as of the date retrieved. Visit charitywatch.org, charitynavigator.org, and (Candid) guidestar.org to view the most currently published ratings and profiles. NOTE: Candid’s seals are based on charities’ self-assessments and do not include a financial measurement of how efficiently a charity uses the donations it receives. Charity Navigator’s ratings are automated using data pulled from unaudited charity tax Forms 990.
Could Your Money Come Back to the United States?
The differing disclosure requirements for domestic and foreign grants create another potential gap: circular or multi-step transactions can become extraordinarily difficult for you to follow.
If a U.S. charity makes a reportable grant directly to another U.S. organization, Schedule I generally requires the charity to identify the recipient and report the amount of the grant. That allows you to see that Organization A gave money to Organization B.
Foreign organizational grants are treated differently. Schedule F requires information about reportable foreign grants but generally does not publicly identify the foreign organization receiving the money.
Now imagine that U.S. Charity A transfers money to Foreign Organization B, which subsequently transfers some of those funds to U.S. Charity C.
There may be entirely legitimate reasons for money to move this way. And if the organizations are subject to independent financial statement audits, their auditors may examine documentation supporting material grants and other transactions. GAAP may also require additional disclosures when related organizations or related-party transactions are involved.
But an audit does not necessarily make the complete path of those funds publicly traceable. GAAP generally does not require a charity’s audited financial statements to identify every unrelated organization receiving a grant and the amount it received. As a result, you may be able to see pieces of the activity in different organizations’ financial reporting without having enough identifying information to determine that the transactions are connected.
The differing Schedule I and Schedule F disclosure requirements therefore create the potential for circular transactions to circumvent the transparency that Schedule I would otherwise provide. The foreign organization in the middle of the chain can remain unidentified in the U.S. charity’s public tax filing, making it difficult or impossible to connect the outgoing foreign grant with funds that subsequently return to another U.S. organization.
This does not mean that anything improper has occurred or that the organizations themselves or their auditors lack records documenting the transactions. The problem is one of public accountability: you cannot follow the complete path of charitable dollars when some of the organizations along that path cannot be identified from the publicly available reporting.
The Charity May Know. You Still May Not.
Here’s where the reporting system becomes particularly frustrating.
The IRS asks charities whether they maintain records substantiating foreign grant amounts, recipients’ eligibility, and the criteria used to select recipients. Charities must also describe how they monitor grants and re-grants to help ensure that charitable resources are used for their intended purposes and are not diverted.
Those are sensible requirements.
If a charity sends a substantial grant overseas, you would expect it to know who received the money. You would expect it to perform appropriate due diligence before making the grant. And you would expect it to monitor the grant afterward.
But Schedule F generally does not give you enough identifying information to independently check many of those representations.
In effect, you may be told: We know who received your money. We determined that the organization was eligible to receive it. We monitor what happens to it.
But you may not be told who “they” are.
That asks you to place considerable trust in the charity while denying you some of the basic information you would need to verify what it is telling you.
And that undermines one of the most important reasons Form 990 is publicly available in the first place: so you don’t simply have to take a charity’s word for how it operates.
Contrast With Domestic Grants
The contrast with domestic charitable grants is striking.
Schedule I of Form 990 generally requires charities making reportable grants to domestic organizations and government entities to disclose identifying information about the recipient, along with information such as the amount and purpose of the grant.
That gives you somewhere to start.
You can research the recipient. A journalist can investigate it. A charity watchdog can examine its financial reporting. Researchers can identify relationships among organizations. Regulators and members of the public may discover conflicts of interest, unusual transactions, regulatory actions, or other information relevant to understanding how charitable resources are being used.
Much of that independent scrutiny becomes impossible when comparable charitable dollars are transferred to a foreign organization whose identity and even country are not publicly disclosed.
Your charitable dollars can therefore become substantially less traceable simply because they crossed an international border.
There Is a Legitimate Reason for Some Secrecy
There is an important reason the IRS does not simply require every foreign recipient to be publicly identified.
When the redesigned Form 990 and Schedule F were being developed, concerns were raised that publicly identifying certain foreign recipients could endanger organizations or individuals conducting sensitive work overseas.
Those concerns are legitimate.
Imagine a small humanitarian organization working in an active conflict zone, or a human rights organization operating under a hostile government. Publicly identifying that organization as the recipient of substantial funding from a U.S. organization could potentially expose its employees or beneficiaries to terrorism, kidnapping, political violence, persecution, or other dangers.
You don’t need to know the name of a vulnerable organization badly enough to put someone’s life at risk.
But protecting people facing genuine danger does not require treating every foreign grant as though it presents the same danger.
A multimillion-dollar grant to a large, established institution operating in a stable country presents a very different disclosure risk from a grant to a small humanitarian organization operating in a war zone.
Yet Schedule F’s existing disclosure rules make relatively little distinction between those circumstances.
The result is essentially an all-or-nothing approach. Information that could help you follow your charitable dollars can be withheld even when there may be no identifiable security reason for withholding it.
You Shouldn’t Have to Choose Between Security and Accountability
Protecting vulnerable foreign organizations and giving you meaningful information about where your donations go are not mutually exclusive goals.
Schedule F could provide considerably more useful information without publicly identifying every foreign recipient in every circumstance.
At a minimum, significant foreign organizational grants could generally be reported separately by recipient and country rather than leaving recipients unidentified within broad geographic regions.
When a legitimate security concern makes publicly identifying a recipient inappropriate, an anonymized identifier could allow you and others to follow grants to the same organization over time without revealing its identity.
The key would be using the same identifier from year to year.
Suppose you saw that “Foreign Recipient 0174” received $800,000 from a charity one year, $2.1 million the next year, and $3.4 million the year after that.
You still wouldn’t know the recipient’s identity. But you would know that the same organization was receiving increasingly large amounts of charitable resources.
That is meaningful information you don’t have when the identity behind each reported grant remains undisclosed.
Is Your Money Being Used or Passed Along Again?
There is another basic question Schedule F could help you answer:
Is the organization receiving your charity’s money actually going to use it, or is it going to pass some or all of that money along to another organization?
Schedule F already requires charities to provide information about the purpose or ultimate use of reportable foreign grants. It also requires charities to describe generally how they monitor foreign grants and re-grants to help ensure that charitable resources are used for their intended purposes and are not diverted.
Those are useful disclosures. But they still may not tell you something fundamental about the path your donation takes.
For each reportable foreign organizational recipient, Schedule F could clearly indicate whether that organization is expected to use the funds to conduct its own charitable programs or provide assistance directly to individuals, or whether some or all of the money is expected to be re-granted or transferred to another organization.
If the money is expected to move again, you should be able to see that.
Schedule F could also provide standardized information about whether the foreign recipient is related to the U.S. charity and whether officers, directors, trustees, key employees, or related organizations of the U.S. charity have governance or financial relationships with the recipient.
Imagine that the charity you support transfers $5 million to an international organization, which sends $4 million to a regional affiliate, which then distributes $3 million among local organizations actually performing the charitable work.
Those distinctions matter if you are trying to understand where your donation ultimately went.
Simply knowing the first organization in the chain doesn’t necessarily tell you who ultimately used the money to provide the food, medicine, shelter, education, disaster relief, or other charitable services that inspired you to give in the first place.
Would This Create Too Much Work for Charities?
Whenever additional financial reporting is proposed, it is reasonable to ask whether the benefit justifies the burden.
But consider what a charity must already do when it sends $1 million to a foreign organization.
It needs to know who is receiving the money. It needs to know where to send it. It needs to record the transaction in its accounting system and maintain supporting documentation. It should know why the grant was made and monitor it as appropriate.
If the charity has independently audited financial statements, significant transactions must also be supported by accounting records and may be subject to audit procedures involving grant agreements, bank or wire-transfer records, governing-body approvals, correspondence, grantee reports, or other documentation.
Putting a limited amount of information the charity already maintains into standardized fields on Schedule F is fundamentally different from requiring it to create an entirely new recordkeeping system.
There will be exceptions. A charity making thousands of small assistance payments during a humanitarian emergency faces different administrative challenges from one making several multimillion-dollar grants to large institutions. Reasonable thresholds and aggregation rules can account for those differences.
But if a charity sends $100,000, $1 million, or $10 million of donated money to another organization, knowing who received it and where it went is not a trivial detail.
It is fundamental information about what happened to the charitable resources entrusted to that organization.
Why Can’t We Just Rely on the IRS?
You might reasonably wonder why any of this should be your responsibility.
After all, doesn’t the IRS oversee charities?
It does. But the IRS administers federal tax laws across an enormous universe of taxpayers and tax-exempt organizations. It cannot realistically examine every charity and trace every foreign grant.
That’s one reason public disclosure matters so much.
Form 990 allows oversight to extend far beyond the IRS. Journalists investigate charities. Researchers analyze nonprofit finances. State regulators identify potential problems. Watchdog organizations like CharityWatch scrutinize financial reporting. And you can use publicly available information to make more informed decisions about where to give.
Sometimes that outside scrutiny uncovers information that ultimately becomes useful to government regulators or law enforcement.
But someone first needs enough information to recognize that there is something worth investigating.
If Schedule F tells you that millions of dollars went somewhere within a vast geographic region but doesn’t tell you the country, recipient, whether that recipient has relationships with the U.S. charity, or whether the money was subsequently transferred somewhere else, meaningful public oversight becomes extraordinarily difficult.
You Gave the Money. You Deserve Meaningful Accountability.
When you respond to an appeal after an earthquake, a war, a famine, or another humanitarian crisis, you may be making that decision quickly and emotionally.
That’s not necessarily a bad thing. Compassion is one of the reasons people give.
But compassion shouldn’t require blind trust.
Once the immediate crisis has passed, you should be able to look back and learn enough about what happened to your donation to decide whether the charity deserves your support the next time it asks.
There will always be circumstances in which protecting people requires withholding sensitive information. A responsible disclosure system should accommodate those circumstances.
But exceptions designed to protect people facing genuine threats should not unnecessarily prevent accountability for foreign charitable spending more broadly.
Your charitable dollars do not become less deserving of transparency simply because they cross an international border.
Schedule F already recognizes that foreign charitable activities warrant additional reporting. The problem is that the information it currently provides can stop just when the questions you care about become most important.
Who received the money? Where did it go next? Who ultimately used it? And what did your donation accomplish?
Schedule F should help you answer those questions.
Too often, it tells you where the trail disappears.
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