Category Archives: FBI

Facts on TWO Lists, Watch List and Terror List

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Most Wanted Terrorists

Select the images of suspected terrorists to display more information.

JABER A. ELBANEH

 

How Does the FBI Watch List Work? And Could It Have Prevented Orlando?

Wired:  OF ALL THE details investigators have uncovered about Orlando terrorist Omar Mateen, perhaps the most infuriating is the fact that he spent 10 months on a government watch list, yet had no trouble buying an assault rifle and a handgun.

Authorities placed Mateen on a watch list in May 2013 after coworkers at the Florida courthouse where he was a security guard told authorities he boasted of connections to al Qaeda and other terrorists organizations. He remained on the list for 10 months, and FBI Director James Comey told reporters this week that during that time the agency placed Mateen under surveillance and had confidential sources meet with him.

But the feds removed Mateen from the list in March 2014, after concluding that he had no significant links to terrorism beyond attending the same mosque as an American suicide bomber who died in Syria. “We don’t keep people under investigation indefinitely,” Comey said, adding that he doesn’t see anything that his agents should have done differently.

Comey didn’t identify the list Mateen was on, but an unnamed official told the Daily Beast that he was in two databases, the Terrorist Identities Datamart Environment database and the Terrorist Screening Database, more commonly called the terrorist watch list.

Here’s a look at what the lists are and how someone gets their name on one.

What is the Terrorist Watch List?
The Terrorist Screening Database was created in 2003 by order of a Homeland Security Presidential Directive. The database includes the names and aliases of anyone known to be, or reasonably suspected of being, involved in terrorism or assisting terrorists through financial aid or other ways. The federal Terrorist Screening Center maintains the database, and an array of government agencies nominate people to it through the National Counter Terrorism Center.

Some of the information in the database originates with the Terrorist Identities Datamart Environment, also called TIDE. That list contains classified data collected by intelligence agencies and militaries worldwide, but anything passed on to the terrorist watch list is first scrubbed of classified info. In 2013, TIDE had 1.1 million names in it.

The State Department checks all visa applicants against the watch list. The TSA’s No-Fly list and Selectee List, which identifies people who warrant additional screening and scrutiny at airports and border crossings, are also derived from the watch list. But it is most often used by law enforcement agencies at all levels to check the identity of anyone arrested, detained for questioning, or stopped for a traffic violation. The FBI calls it “one of the most effective counterterrorism tools for the US government.”

Entries in the database are coded according to threat level to provide law enforcement with instructions on what to do when they encounter a suspected terrorist who is on the list. According to a 2005 inspector general report (.pdf), of some 110,000 records in the database that the IG reviewed, 75 percent of them were given handling code 4, considered the lowest level, and 22 percent were given handling code 3. Only 318 records had handling codes 1 or 2. A description of what each level means is redacted in the publicly released version of the document, but a note indicates that people are usually given code 4 when they are either just an associate of a suspected terrorist and therefore may not pose a threat or if there is too little information known about the individual to categorize them at a higher level.

Appearing in the database doesn’t mean you’ll be arrested, denied a visa, or barred from entering the country. But it does mean your whereabouts and any other information gleaned from, say, a traffic stop, will be added to the file and scrutinized by authorities.

What’s the Criteria for Getting on the Watch List?
According to a 2013 watch list guideline produced by the Terrorist Screening Center and obtained by The Intercept, engaging in terrorism or having a direct connection to a terrorist organization is not necessary for inclusion on the list. Parents, spouses, siblings, children and “associates” of a suspected terrorist can appear on the list without any suspicion of terrorist involvement. “Irrefutable evidence” of terrorist activity and connections is also not necessary, the document states. Reasonable suspicion is sufficient, though this isn’t clearly defined.

“These lists are horribly imprecise,” a former federal prosecutor, who asked to remain anonymous, told WIRED. “They are based on rumor and innuendo, and it’s incredibly easy to get on the list and incredibly difficult to get off the list. There’s no due process for getting off the list.”

The guidelines also reveal that the Assistant to the President for Homeland Security and Counterterrorism can temporarily authorize placing entire “categories” of people on to the No-Fly and Selectee lists based on “credible intelligence” that indicates a certain category of individuals may be used to conduct an act of terrorism.

“Instead of a watch list limited to actual, known terrorists, the government has built a vast system based on the unproven and flawed premise that it can predict if a person will commit a terrorist act in the future,” Hina Shamsi, head of the ACLU’s National Security Project, told The Intercept. “On that dangerous theory, the government is secretly blacklisting people as suspected terrorists and giving them the impossible task of proving themselves innocent of a threat they haven’t carried out.”

What Is the No-Fly List?
This narrower list, derived from the terrorist watch list, includes people who haven’t done anything to warrant being arrested, yet the government deems too dangerous to allow onto commercial aircraft. Mateen reportedly did not appear on this list. The list included 2,500 individuals when Homeland Security chief Michael Chertoff released the tally for the first time in 2008. Six years later, Christopher Piehota, director of the Terrorist Screening Center, told a House subcommittee it had 64,000 names on it. That sounds like a lot, but the list includes dead people and multiple versions of names.

The No-Fly list is also notorious for ensnaring the innocent whose names resemble those of suspected terrorists. Senator Ted Kennedy, for example, was repeatedly prevented from boarding planes because his name matched that of someone on the list.

What Kind of ‘Terrorist Activity’ Gets You on the Terrorist Watch List?
Obvious things like using or possessing weapons of mass destruction will land you on the terrorist watch list. So will committing violence at an international airport, or engaging in arson or other types of destruction of government property if it’s done to intimidate, coerce, or influence people or government policy. But computer hacking can also get you included if it damages a computer used for interstate or foreign commerce or ones that are used by a financial institution or the government, if the hack was intended to influence people or policy.

Just as there are those on the list who shouldn’t be, so too are there people who don’t make it onto the list who should. Umar Farouk Abdul Mutallab, the so-called “underwear bomber” who attempted to detonate explosives aboard a flight from Europe in 2009, wasn’t on the terrorist or No-Fly lists, even though his father alerted the US embassy in Nigeria to his radicalization. He did appear in the TIDE database, but because that information is classified, it didn’t make it to the No-Fly list or the Amsterdam airport where he boarded his flight.

A 2007 inspector general’s audit of the terrorist watch list found that in 15 percent of terrorism cases the inspector’s office reviewed, the FBI failed to add suspects in the cases to the list.

Can Someone on the List Buy a Gun from a Federally Licensed Seller?
Appearing on the terrorist watch list wouldn’t necessarily prevent someone from purchasing a gun; it simply means law enforcement is alerted if you apply to purchase a weapon. So even if he’d been included on the list at the time he bought his weapons, Mateen would still have had no trouble purchasing his Sig Sauer MCX rifle and Glock 17 handgun.

There are ten criteria, however, that do prevent people, whether they’re on the terrorist watch list or not, from buying firearms from a licensed seller. They include a felony conviction, being an undocumented immigrant and being deemed mentally unstable by a court.

Government Accountability Office data recently released to California Democratic Senator Dianne Feinstein indicate that 2,477 people on the watch list attempted to buy a firearm between February 2004 (when authorities started checking gun sale purchases against the list) and the end of 2015. Of those, 2,265 of the transactions were allowed.

Feinstein proposed legislation last year to prevent known or suspected terrorists on the watch list from obtaining a gun license or buying a weapon from a licensed seller. The Senate rejected the proposal one day after the San Bernadino attack, but Feinstein said she hopes the Orlando massacre will give the bill new life. This week, Senate Democrats filibustered until Republicans agreed to consider such legislation.

But barring anyone on the list from buying a gun can create a different problem. “If you prevent people on the list from buying a weapon, then an attempt to buy the weapon can alert the person that they’re on the list,” the former prosecutor told WIRED. “So you’re aiding the terrorist [with that information].”

 

How Many People Are on the Terrorist Watch List?
The exact number is unclear because the list includes many aliases and variations of names, and officials often confuse the number of names that are on the list and the number of unique individuals that are on it. In 2011, for example, more than 1 million names appeared on the list, but just 400,000 of these represented unique individuals. In 2014, the Terrorist Screening Center’s Piehota told lawmakers the list included 800,000 names.

About 99 percent of names nominated to the list each year are accepted, and the number of nominations grows annually. In 2009, authorities nominated 227,932 known or suspected terrorists. In 2013, the number reached nearly 469,000.

Most of the people on the watch list are not US citizens; placing a citizen or permanent US resident on the list is supposed to require a higher standard, such information “from sources of known reliability or where there exists additional corroboration or context supporting reasonable suspicion,” according to the guidelines The Intercept obtained.

How Do You Get Off the Terrorist Watch List or No-Fly List?
This remains a source of great controversy. People on these lists rarely know how or why they landed there, and the process of removal can be convoluted. In 2007, the Department of Homeland Security created a redress program through which people can challenge their inclusion on the No-Fly list. It works well enough for anyone mistakenly added to the list, but provides little help to those whom the government says are on the list for legitimate reasons but won’t disclose the reasons.

The FBI will remove people from the terrorist watch list after closing an investigation that failed to uncover terrorist activity or connections. This is exactly what happened to Mateen, which has angered some officials. “The only way you should get off the list is if they no longer believe you’re a threat,” Senator Lindsey Graham said during a Capitol Hill briefing after the Orlando shooting. “It should have nothing to do with not being able to prove a crime.”

But the FBI was simply following procedure when it dropped Mateen from the watch list, after being criticized in the past for not promptly removing people when cases get closed. An inspector general’s report in 2007 found that the FBI failed to remove names in a timely manner in 72 percent of the cases the Bureau closed for lack of evidence. A 2009 audit found that the situation had not improved, prompting lawmakers like Vermont Democratic Senator Patrick Leahy to criticize the Bureau.

 

The bigger question then, is not why was Mateen removed from the list, but why did the FBI close its investigation of him prematurely? “To me, there was enough here to keep it in some sort of a status,” New York Republican Representative Peter King said during the Capitol Hill briefing this week.

But with so many suspects on the watch list, authorities must be judicious in choosing which ones to pursue. “Our work is very challenging,” Comey said this week. “We are looking for needles in a nationwide haystack. But we’re also called upon to figure out which pieces of hay might someday become needles.”

There is no specific criteria guiding when to close a case related to the terrorist watch list. “It’s a judgment call,” says the former prosecutor. “It depends on the seriousness of the allegations and the result of the investigation. It’s [a matter of whether an] investigator is convinced, more than anything else, that ‘We better keep looking at this guy.’”

In the case of Mateen, investigators surveilled him, looked into his background, and performed a “dangle,” the former prosecutor says. That’s when a confidential informant meets with a suspect. “They feel the guy out to try to figure out if he’s real or if he’s just all talk,” he says. They may do this by asking if he’s interested in purchasing weapons or materials to make a bomb. “They may try the dangle operation two or three times, and if he shows no genuine interest in activity, if he doesn’t take the bait, then they say after a period of time, we’ve got no reason to believe this person is something other than an angry young man … and they close the investigation.”

Still, a case is never truly closed. Authorities can re-open it if something piques their interest—like say, a suspect buying weapons. That would have been sufficient to get Mateen back on the FBI’s radar. But because he wasn’t on the watch list, the FBI didn’t know what he was up to. And that’s what lawmakers are saying they want to fix.

 

 

 

Omar Terrorist Went to Saudi via NYU

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The boom happened already, how long has it been going on? And what are they really teaching and how is this promoted? It is called Tablighi Jama’at.

 

Harvard? Uh huh:

The Prince Alwaleed Bin Talal Islamic Studies Program At Harvard University

The Prince Alwaleed Bin Talal Islamic Studies Program promotes the scholarly study of Islam and the Muslim world in a broadly interdisciplinary context.

Department of Middle Eastern Studies

Established in 1997, the program in Islamic Studies is undergirded by the University’s belief that Islamic religion, culture and history are important areas of inquiry, and that students should be able to pursue such inquiry as a part of their undergraduate education.  At present, the University of Texas at Austin is one of only a handful of four-year institutions in the U.S. that offer Islamic Studies as an independent major; it is the only such program in the state of Texas.

Islamic Studies in U.S. Universities

As in Europe, Islamic studies in the U.S. originated in the tradition of Orientalist scholarship and Christian theology, with its strong textual emphasis, but it has gradually expanded to overlap with Middle East area studies as well as a number of humanistic and social science disciplines, especially religious studies.1 Over the past several decades, and especially since 9/11, scholarly interest in Islamic studies has mushroomed. This interest is visible in the number of doctoral dissertations produced on Islam and Muslims over the past half-century. Read more from Charles Kurzman and Carl W. Ernst University of North Carolina at Chapel Hill.

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Orlando Shooter Traveled to Saudi Arabia on Trip Organized By NYU Center

University spokesman says Omar Mateen and three others thought to be family members joined tour group on 2012 trip

By: Damian Paletta

WSJ: An Islamic center in New York determined Thursday that Orlando shooter Omar Mateen was among a group of roughly 80 people who traveled to Saudi Arabia in 2012 as part of an annual pilgrimage facilitated by the organization.

Mateen and three others believed to be his family members joined a tour group that was organized by the Islamic Center at New York University, university spokesman John Beckman said.

International students continue to seek out the chance to enroll in Islamic universities and colleges in the US. Islamic colleges provide incredible education to international students who are looking to both advance their education while exploring deeper into their faith. Islamic universities seek to educate their students about the history of their religion as well as continue to build their faith and education for the future.

Islamic Education

The Islamic education main purpose is to educate Muslim students in the United States about the Quran as well as the deep rooted Muslim traditions, known as Sunnah. Islamic colleges are private institution based deep rooted aspects of the faith spread throughout the United States. All of these Islamic colleges share the same message and curriculum. Like most private religious colleges, Islamic universities in America instill an interdisciplinary curriculum with very challenging academic and extracurricular activities. Islamic schools also pride themselves in having incredible faculty and staff who are among the top Muslim educators and scholars in the world. Islamic universities in America follow the teachings of the Quran and their prophet Muhammad. Islamic teachings are the backbone of their universities, with values like knowledge being the upmost important. Islamic colleges seek to turn students into upstanding members of the Muslim community, preparing them for a life of leadership and devotion to their community and their religion. While not all students are expected to be practicing Muslims when they arrive at such a university, they all are expected to follow the basic teachings of the Quran as well as exploring the religion and its customs. Islamic universities seek to make the education affordable for potential students, while also being thoroughly available to all people. Though education is the main fixture for Islamic universities, improving the human experience is a very important function. Islamic colleges in America continue to educate international students and domestic students alike for decades.

Goals of Islamic Colleges and Universities in America

The goals of Islamic universities in America are much like those of any other religious university in the US. The first goal is to educate students on all aspects of the Islamic knowledge. In addition, these universities look to educate students in the proper methods of Islam in order to perform wholly as a Muslim each day. Students are also groomed to be great embers of their community and parish, while providing students with an unwavering sense of knowledge. Like most colleges, the curriculum is based on a four year plan with 120 credits. While each university differs, most Islamic universities push students to major in some sort of Islamic studies area.

Top Islamic Universities in America

There are several Islamic colleges and universities spread throughout the United States which teach a number of different students. While they contain some of the best academics of any college, finding these colleges are quite a bit more challenging. One Islamic college, the Islamic College of Minnesota educates many students. The college has both a graduate and undergraduate section, but only educate students in one major: Islamic Studies.

The Islamic American University is one of the most renowned Islamic colleges in the US. The IAU has several different campuses spread throughout the US in many different states. In addition, the university offers several different online programs for students. An important aspect for international students is to make sure that any classes they have taken transfer into the university, and as well be sure to check into the accreditation of any such college. Islamic education is exceptional in many facets. These universities regularly put out top Islamic leaders in the community and enroll top level international students.

International students will truly enjoy the experiences at these great universities. With a strong education, a diverse and intellectual student body as well as a curriculum based on multiple disciplines and the overall educational experience, international students can find true success in these top universities. Islamic universities are committed to bringing the best education to international students so that they can seek to educate the world with their values of equality and service.

This is the End of Integrity for the VA

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Curious, but factual, it comes down to protecting the unions at the VA. Some locations operate with four unions, while the larger VA facilities have five unions, the worst being SEIU.

This is the reason, the Department of Justice is protecting legal actions at the VA and wont allow the FBI to do deeper investigations for fraud, waste and corruption. Need more proof?

Top VA benefits official Pummill retires

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AirForceTimes: Danny Pummill, who took over the post last October, said in a letter to VBA employees that he had planned to retire from his deputy post in 2015 but remained on the job after being asked to oversee the agency. The retired Army colonel has worked at VA since 2010.

The job of overseeing $90 billion in veterans benefits and dozens of regional offices nationwide now falls to acting principal deputy undersecretary Tom Murphy, who has been serving in that role since Pummill’s promotion last fall.

Pummill was suspended for two weeks in March for “lack of oversight” in a relocation scandal involving two other high-ranking VA administrators, a reprimand that irritated some lawmakers who wanted harsher punishment for what appeared to be unwarranted promotions for longtime bureaucrats. Read full summary here.

 

VA won’t use its fast-track firing powers anymore

MilitaryTimes: Veterans Affairs officials will stop using streamlined disciplinary powers to punish senior department executives after another legal challenge to the congressionally backed process, Capitol Hill officials said Friday.

The move all but resets VA accountability rules to two years ago, when the expedited removal authority was approved by lawmakers in the wake of the department’s wait times scandal.

It also provides new urgency for a series of VA-related accountability bills stalled in Congress, given elected officials’ belief that department leaders have not been aggressive enough in dealing with misbehavior and possible criminal activity among VA employees.

Senate Veterans’ Affairs Committee Chairman Johnny Isakson, R-Ga., called the department’s decision infuriating.

“It is outrageous and unconscionable that the VA is choosing to blatantly ignore all of the accountability reforms set in place by the Veterans Choice Act,” he said. “Two years ago, veterans were forced to wait far too long for care because of incompetent executives. Since then, we’ve seen scandal after scandal emerge at the department.

“While some progress has been made to hold bad actors accountable, there is still a long way to go and choosing to ignore these key reforms is a slap in the face to our veterans.”

VA leaders have long complained about the value of the new disciplinary powers, noting that as written they apply only to a small segment of department employees — senior executives — and create problematic legal questions about appeals.

Only a few individuals have been disciplined under the rules, and the Merit Systems Protection Board has overturned proposed punishment in several other cases.

Earlier this month, U.S. Attorney General Loretta Lynch said the new law speeding up executive firings is unconstitutional because it does not afford those workers proper appeals. The VA decision to dump the entire accountability process passed in 2014 comes as a direct result of that Justice Department stance.

Isakson said the announcement should be seen as a call for Congress to act quickly on new legislation.

“I am not going to stand by and watch the VA continue to look the other way while another one of its own gets away with egregious misconduct at the expense of veterans’ access to quality care and services,” he said.

Earlier this year Isakson introduced a sweeping veterans reform measure which includes new disciplinary rules, including a provision to requiring all appeals by executives to be heard by the VA secretary, and not an outside arbiter.

It would also grant other expedited firing and hiring authorities for more VA employees, and shorten the appeals process for every VA worker.

VA leaders have voiced support for the bill. Federal union officials have have objected to the provisions as too harsh, while congressional critics have labeled the plan too lenient. Isakson had hoped to move the measure through his chamber last month, but the legislation has remained stalled.

House lawmakers last summer passed a new VA accountability act along party lines, with revised whistleblower protections and different appeals provisions. That legislation has yet to move in the Senate.

VA leaders have repeatedly stated that they take disciplinary issues seriously, but also don’t see demotions and dismissals as the only way to improve service throughout the department.

Earlier this year, VA Secretary Bob McDonald told lawmakers that more than 2,600 department employees have been dismissed since he assumed office in August 2014, but lawmakers have questioned whether that figure shows an increase in accountability or normal turnover for the 300,000-plus-person bureaucracy.

States Complying with DOJ/FBI Facial Recognition Database

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GAO: The Department of Justice’s (DOJ) Federal Bureau of Investigation (FBI) operates the Next Generation Identification-Interstate Photo System (NGI-IPS)— a face recognition service that allows law enforcement agencies to search a database of over 30 million photos to support criminal investigations. NGI-IPS users include the FBI and selected state and local law enforcement agencies, which can submit search requests to help identify an unknown person using, for example, a photo from a surveillance camera. When a state or local agency submits such a photo, NGI-IPS uses an automated process to return a list of 2 to 50 possible candidate photos from the database, depending on the user’s specification. As of December 2015, the FBI has agreements with 7 states to search NGI-IPS, and is working with more states to grant access. In addition to the NGI-IPS, the FBI has an internal unit called Facial Analysis, Comparison and Evaluation (FACE) Services that provides face recognition capabilities, among other things, to support active FBI investigations. FACE Services not only has access to NGI-IPS, but can search or request to search databases owned by the Departments of State and Defense and 16 states, which use their own face recognition systems. Biometric analysts manually review photos before returning at most the top 1 or 2 photos as investigative leads to FBI agents.

DOJ developed a privacy impact assessment (PIA) of NGI-IPS in 2008, as required under the E-Government Act whenever agencies develop technologies that collect personal information. However, the FBI did not update the NGI-IPS PIA in a timely manner when the system underwent significant changes or publish a PIA for FACE Services before that unit began supporting FBI agents. DOJ ultimately approved PIAs for NGI-IPS and FACE Services in September and May 2015, respectively. The timely publishing of PIAs would provide the public with greater assurance that the FBI is evaluating risks to privacy when implementing systems. Similarly, NGI-IPS has been in place since 2011, but DOJ did not publish a System of Records Notice (SORN) that addresses the FBI’s use of face recognition capabilities, as required by law, until May 5, 2016, after completion of GAO’s review. The timely publishing of a SORN would improve the public’s understanding of how NGI uses and protects personal information.

Prior to deploying NGI-IPS, the FBI conducted limited testing to evaluate whether face recognition searches returned matches to persons in the database (the detection rate) within a candidate list of 50, but has not assessed how often errors occur. FBI officials stated that they do not know, and have not tested, the detection rate for candidate list sizes smaller than 50, which users sometimes request from the FBI. By conducting tests to verify that NGI-IPS is accurate for all allowable candidate list sizes, the FBI would have more reasonable assurance that NGI-IPS provides leads that help enhance, rather than hinder, criminal investigations. Additionally, the FBI has not taken steps to determine whether the face recognition systems used by external partners, such as states and federal agencies, are sufficiently accurate for use by FACE Services to support FBI investigations. By taking such steps, the FBI could better ensure the data received from external partners is sufficiently accurate and do not unnecessarily include photos of innocent people as investigative leads.

*** The Privacy Act of 1974 places limitations on agencies’ collection, disclosure, and use of personal information maintained in systems of records.3 The Privacy Act requires agencies to publish a notice—known as a System of Records Notice (SORN)—in the Federal Register identifying, among other things, the categories of individuals whose information is in the system of records, and the type of data collected.4 Also, the E-Government Act of 2002 requires agencies to conduct Privacy Impact Assessments (PIA) that analyze how personal information is collected, stored, shared, and managed in a federal system.5 Agencies are required to make their PIAs publicly available if practicable.  See the entire report here from the General Accounting Office.

 

Trump Has Lawyers to Ensure this Does Not Happen

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It must be noted, the FBI does have investigators on the Clinton Foundation as well as several others that are performing comprehensive financial forensics on individuals associated with the Clintons.

 

Sadly, we do have to know these facts. It does hurt the presidential election process for both parties but worse, it could be a real coming crisis for America and her future. One may be worse than the other, but as reported, a violation of law(s), is still a violation when both presumptive nominees are lawyer heavy.  

Donald Trump Accused of Using His Charity as a Political Slush Fund

DailyBeast: When the presumptive GOP nominee doled out money to veterans’ groups over the past few months, he did so using the Trump Foundation—which, according to FEC and IRS rules, should not be engaged in political activity.

The Trump Foundation, Donald Trump’s nonprofit organization, is under fire for allegedly operating as more of a political slush fund than a charity. The foundation is accused of violating rules prohibiting it from engaging in politics—prompting ethics watchdogs to call for public investigations.

On numerous occasions this year, Trump’s campaign work and his foundation work have overlapped—putting himself at risk for penalties and his charity at risk of being shut down.

It’s the latest example of Trump courting controversy: not merely through inflammatory rhetoric, but also through private dealings that raise serious legal questions—all of which indicate how he might govern if elected president of the United States.

Trump is listed as the president of the foundation in the charity’s annual disclosures, and his children Donald Trump Jr., Eric Trump, and Ivanka Trump are all listed as directors. Foundations like theirs are exempt from paying taxes, and as such are barred from engaging in political causes.

“A 501(c)(3) [nonprofit organization], like the Trump Foundation, is strictly prohibited from engaging in political activity. On its tax forms, the Foundation told the IRS that it does not,” said Jordan Libowitz, a spokesman for Citizens for Responsibility and Ethics in Washington (CREW).

But in key early primary states this year, Trump handed out Foundation checks to charities at campaign rallies. This also calls into question “whether the foundation provided the campaign with an illegal in-kind contribution by providing services for what was a campaign event. Under the campaign finance laws… providing anything of value to a campaign for free or at less than fair market value is a contribution to the campaign,” said Larry Noble, the general counsel at the Campaign Legal Center.

And in 2013, the Trump Foundation donated $25,000 to a political organization supporting Florida Attorney General Pam Bondi—an action the foundation is prohibited from taking, and which it failed to report on its disclosures.

The Trump campaign blamed this failure on clerical mistakes, but legal experts are sounding the alarm because at the time Bondi was reviewing complaints surrounding the businessman’s controversial Trump University project.

Both the contribution to Bondi and the overlap between the Trump campaign and his charity should be publicly examined, government watchdogs said.

“This should be investigated. There are troubling legal issues posed in both circumstances,” said Richard Skinner, a money-in-politics policy analyst at the Sunlight Foundation. “There is definitely [use of] a charitable foundation in an inappropriate way.”

Noble, the general counsel at the Campaign Legal Center, added that the Federal Election Commission and the IRS should both open an investigation into whether any laws were broken.

Notably, Donald Trump has legal expertise at his disposal that would allow him to know better than to put himself at risk for these violations. Donald F. McGahn, a Trump lawyer who works for the firm Jones Day, is a former FEC chairman. McGahn did not respond to The Daily Beast’s requests for comment.

Trump decided to skip the January Fox News GOP debate in protest of Megyn Kelly, whose question at a debate in August prompted an onslaught of criticism from Trump and his supporters. He held a charity event for veterans instead, during which he claimed to have raised $6 million. (After much prodding from reporters, and months of delay, he accounted for $5.6 million of the original figure.)

This money was disbursed gradually, and the involvement of the foundation was clear. At multiple campaign rallies this year, the businessman handed out Trump Foundation checks to veterans’ charities.

“It would be one thing to raise money for the charity and send it to them. But if receiving the contribution was dependent on attending the campaign event, it looks like the purpose of the whole thing was to support the campaign,” Noble said. “It raises serious questions when you make a charity part of your campaign event. It could create legal problems for both the campaign and the charity.”

On Jan. 30, with Liberty University President Jerry Falwell Jr. by his side at a campaign rally in Davenport, Iowa, Trump presented a $100,000 Trump Foundation check to Puppy Jake, a charity which supports veterans by providing service dogs.

Puppy Jake’s executive director, Becky Beach, told The Daily Beast that the Trump campaign had been in touch with her about the Trump Foundation’s contributions.

“They called me on the phone,” Beach said, but she could not remember who on the campaign her organization had coordinated with to organize their rally appearance. It was likely an “advance guy” from the Trump campaign, she said.

The next day, the day before the Iowa caucuses, the founder of Support Siouxland Soldiers, another vets charity, appeared on stage with Trump at a Sioux City campaign rally to accept a $100,000 Trump Foundation check.

Support Siouxland Soldiers executive director Sarah Petersen told The Daily Beast that she had been in touch with a Trump staffer named Hope, and provided the phone number they used in order to discuss the donation. The phone number matches up with the campaign’s listed number for Hope Hicks, the Trump campaign’s spokeswoman.

In New Hampshire, those in Trump’s orbit tried to organize a similar rally. They reached out to Keith Howard, the executive director of a local vets charity called Liberty House.

Earlier this year, Howard told The Daily Beast he received a call from a figure affiliated with the Trump campaign, who said that Trump would like to present them with a six-figure check at a Londonderry, New Hampshire, rally right before the Granite State’s primary.

Howard, concerned that being presented with money by a political candidate at a political rally might jeopardize his charity’s nonprofit status, called an expert in the state’s attorney general’s office, who confirmed his suspicions.

Howard declined to attend the rally, and Trump instead presented the check to a New Hampshire state representative who advised him on veterans issues. The state representative ultimately passed those funds along to Howard’s group, without the fanfare.

More recently, following pressure from the press to account for the $6 million he supposedly raised, the Trump campaign announced donations to 20 additional charities. Nine of them, all of which received checks from the Trump Foundation, responded to The Daily Beast’s inquiries. Representatives for each organization said they were neither in contact with the Trump campaign nor were asked to appear at campaign rallies.

The Daily Beast’s attempts to contact the Trump Foundation suggest that the charity exists largely on paper. A phone call to the number listed on the Trump Foundation’s annual disclosures led to a staffer for the Trump Organization, the umbrella group for Trump’s business dealings. Multiple phone calls to the organization failed to yield contact with a foundation staffer.

At one point, a Daily Beast reporter was told that Hicks, Trump’s campaign spokesperson, was responsible for media inquiries related to the foundation. During a second phone call, the reporter was told to contact Justin McConney, who supposedly handles the foundation’s account and donations. Calls and emails to McConney—whose official title is director of new media for the Trump Organization—went unreturned.

McConney also works on the Trump campaign—a January report questioned whether he was being paid fair market value for his work, as he split time between the Trump Organization and the Trump campaign.

The Trump campaign and the Trump Organization did not respond to a request for comment.

The Trump Foundation is already under a microscope.

CREW has filed a complaint against the Trump Foundation over the contribution to Bondi in March, claiming that the charity made an illegal political donation and failed to disclose it to the IRS; and Florida State Sen. Dwight Bullard has written to U.S. Attorney General Loretta Lynch, asking for the Justice Department to investigate the donation.

“Trump apparently does not understand either [the Federal Election Campaign Act] or the tax code and seems to have encouraged both organizations to cross the line,” said Craig Holman, a government affairs lobbyist at the consumer rights group Public Citizen.

When the foundation’s activity crosses over into politics, Holman said, it poses a potential violation of the FECA, which prohibits campaign coordination with outside groups that are not subject to political contribution limits and disclosure requirements.

Philip Hackney, a law professor who spent five years working for the IRS’s chief counsel, said the apparent coordination between the foundation and the campaign was “unwise” because it could put his foundation—and its tax-exempt status—in jeopardy.

The Bondi donation is probably sufficient evidence for the IRS to open an audit into the Trump Foundation, Hackney told The Daily Beast, adding that Trump himself could be subjected to extra taxes.

“I don’t know that they’ll even audit him,” Hackney said. “I think it’s dangerous, particularly politically for them right now, to audit in this realm. That bothers me, given what I see in this particular case, but I don’t know that the IRS has another choice in some ways.”