How Do You Catch the Vampire Squid Consuming Taxpayer Money in Non Government Organizations (NGOs)?
Bait it, Track it, Starve it With a Grand Army of Citizen Auditors
The vampire squid is one of the strangest creatures in the ocean. It lives 600 to 3,000+ meters down in the oxygen minimum zone where almost nothing else survives. It doesn’t drink blood — it gently eats “marine snow,” the falling bits of dead plankton, poop, and mucus. It defends itself by turning inside out to show spiky arms, flashing bioluminescent lights, or shooting glowing mucus to confuse threats. Think Chuck Schumer or Lindsey Graham. It has no ink cloud like real squids. It is rare, fragile, ecologically fascinating, and best admired from a safe distance through videos from MBARI or the Monterey Bay Aquarium. In short, the real vampire squid is almost impossible to catch.
But the vampire squid I’m talking about in Washington is something else entirely. Right now, on April 29, 2026, the House Oversight Committee is marking up H.R. 8463 (Pre-Payment Fraud Prevention and Treasury Data Access Act) and H.R. 8464 (Stopping Fraudulent Payments Act). Both bills aim to stop fraudulent payments before the money leaves the Treasury.
They are good first steps. But they will be far more effective if they are paired with the real-time, standardized reporting and full beneficial ownership disclosure I propose here. Without transparent data and a Grand Army of citizen auditors watching every grant, we will quickly revert to blind sheep letting Congress and NGOs sequester our money for their good - not the public good. My recommendations do not replace these bills; they supercharge them.
As a freshman at Marquette University in 1976, I watched Network in rapt attention at the Ward Parkway Theaters in Kansas City. I was working my summer job there. I ate often at Eddie’s Loaf ’n Stein, and I even ran catering for the Republican National Convention at Crown Center where Gerald Ford was nominated. It was a time of war, inflation, Cold War tensions, and accusations of government waste and fraud. Politicians arrived in D.C. with principles that quickly drowned in “go along to get along” inducements. Watching that clip today, I am struck by how little has changed; the scale of the money has grown enormously, the sophistication of the intermediaries has increased, and the decades of unchecked federal accounting failures continue. The movie Network exemplified times not dissimilar to today - Mad As Hell
I’ve now lived through 13 election cycles. Candidates promise to solve wedge issues such as abortion, guns, immigration, and Israel; then they keep those issues alive because the campaign cash flows. Even unified party control never fixes them. The explosion of hidden dark-money endorsements only confirmed my cynicism. There is just too much money at stake. If President Trump’s “drain the swamp” pledge has any teeth in 2026, it must start by forcing the federal government and the vast non-profit/NGO ecosystem it funds to adopt the same real-time accounting standards that any public company has followed for nearly a century.
The federal government’s spending and accounting practices remind me of Bernie Madoff’s decades-long deception. Massive sums moved with little real transparency or accountability until the damage was enormous. Why should the Beltway get a pass that Enron and WorldCom never did? Why has the federal government been allowed to operate with weaker transparency for decades while trillions flow out the door?
The Vampire Squid Wrapped Around the Taxpayer
The real scandal isn’t just bureaucratic bloat. It’s the explosion of federal grants flowing through non-profits and NGOs that operate with minimal oversight. These organizations have become the “vampire squid” of the administrative state; they wrap tentacles around trillions in taxpayer dollars while delivering questionable results and, in too many cases, outright fraud. Look no further than the still-unfolding Minnesota Somali welfare fraud scandal.
What began as the Feeding Our Future scheme — $250 million+ in fake meal claims during COVID — has revealed itself as only one of many tentacles sucking on the arteries of federal spending in Minnesota communities. Nearly 100 individuals have been charged, the overwhelming majority Somali-American, with funds allegedly funneled overseas via hawala networks that even counterterrorism sources worry may have benefited al-Shabaab. Non-profits like Feeding Our Future were the pipeline. Fake sites, shell companies, luxury cars, and cash headed to Somalia while American kids went unfed. The FBI is still raiding sites. The Trump administration has frozen funds and launched probes. This isn’t isolated; it’s a symptom of a system where grants go out the door with little real-time tracking of beneficial owners or outcomes. And Minnesota is just the visible tip.
The Government Accountability Office’s April 2026 report puts FY2025 improper payments at $186 billion across 64 programs — an increase of $24 billion in a single year. Medicare, Medicaid, unemployment, housing assistance — you name it. Much of it flows through non-profits that certify compliance, submit claims, and then disappear into the ether. The Department of Government Efficiency (DOGE) exposed billions in hidden or wasteful spending, yet the underlying grant data remains fragmented and opaque.
Let me explain something very simple. In 2021 Congress passed a law called the Corporate Transparency Act. The whole point was to stop bad guys from hiding who really owns companies and non-profits. The law said that if you own 25% or more of a company, or you are the boss who really controls it, you have to tell the government your name. That way everyone could see who was really getting the money.
But in March 2025, FinCEN — part of the Treasury Department under President Trump — issued a new rule that basically killed the law for almost every American company and non-profit. The Biden Treasury tried to sweep up small businesses and LLCs into a dragnet by requiring even the tiniest LLC to register with the federal government, with threatened large fines for non compliance. The Trump Treasury killed the whole thing and extinguished any hope for understanding who owns and operates non profits and LLCs swimming in federal grant dispositions.
Most U.S. companies no longer have to tell anyone who owns them. They do not have to say who controls them. They do not have to say anything. This was actually a good move for little guys like me. I own several small LLCs to protect my two farms from lawsuits. I did not want to waste time filling out extra government forms just to stay legal. The new rule helps regular people and small businesses. But the killing of disclosures for non profits and LLCs getting government money went too far.
Now a sneaky operator can own 10%, 15%, or 20% of a non-profit or LLC that gets huge government grants - this is the modern cloak of invisibility. Their friends and family can do the same. They can split the money with big salaries, nice contracts, and fat bonuses. The public never sees the ownership. Federal grants typically pay 70c to middlemen who then give 30c to those working to educate, nurse, actuate human potential. The citizen watchdogs never see the connections. Here is the fair fix. Keep the exemption for small entities, but bring back full beneficial ownership disclosure for any group that receives more than $1 million in federal grants or contracts in a single year.
Why $1 million? Because that is the exact line the government already uses. It is called the Single Audit threshold.1 Any organization that spends more than $1 million of taxpayer money in a year already must complete a special audit. It is not arbitrary; it is the government’s own rule for “this is big enough to watch closely.”
This means tiny farms and small LLCs stay free and simple. But the giant non-profits and NGOs that swallow hundreds of millions or billions and then upchuck it back to political operators — the ones in the Minnesota scandals — would finally have to show who really owns and controls them. No more hiding 10% or 15% stakes while the money flows to friends and family.
As an investor with nearly 40 years in the markets, I ask the obvious question. Why does the federal government — and every contractor or non-profit it funds — get to operate with weaker standards than a publicly traded company? Isn’t the U.S. government the ultimate publicly owned and operated company?
Real-Time Federal Expense Reporting
To list and trade in public markets and attract public investments, companies must comply with specific quarterly and annual reports. These reports are placed immediately in the public domain for investors and financial analysts. Sarbanes-Oxley placed criminal liability on executives who misrepresent the financial condition of a company. With the advent of the cloud and the ability to instantly update global databases, why should we excuse any government agency from the responsibility to provide regular reports of spending? These reports should be equivalent to a public company’s 10-Qs; they should detail program performance, budget allocation, and progress toward goals. An annual report to a centralized database, equivalent to the 10-K for the publicly traded company, would offer spending changes, major program updates, independent audits, and risk assessments. Furthermore, the 10-K should flag significant events; these include major policy shifts, data breaches, or unexpected budget changes or spending patterns.2
The template for more accountable federal spending exists in the 1933 and 1934 Securities Exchange Acts for public companies. The time is now to ask the Office of Management and Budget to establish a universal protocol, identification system, and centralized database. This system must be consistent across every agency and contractor serving the taxpayer through the federal government. It must record both grant allocations and disposition by recipients — unless all of the Kabuki Theater around executive orders is eye candy and not meant to install permanent change to business practices in the Beltway.
I helped catalyze the movement toward an integrated, electronic, accessible trading market for global securities.3 The emergence of the FIX protocol created an open standard. It originally captured the information necessary to send and to audit both orders and trades for stocks and foreign exchange through electronic, global highways. The transition posed a grave threat to Wall Street, especially NASDAQ market makers at the time. My testimony asking Congress to demand the equity market transition to decimals from fractions was controversial. It was considered immediately threatening to Wall Street’s place in global capital markets. If we could force that level of transparency on private markets decades ago, we can and must do it for the public’s money today.
The Foundations for Evidence-Based Policymaking Act of 2018 (Evidence Act) and the False Claims Act give us the statutory hooks. The FCA delivered a record $6.8 billion in recoveries in FY2025 — the highest ever, with over $5.3 billion from whistleblower suits. We simply need OMB to mandate standardized, machine-readable data. Every agency, contractor, grant recipient, and sub-recipient must report in real time. This includes full beneficial ownership disclosure for NGOs and LLCs that receive more than $1 million in federal funds. Blockchain could make grant flows transparent and tamper-proof. DOGE’s transparency pushes show exactly why this is urgent. The Pentagon’s failure of its eighth consecutive financial audit in FY2025, with 26 material weaknesses, underscores the urgency.
The Grand Army of Retired Citizen Auditors (GARCA)
Once the data is open, standardized, and reported in real time, we unleash the talent. A Grand Army of Retired Citizen Auditors (GARCA) offers the solution. It is bipartisan and nonpartisan. It is powered by retirees, forensic accountants, financial analysts, and motivated sleuths. Modeled on the original Grand Army of the Republic, GARCA turns civic duty into a modern, gamified, cloud-based force multiplier. The government could even provide transparency incentives to game and app producers competing to uncover the worst of fraud, abuse and just plain stealing by government insiders.
Open enrollment for qualified volunteers with no political litmus test.
Anonymous numerical IDs to keep focus on substance, not personalities or self-promotion.
A crowdsourced platform, building on USASpending.gov plus Evidence Act data, where volunteers submit findings on fraud, waste, or inefficiency.
Community voting and a Volunteer Impact Score (VIS) inspired by baseball’s OPS. It rewards consistency and high-impact results such as dollars recovered and processes fixed. Leaderboards show top anonymous analysts and categorized wins. These include fraud eliminated, waste identified, and efficiency gained.
Gamification with badges, peer recognition, and tiered President’s Volunteer Service Awards (Bronze, Silver, Gold, Lifetime) to sustain engagement without bureaucracy.
Incentives aligned with the False Claims Act. Modest financial rewards for top performers are capped at low percentages of actual recoveries, for example $50k–$100k over years. This supplements existing qui tam shares for major cases. The goal is public service, not windfalls.
Findings feed directly into official Inspector General processes. A small neutral oversight body made up of OMB officials, experts, and citizen representatives ensures security and integration. Strict rules against coordinated manipulation keep it clean. This is not fantasy. The cloud, AI, and broadband already enable it. The Evidence Act demands evidence-based policy and open data. The Minnesota scandals and Pentagon audit failures show what happens when we do not have eyes on the ground.
Why They Don’t Want Us to Follow the Money
Because it exposes how wedge issues stay alive for fundraising. It would reveal how grants become patronage. And it would show how the non-profit industrial complex has grown into a multi-trillion-dollar shadow government with little accountability. It would force real reform instead of performative hearings. An executive order under the Evidence Act could launch GARCA tomorrow. Better still, Congress should codify it in statute. The law should be bipartisan, permanent, and trusted. Recognition via the Presidential Citizens Medal or Medal of Freedom for top contributors would honor the service. The original GAR helped heal a fractured nation after the Civil War through shared sacrifice and accountability. In 2026, with massive debt and scandals exposing systemic rot, we need their spirit more than ever. A volunteer army of citizen auditors, armed with transparent data and modern tools, can finally make “follow the money” the norm and not the exception.The technology exists. The legal framework exists. The retirees with the expertise are ready. The only question left is this. Why don’t they want us to see where the money really goes? Let’s build GARCA. Let’s drain the swamp for real this time.
Historical note on the Grand Army of the Republic: Founded in 1866, it grew to 400,000 members and shaped veterans’ rights, national holidays, and post-war unity while bridging divides through civic action.
Office of Management and Budget (OMB), Uniform Guidance (2 CFR Part 200, §200.501). The Single Audit threshold was raised from $750,000 to $1 million for fiscal years beginning on or after October 1, 2024.
The U.S. Government as a whole has received a disclaimer of opinion on its consolidated financial statements for decades, primarily due to material weaknesses at the Department of Defense. The Pentagon has failed its financial audit for eight consecutive years as of FY2025, with 26 material weaknesses identified. See GAO’s audit of the FY2025 Consolidated Financial Statements of the U.S. Government and the Department of Defense Agency Financial Report for FY2025.
Per Grok: Harold S. Bradley, Vice President and Director of Trading at American Century Investment Management (formerly Twentieth Century), played a prominent role in shaping federal securities-market reforms during the 1990s and early 2000s. He submitted a detailed comment letter dated January 13, 1996, to the SEC’s Market 2000 initiative, furnishing groundbreaking institutional buy-side data and analysis on hidden limit orders, quote transparency, and the inefficiencies of fragmented markets (cited in subsequent SEC rulemaking on the Order Handling Rules and Display Rule). At the invitation of SEC Commissioner Steven M.H. Wallman, Bradley testified in 1997 before the House Committee on Commerce, Subcommittee on Finance and Hazardous Materials, in support of the Common Cents Stock Pricing Act of 1997 (H.R. 1053), advocating decimal pricing to narrow spreads and reduce investor costs. SEC Chairman Arthur Levitt personally appointed him in summer 2000 to the federal Advisory Committee on Market Information (2000–2001), where he addressed the cost, consolidation, and provision of stock-market data to investors; Bradley participated actively in committee meetings and contributed to its September 14, 2001 final report. He also provided congressional testimony on electronic communication networks (ECNs) and market transparency (Senate Banking Committee, April 26, 2000), soft-dollar practices and mutual-fund transaction costs (2003), and exchange-traded funds (Senate Banking Committee, October 19, 2011). These interventions illustrate the influence of institutional investor perspectives on federal regulatory accounting and disclosure frameworks in equity markets.
(all publicly available):
Bradley’s January 13, 1996 Market 2000 letter: referenced in SEC Release No. 34-37619 (Order Handling Rules) and related Federal Register notices.
Advisory Committee Report (Sept. 14, 2001): https://www.sec.gov/divisions/marketreg/marketinfo/finalreport.htm(Bradley listed as member; meeting minutes confirm participation).
2000 Senate testimony: archived references in Kauffman Foundation materials and SEC dockets.
2003 and 2011 hearings: available via congress.gov (CHRG-108hhrg87798 and CHRG-112shrg74309).