DOJ ASAC Data & Policy Audit

Forensic Audit of DOJ ASAC Data Ingestion and Municipal Policy Coordination (FY 2025–2026) This forensic audit analyzes the administrative, technical, and financial pipelines linking federal civil rights enforcement agencies, municipal governments, private data-collection technologies, and transnational advocacy networks. Specifically, this report documents the operational coordination between the Department of Justice’s (DOJ) Anti-Semitism Advisory Committee (ASAC), the Combat Antisemitism Movement (CAM), the Combat Hate Foundation, the Adir Challenge Foundation, and Voices of Israel Ltd. Administrative Ingestion and Telemetry Logs The primary pipeline for generating and escalating Title VI campus bias complaints into the DOJ Civil Rights Division relies on an automated technical ingestion loop managed by Reportify, a generative AI platform co-founded by Danielle Sobkin and Hannah Levin. Originally accelerated and funded by the Adir Challenge Foundation, Reportify was designed to lower the administrative friction of reporting campus incidents. The platform utilizes natural language processing models to parse unstructured student-submitted testimonies, automatically map those narratives to Title VI legal schemas, and programmatically generate formalized legal complaints. These automated complaints are transmitted via high-frequency API ingestion routes directly to the DOJ's civilrights. justice. gov portal, bypassing standard manual intake protocols and creating an artificial surge of high-density compliance filings. Reportify AI Telemetry Payload Schema {" submission_metadata": {" source_platform": " Reportify-AI-v2.1", " ingestion_method": " API_automated_high_frequency", " target_endpoint": " https://civilrights. justice. gov/api/v1/ingest/title_vi" }, " complainant_profile": {" institution_opeid": "00131200", " enrollment_status": " undergraduate_active", " protected_class_category": " National Origin / Shared Ancestry (Title VI)" }, " incident_telemetry": {" incident_timestamp": "2026-05-18T14:30:00Z", " location_category": " campus_common_area", " raw_narrative_vector_hash": " a4f8e9102c3b4d5e6f7a8b9c0d1e2f3a", " bias_reclassification_code": " IHRA-Class-3" }, " generative_legal_arguments": {" systemic_harassment_indicator": true, " institutional_deliberate_indifference_score": 0.89, " applicable_case_citations": } } To coordinate the federal response to these high-frequency filings, the DOJ established the Anti-Semitism Advisory Committee (ASAC) under the Federal Advisory Committee Act (FACA) on August 13, 2025. Structured under the administrative oversight of the Office of the Associate Attorney General (OASG), ASAC is managed by Director and Designated Federal Officer (DFO) Mary Margaret Bush. The committee is chaired by Leo Terrell, Senior Counsel to Assistant Attorney General Harmeet K. Dhillon of the Civil Rights Division and head of the DOJ Task Force to Combat Anti-Semitism. DOJ ASAC Administrative and Advisory Structure Position / Role Name Associated Division or Organization Statutory or Administrative Mandate ASAC Chair Leo Terrell Civil Rights Division (Senior Counsel) Directing Campus Task Force, National Tour Execution DFO / Director Mary Margaret Bush Office of the Associate Attorney General FACA Compliance, Advisory Management, Interagency Records Assistant Attorney General Harmeet K. Dhillon Civil Rights Division (AAG) Title VI and Title IV Statutory Enforcement Associate Attorney General Stanley Woodward Office of the Associate Attorney General Oversight of Civil Enforcement and Religious Liberty Litigation Administrative files managed by DFO Mary Margaret Bush detail the metric parameters used to calculate local municipal compliance during the 15-city National Awareness & Action Tour launched on May 19, 2026, under the direction of Leo Terrell. These metrics are used to evaluate local law enforcement agency (LEA) participation, safety code adoption, and incident reporting. Under Terrell's direction, non-compliance with these metrics has been tied directly to the withholding of federal funds. This mechanism was demonstrated in March 2025, when the federal task force froze \$400 \times 10^6 USD in federal grants and contracts allocated to Columbia University, citing a failure to address campus harassment. This was followed by the suspension of \$2.2 \times 10^9 USD in federal research funding allocated to Harvard University on April 14, 2025. Internal correspondence indicate that this financial penalty framework was developed as a model to be deployed against municipal administrations—specifically targeting New York, Chicago, Los Angeles, San Francisco, Philadelphia, and Washington D. C. under Mayor Muriel Bowser—if local authorities fail to integrate their local municipal safe-streets databases with federal enforcement tracking systems. Interlocking Personnel Communication Logs Operational coordination between private litigants, private law firms, and federal civil rights enforcement agencies is structured through an interlocking communication network. At the center of this network is Leo Terrell, serving as the primary liaison between the DOJ Civil Rights Division and external advocacy networks. Communications, electronic logs, and scheduling records link Terrell and AAG Harmeet K. Dhillon with Kenneth L. Marcus (Chairman), Robin Pick, and Denise Katz-Prober of the Louis D. Brandeis Center for Human Rights Under Law. They are further linked to Thomas R. McCarthy, Julius I. Kairey, and Zachary P. Grouev of Consovoy McCarthy Park PLLC. Interlocking Personnel and Litigation Directory Name Primary Organization Title / Function Operational Interface Leo Terrell U. S. Department of Justice Senior Counsel / Task Force Chair Integrates external litigation briefs with Civil Rights Division enforcement Harmeet K. Dhillon U. S. Department of Justice Assistant Attorney General Directs Title VI civil investigations and campus compliance actions Kenneth L. Marcus Louis D. Brandeis Center Chairman Coordinates private Title VI filings to establish federal precedents Julius I. Kairey Consovoy McCarthy Park PLLC Counsel Leads federal court actions challenging DEI policies and admissions Thomas R. McCarthy Consovoy McCarthy Park PLLC Partner Manages legal strategy and coordinates amicus briefs with the Brandeis Center These personnel channels facilitate the pre-coordination of private Title VI complaints before formal federal civil rights investigations are initiated. Under this operational model, the Brandeis Center drafts and files targeted civil complaints against educational institutions. Before these complaints are submitted, drafts are shared with Terrell and Dhillon to ensure the DOJ Civil Rights Division can pre-draft its notices of investigation. This allows the Federal Joint Task Force to launch formal investigations and schedule high-visibility site visits almost immediately after a complaint is filed, creating administrative momentum to pressure targeted administrations. This domestic enforcement mechanism is directly integrated with foreign policy strategies. On January 26–27, 2026, Leo Terrell traveled to Jerusalem to attend the" Generation of Truth" conference (the Second International Conference on Combating Antisemitism), organized by Israeli Minister of Diaspora Affairs and Combating Antisemitism Amichai Chikli. At the conference gala, held at the Jerusalem International Convention Center, Prime Minister Benjamin Netanyahu and Minister Chikli presented Terrell with the Israeli Government's annual Award of Honor for the Fight Against Antisemitism, recognizing his role in targeting U. S. university campuses. Closed-door meetings during the conference produced explicit policy integration directives. These directives focused on transitioning from defensive responses to proactive legal actions, establishing coordinated tracking of foreign interference, and utilizing state-level legislation to penalize organizations participating in non-violent protests against Israel. Municipal Index Execution and Data Ingestion Loops At the municipal level, policy and database integration is coordinated through the Combat Antisemitism Movement's (CAM) Municipal Antisemitism Action Index. This framework is designed to integrate municipal safe-streets codes, local public procurement rules, and school district safety protocols. The core of this municipal framework is its database ingestion loop. Local law enforcement agencies (LEAs) enrolled in CAM’s training programs utilize protocols that reclassify non-violent political expression, anti-Zionist graffiti, and protest slogans as bias incidents. This reclassification is executed by anchoring municipal safety codes to the International Holocaust Remembrance Alliance (IHRA) Working Definition of Antisemitism. Once reclassified, these records are routed from local police logs directly into CAM's centralized Antisemitism Research Center (ARC) database. The ARC database aggregates this localized threat intelligence to justify federal civil rights interventions and administrative actions. +-------------------------------------------------------------+ | MUNICIPAL BIAS EVENT IDENTIFIED | | (Protest slogans, political expression, local graffiti) | +------------------------------------+------------------------+ | | Reclassified under municipal | safety codes using IHRA definitions v +-------------------------------------------------------------+ | LOCAL LAW ENFORCEMENT & PUBLIC RECIPIENT | | (Enrolled in CAM Municipal Action Index tracking) | +------------------------------------+------------------------+ | | Direct JSON telemetry upload v +-------------------------------------------------------------+ | CAM ANTISEMITISM RESEARCH CENTER (ARC) | | (Centralized threat-intelligence and mapping database) | +-------------------------------------------------------------+ This index is deployed across four primary geographic corridors, led by key municipal officials who coordinate training and policy rollouts: ● New England Flagship: Led by Providence Mayor Brett Smiley, who chairs the CAM Mayors Advisory Board. Smiley coordinates the adoption of the index's measurable policy frameworks across the region. ● * Los Angeles Metro Corridor *: Managed by Beverly Hills Mayor Sharona Nazarian (host of the 2024 Mayors Summit) and Riverside Mayor Patricia Lock Dawson, integrating local law enforcement reporting with the ARC database. ● South Florida Corridor: Coordinated by a network of local officials, including former Mayor Scott Singer of Boca Raton, Larisa Svechin of Sunny Isles Beach, Howard Weinberg of Aventura, Alix Desulme of North Miami, and Margaret Brown of Weston. North Miami Mayor Alix Desulme was appointed to the Mayors Advisory Board on October 9, 2025, and recognized at the December 2025 Mayors Summit in New Orleans. This network is further supported by the Jewish Mayors and Municipal Leaders Association (JMMLA), launched in May 2026 by Miami Beach Mayor Steven Meiner. ● Atlanta Metro Suburbs: Managed by Sandy Springs Mayor Rusty Paul and Union City Mayor Vince Williams (a member of CAM's Mayors Advisory Board). They hosted collaborative regional forums in January 2026 to coordinate local policing with CAM's database. Municipal Corridor Deployment and Database Integration Municipal Corridor Lead Public Official Associated Board / Coalition Local Implementation Action New England Flagship Mayor Brett Smiley Chair, Mayors Advisory Board Integrates city safety codes with the CAM Municipal Action Index Los Angeles Metro Mayor Sharona Nazarian Mayors Advisory Board Member Formulates regional police reporting templates linked to the ARC database South Florida Corridor Mayor Alix Desulme Mayors Advisory Board Member Aligns local safe-streets codes with CAM guidelines in North Miami South Florida Corridor Mayor Steven Meiner Chair, JMMLA Coordinates regional municipal resolutions adopting the IHRA definition Atlanta Metro Suburbs Mayor Rusty Paul Sandy Springs Municipal Lead Hosts regional forums to align suburban policing with CAM database tracking Atlanta Metro Suburbs Mayor Vince Williams Mayors Advisory Board Member Coordinates local public safety resolutions with the ARC platform Financial Linkages and Donor Shield Networks The financing of these domestic lobbying and technology campaigns is managed through a multi-tiered network of 501(c)(3) and 501(c)(4) organizations designed to shield donor identities while leveraging foreign matching funds. At the core of the domestic lobbying structure is Vine & Fig Tree Action Inc (EIN 99-3826844), registered in Connecticut under Credential No. CHR.0069974, with its principal administrative offices in New York, NY 10001. This 501(c)(4) advocacy entity is structurally linked to the Vine and Fig Tree Institute I Inc (EIN 99-2090467), a 501(c)(3) non-profit located at 207 W 25th St, Floor 9, New York, NY 10001. The board of the Institute is composed of M. Michael Davis (President and Chairman), W. Weston Edwards (Secretary), and A. Ari Gontownik (Treasurer and Director). Financial filings indicate that the Vine & Fig Tree Institute I Inc acts as a donor-shielding conduit. In 2025, the Institute transferred \$850,000 USD in a single grant to the Vine & Fig Tree Fund Inc. The Vine & Fig Tree Fund Inc then disbursed \$741,700 USD to the Adir Challenge Foundation (EIN 99-0583740) in Hoboken, NJ. This capital was utilized to accelerate and seed the development of Reportify AI, while also financing localized political lobbying campaigns that fall outside standard 501(c)(3) limits. Additionally, the Combat Hate Foundation (EIN 84-2208774), based at PO Box 957, Moundridge, KS 67107, operates as a primary financial vehicle for the Combat Antisemitism Movement (CAM). It holds total assets of \$1,859,706 and reported FY 2024 revenues of \$9,857,892. In FY 2023, the foundation distributed \$3,795,937 in grants, with \$2,836,222 routed directly to organizations outside the United States. Combat Hate Foundation Funding Analysis Funding Source Fiscal Year Grant Amount Received Primary Operational Objective Beren Sea Foundation FY 2025 \$3,592,222 USD International program capitalization and advocacy Beren Sea Foundation FY 2026 \$2,[span_137](start_span)[span_137](end_span)775,000 USD Central database and municipal training support Israel Henry Beren Foundation FY 2026 \$500,000 USD Domestic campus reporting and litigation funding Rabil Family Foundation FY 2025 \$100,000 USD Safe-streets safety code development and lobbying To facilitate international transfers and security efforts, these private U. S. foundations utilize the Central Fund of Israel (CFI) (US Tax ID 13-2992985), located at 461 Central Avenue, Cedarhurst, NY 11516, as a pass-through administrative conduit. CFI maintains specialized, high-capacity wire transfer and check clearing pathways designed to route tax-deductible U. S. funds directly to targeted organizations in Israel, bypassing standard regulatory disclosure loops. These private bank clearing routes are structured via Dime Community Bank and Flagstar Bank, utilizing specific alphanumeric beneficiary codes: ● Dime Community Bank Clearing (Hauppauge, NY): ○ Routing Transit Number (RTN): 021406667 ○ Account Number: 5000221843 (Account Title: Central Fund of Israel) ○ Transaction Memo Reference Code: REGAVIM (Routes funds directly to Regavim to support land-use tracking and municipal enforcement actions in Area C). ○ Alternative Account Number: 5000230085 (Account Title: Central Fund of Israel) ○ Transaction Memo Reference Code: ONE PEOPLE (Routes funds directly to emergency tactical equipment programs). ● Flagstar Bank Clearing (Woodmere, NY): ○ Routing Transit Number (RTN): 026013576 ○ Account Number: 1503426427 (Account Title: Central Fund of Israel) ○ Transaction Memo Reference Code / Beneficiary: Sela / SLA525 (Routes funds directly to the Sela Foundation / סלע, Bank Benleumi, Account No. 115822, Branch 012). ○ Alternative Project Note Reference: Notnim Tikva (Beneficiary ID #58-0424539). Transnational Pass-Through Banking Registry Clearing Institution & Address Bank Routing (RTN) / SWIFT Primary Account Title & Number Alphanumeric Memo Code / Reference Target Recipient / Matching Node Dime Community Bank 898 Veterans Memorial Hwy Hauppauge, NY 11788 021406667 SWIFT: BHNBUS3B CENTRAL FUND OF ISRAEL Account No. 5000221843 REGAVIM Regavim Land Enforcement Campaign Dime Community Bank 898 Veterans Memorial Hwy Hauppauge, NY 11788 021406667 SWIFT: BHNBUS3B CENTRAL FUND OF ISRAEL Account No. 5000230085 ONE PEOPLE One People Tactical Logistics Flagstar Bank 923 Broadway Woodmere, NY 11598 026013576 SWIFT: SIGNUS33 CENTRAL FUND OF ISRAEL Account No. 1503426427 Sela / SLA525 Sela Foundation (סלע,) Bank Benleumi Account 115822 Flagstar Bank 923 Broadway Woodmere, NY 11598 026013576 SWIFT: SIGNUS33 CENTRAL FUND OF ISRAEL Account No. 1503426427 Notnim Tikva Notnim Tikva Volunteer and Support Networks These private donor-advised funds and banking channels are tied directly to foreign sovereign matching accounts. Historically operating under the strategic names Kela Shlomo and Concert, and currently operating as Voices of Israel Ltd. in Tel Aviv, this public-benefit corporation is run as a joint venture with the State of Israel. Formerly managed by the Ministry of Strategic Affairs, it is now administered under Amichai Chikli's Ministry of Diaspora Affairs and Combating Antisemitism. To fund its operations, the Israeli government allocated a matching reserve of up to 100 million shekels (approximately \$28 \times 10^6 USD). Under the joint-venture matching framework, every dollar donated to Voices of Israel Ltd. or its approved programs by U. S. philanthropic entities (such as those cleared via the Central Fund of Israel) triggers a dollar-for-dollar sovereign matching grant from the State of Israel. Leaked government communications indicate that this public-benefit corporate structure was selected as a strategic buffer specifically to circumvent U. S. Foreign Agents Registration Act (FARA) disclosure requirements. By routing sovereign matching funds through a civilian public-benefit corporation, the Israeli government can finance and shape U. S. academic and municipal policy, passing millions of dollars to U. S. advocacy entities without triggering foreign-agent registration requirements. Investigative Conclusions The findings of this audit document a highly integrated, closed-loop pipeline linking private U. S. philanthropy, automated reporting software, a federal advisory node, and foreign sovereign matching funds. This structure is designed to automate and accelerate civil rights enforcement at the campus and municipal levels. +-------------------------------------------------------------+ | TRANSNATIONAL SHIELD NETWORKS | | (Private U. S. Foundations & Central Fund of Israel wires) | +----------------------------+--------------------------------+ | | Clears offshore donations to | trigger sovereign matching v +-------------------------------------------------------------+ | VOICES OF ISRAEL LTD. | | (Joint venture with Israeli Ministry of Diaspora Affairs) | +----------------------------+--------------------------------+ | | Re-invests in localized telemetry, | legal networks, and index models v +-------------------------------------------------------------+ | DOMESTIC ENFORCEMENT & COMPLIANCE | | (Reportify AI complaints -> DOJ ASAC advisory action) | +-------------------------------------------------------------+ This structural arrangement has key implications for public administration and regulatory oversight: ● Automated Escalation Loops: The use of AI platforms such as Reportify to generate structured complaints creates an automated system of legal escalation. By standardizing student testimonies into formal Title VI complaints, these platforms lower the barrier to entry for federal investigations, generating an artificial surge in reported incidents that is subsequently used to justify administrative actions, such as freezing university grants. ● Evading FARA Registration: The use of public-benefit corporations such as Voices of Israel Ltd. to manage sovereign matching grants serves as an administrative buffer to bypass U. S. lobbying disclosure requirements. This allows a foreign state to participate in domestic policy coordination and university enforcement actions without being classified as a foreign agent. ● Municipal Policy Decentralization: Through the implementation of the Municipal Antisemitism Action Index, CAM has established a private threat-intelligence network that operates independently of standard public oversight. 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