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Non-Profit Foreign Influence Investigation

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Summary

Transnational Proxy Networks: Structural, Financial, and Personnel Linkages Between Domestic U. S. Non-Profits and the Israeli State Apparatus Executive Summary This report delivers a rigorous structural and financial analysis of the influence networks operating between domestic U. S.

Transnational Proxy Networks: Structural, Financial, and Personnel Linkages Between Domestic U. S. Non-Profits and the Israeli State Apparatus Executive Summary This report delivers a rigorous structural and financial analysis of the influence networks operating between domestic U. S. 501(c)(3) non-profit organizations and the Israeli state apparatus, with a specific focus on the Ministry of Diaspora Affairs and its public-private proxy initiatives. By cross-referencing corporate tax filings, federal lobbying registers, leaked internal legal memoranda, and executive biographies, this investigation exposes a highly coordinated, multi-tiered infrastructure designed to shape domestic U. S. policy, suppress political activism, and systematically bypass the Foreign Agents Registration Act (FARA). The network operates through a series of domestic non-profit cutouts, primarily the Moundridge, Kansas-registered Combat Hate Foundation, which manages the Combat Antisemitism Movement (CAM). This operational core is sustained by a specialized domestic funding pipeline led by Midwestern oil magnate Adam E. Beren’s family foundations and the New York-based Vine and Fig Tree network. Operating alongside allied organizations such as the Philos Project and the Merona Leadership Foundation, these entities form an interlocking directorate that aligns domestic advocacy with foreign state agendas. Integrating former senior Israeli military intelligence, defense, and diplomatic officials directly into the governance of U. S. charities allows the network to execute synchronized campaigns. Leaked documents reveal that this structure was intentionally designed to evade FARA registration by employing domestic non-profits as intermediaries. Furthermore, these organizations have successfully embedded key personnel into federal advisory bodies, congressional offices, and municipal policy networks, effectively institutionalizing foreign-aligned speech and policy parameters across local and federal levels of the U. S. government. The Combat Hate and Combat Antisemitism Movement Nexus The administrative and operational hub of this transnational network is the Combat Hate Foundation, a 501(c)(3) public charity incorporated in 2019 in Moundridge, Kansas. While its primary front-facing initiative, the Combat Antisemitism Movement (CAM), is presented as a global grassroots coalition of over 850 interfaith organizations and millions of activists, its corporate structure is entirely integrated with and managed by executive personnel from Berexco LLC, a prominent Midwest oil and gas exploration and production firm. Administrative and Corporate Integration with Berexco LLC Adam E. Beren, the owner and president of Berexco and a major donor to the Republican National Committee, founded CAM and the Combat Hate Foundation in 2019. To obscure his direct involvement during the organization’s formative years, Beren did not publicly acknowledge his role until 2023. During this period, the Combat Hate Foundation was officially registered under the name of Donna Stucky, who serves as the chief financial officer of Berexco and the record-keeper for Beren’s family foundations. Jonathan Oller, another key Berexco corporate executive, serves as the foundation’s treasurer, ensuring that financial and administrative oversight remains centralized within the oil firm's headquarters. The day-to-day operations of the foundation are directed by Executive Director Mikhail (Misha) Galperin, who was compensated $127,500 in fiscal year 2022 and has served as a senior advisor and co-creator of the advocacy group since its inception. Jason Guberman also serves on the board of directors, solidifying the operational leadership core. To understand the scale of the Combat Hate Foundation’s operations, its financial disclosures demonstrate rapid capital expansion. In fiscal year 2024, the foundation reported total assets of $1,859,706, total revenues of $9,857,892, and total functional expenses of $11,943,380. The vast majority of these expenses are directed toward international grants, public relations campaigns, and the annual Mayors Summit Against Antisemitism. The Domestic Funding Architecture and the Vine and Fig Tree Pipeline The financial viability of the Combat Hate/CAM nexus is sustained by a continuous flow of domestic capital designed to isolate the organization from direct foreign funding streams that would trigger federal registration. The primary contributor is the Beren Sea Foundation, Adam Beren’s family charity, which has injected over $13.1 million into the Combat Hate Foundation since 2020. This is augmented by specialized donor-advised funds and family foundations, including a critical $250,000 financial pipeline from the New York-based Vine and Fig Tree Fund Inc., awarded in fiscal year 2024 for" general support for programs combating antisemitism and hate". The table below delineates the major financial pipelines sustaining the Combat Hate Foundation, illustrating the concentration of corporate oil wealth, family foundations, and specialized grantmaking networks. Funder / Donor Entity Tax Period / Fiscal Year Designated Purpose Grant Amount Beren Sea Foundation FY 2023 General Operating Support $3,592,222 Beren Sea Foundation FY 2022 General Operating Support $3,125,000 Beren Sea Foundation FY 2024 General Operating Support $2,775,000 Beren Sea Foundation FY 2020 General Operating Support $2,000,000 Beren Sea Foundation FY 2021 General Operating Support $1,500,000 Israel Henry Beren Charitable Foundation FY 2024 Combat Antisemitism Movement $500,000 Funder / Donor Entity Tax Period / Fiscal Year Designated Purpose Grant Amount Ric & Suzanne Kayne Foundation FY 2024 Annual Discretionary Giving $500,000 Fidelity Investments Charitable Gift Fund FY 2020 Exempt Charitable Purpose $450,000 Vanguard Charitable FY 2024 Exempt Charitable Purpose $305,000 Vine & Fig Tree Fund Inc. FY 2024 General Program Support $250,000 **Donor Advised Charitable Giving, Inc. FY 2022 Combating Antisemitism and Hate $200,100 While the Combat Hate Foundation operates as a recipient of these capital flows, it also acts as a primary donor to specialized research and advocacy groups. In 2022, the foundation contributed $75,000 to the Network Contagion Research Institute (NCRI) to fund social media tracking studies and $15,000 to the International March of the Living. Additionally, the foundation paid $35,000 in 2020 to Winning Strategies Washington to conduct federal lobbying on" education and advocacy related to anti-Semitism". The Vine and Fig Tree network itself represents a sophisticated, parallel funding structure. To consolidate its philanthropic reach, the Vine and Fig Tree Institute I Inc. was incorporated in New York in 2024 under the leadership of Chairman and President M. Michael Davis and Director and Treasurer Ari Gontownik, an Oliver Wyman consultant and Columbia Engineering graduate. In fiscal year 2025, this institute awarded an $850,000 grant to a single recipient: the Vine & Fig Tree Fund Inc., which in turn acts as a key donor to CAM, the Philos Project, and the Merona Leadership Foundation. Foreign State Institutional Ties and the Strategic Avoidance of FARA A critical examination of CAM’s operational timeline and leaked diplomatic communications reveals a calculated strategy designed to bypass FARA while executing domestic advocacy on behalf of the Israeli state. Under FARA, U. S. organizations directed, controlled, or funded by a foreign government must register with the Department of Justice, label their publications as foreign propaganda, and submit to intensive public disclosure of their activities and donors. Leaked Legal Frameworks and Intermediary Non-Profit Formations Leaked legal memos and communiqués from Liat Glazer, then a senior legal adviser to Israel’s Ministry of Strategic Affairs, demonstrate that Israeli officials viewed mounting FARA enforcement as a severe threat to their overseas advocacy efforts. Legal advisers noted that complying with FARA would require American partner groups to declare their materials as foreign propaganda and face onerous transparency requirements that would deter domestic donors. To circumvent these requirements, Glazer and other legal strategists proposed establishing a new American non-profit to act as an intermediary. Although this non-profit would not be formally managed by Israel, the government would maintain" means of supervision and management" through grant-making and" informal coordination mechanisms, " including oral meetings and updates. This structure was designed to ensure that no written record of agency existed while keeping operational objectives fully aligned. The Public-Private Funding Vehicles of Concert and Diaspora Affairs This strategy was executed during the tenure of Brigadier General Sima Vaknin-Gil, a former intelligence officer and Director-General of the Ministry of Strategic Affairs. Vaknin-Gil’s framework utilized a public-private partnership called Kela Shlomo (later renamed Concert, and currently operating as Voices of Israel ). This state-funded body was designed to channel government grants to international organizations that would, in turn, execute advocacy campaigns aligned with state interests. CAM was established in Kansas in 2019, exactly one year after the Ministry of Strategic Affairs finalized this FARA-mitigation strategy. Following her exit from government, Vaknin-Gil transitioned directly into CAM's governance structure, taking a seat on its board of directors. Despite CAM’s formal denials of receiving direct foreign government funding, the organization acknowledges that it collaborates closely with Voices of Israel (Concert) and the Israeli Ministry of Diaspora Affairs (which absorbed the functions of the Ministry of Strategic Affairs). This institutional coordination manifests in highly synchronized campaigns. For example, in February 2026, when the Israeli Ministry for Diaspora Affairs and Combating Antisemitism announced the forced halting of the humanitarian charity Oxfam’s operations in the Gaza Strip, CAM’s executive apparatus immediately launched a global media campaign. CAM CEO Sacha Roytman-Dratwa—himself a former commander of the IDF Spokesperson’s Unit's New Media Division—issued coordinated public statements defending the state's actions and accusing international NGOs of maintaining a" toxic antisemitic culture". The Personnel Revolving Door and Interlocking Directorate Matrix The execution of transnational advocacy campaigns requires a highly integrated network of personnel who move seamlessly between foreign military, intelligence, and diplomatic roles into domestic non-profit board seats and executive positions. By tracing these movements, a distinct interlocking directorate emerges across the Combat Antisemitism Movement, the Philos Project, the Merona Leadership Foundation, and the Vine & Fig Tree network. Governance Integration Across CAM, Philos, Merona, and Vine and Fig Tree The governance of these organizations is structurally linked through shared directors, common funding sources, and collective participation in elite donor coalitions: ● The Milstein Network and Merona: The Merona Leadership Foundation, based in Encino, California, is presided over by Adam Milstein, a commercial real estate investor, managing partner of Hager Pacific Properties, and co-founder of the Israeli-American Council. Gila Milstein, his wife, previously served as president. Merona is the primary financial backer of StopAntisemitism, paying the salary of its executive director, Liora Rez, and covering its operating expenses. Merona is a core member of the Impact Forum, a Los Angeles-based network of pro-Israel philanthropists that coordinates support for the Philos Project, the Louis D. Brandeis Center, and StopAntisemitism. ● The Philos Project: Directed by Executive Director Luke Moon, an ordained Southern Baptist minister, the Philos Project promotes" positive Christian engagement in the Near East". The organization's board has included influential political figures, such as Dan Senor (who serves as Treasurer and has held prominent roles as a U. S. foreign policy adviser) and Mark Tooley. ● The Vine and Fig Tree Network: This network acts as a quiet financial engine for these domestic advocacy groups. The Vine and Fig Tree Fund Inc. has issued consecutive $100,000 grants to both the Philos Project and the Merona Leadership Foundation, alongside its $250,000 grant to the Combat Hate Foundation. To support this operation, the Vine and Fig Tree Institute I Inc. was established in New York in 2024, led by Chairman and President M. Michael Davis and Director and Treasurer Ari Gontownik. The table below provides a structured mapping of this interlocking directorate, exposing how key individuals hold simultaneous positions across these entities while maintaining direct or historical links to foreign state apparatuses. Individual Name Domestic Non-Profit & Executive Roles Foreign State Apparatus Linkage Strategic Role within the Network Natan Sharansky Chair of Global Advisory Board, CAM Former Deputy Prime Minister of Israel; Former Chair, Jewish Agency Coordinates global political alignment and provides high-level diplomatic access. Sima Vaknin-Gil Board Member, CAM Former Director-General, Ministry of Strategic Affairs; Former IDF Chief Censor Designed the FARA-circumvention framework and public-private funding models. Sacha Roytman-Dratwa CEO, CAM Former Head of New Media, IDF Spokesperson's Unit Directs digital operations, social media influencer summits, and public campaigns. Barney Breen-Portnoy Editor-in-Chief, CAM Former IDF Spokesperson Manages the editorial strategy and media output of the advocacy network. Arie Lipnick Chair of U. S. Advisory Board, CAM Senior Advisor to Representative Elise Stefanik Directly interfaces with congressional leadership to shape federal investigative agendas. Aaron Keyak Special Representative, CAM; Board Member Former Deputy Special Envoy, State Department (2021-2025) Connects non-profit advocacy with federal diplomatic and foreign policy channels. Dan Senor Director & Treasurer, Philos Project Former U. S. Foreign Policy Advisor Integrates conservative foreign policy doctrine with domestic Christian Individual Name Domestic Non-Profit & Executive Roles Foreign State Apparatus Linkage Strategic Role within the Network Zionist advocacy. Luke Moon Executive Director, Philos Project; Co-Chair, independent task force Former IRD Business Manager & Missionary Mobilizes Evangelical grassroots networks and directs political task forces. Adam Milstein President, Merona Leadership Foundation Co-Founder, Israeli-American Council Manages funding allocations to StopAntisemitism and other campus advocacy groups. M. Michael Davis Chairman & President, Vine & Fig Tree Institute Non-profit Funder Oversees the consolidation of the Vine & Fig Tree grantmaking apparatus. Ari Gontownik Director & Treasurer, Vine & Fig Tree Institute Oliver Wyman Consultant; Columbia Engineering Graduate Manages financial tracking and regulatory compliance for the funding network. Administration Interface Nodes and Federal Legislative Liaisons The primary objective of this transnational network is the institutionalization of its policy goals within federal and municipal governing bodies in the United States. This is achieved by placing key personnel in government advisory positions, establishing legislative task forces, and systematically recruiting municipal mayors to implement localized speech restrictions and enforcement mechanisms. Federal Executive Alignments and the Department of Justice Advisory Architecture At the federal level, the network’s interface is driven by a highly coordinated revolving door of political advisors and diplomats. Arie Lipnick, the Chair of CAM’s U. S. Advisory Board, simultaneously serves as a senior advisor to Representative Elise Stefanik, who has used her seat on the House Republican leadership team to spearhead congressional investigations into academic and political speech on college campuses. This direct connection ensures that CAM’s strategic definitions of antisemitism are mirrored in congressional hearings and legislative proposals. Simultaneously, Aaron Keyak’s transition from his role as the State Department’s Deputy Special Envoy to Monitor and Combat Antisemitism (2021–2025) to CAM's Special Representative on International Affairs demonstrates how executive branch personnel are immediately absorbed back into foreign-aligned advocacy structures. Keyak, who also leads Capitol K Consulting alongside retired Ambassador Deborah Lipstadt, leverages his extensive federal network to reinforce CAM’s policy initiatives. On the political right, the National Taskforce to Combat Antisemitism —originally established at the Heritage Foundation and co-chaired by Philos Project Executive Director Luke Moon—serves as a primary policy incubator. Although CAM suspended its participation in the Heritage-hosted task force in late 2025 due to disputes over the platforming of far-right isolationist voices, the task force was subsequently reformed as an independent entity under Moon's leadership to continue crafting policy papers and organizing legislative firewalls. The Municipal Strategy and Local Administrative Co-optation Recognizing that federal legislation is subject to heavy constitutional scrutiny, the network has pioneered a highly effective municipal strategy designed to implement localized speech constraints and policy changes. In October 2025, CAM launched its Mayors Advisory Board, recruiting an inaugural cohort of North American local officials to drive its municipal policy agenda. This board is designed to implement CAM's signature Municipal Antisemitism Action Index, which establishes city-level criteria for policing local speech and adopting the IHRA definition. The chronological tracking of these key personnel movements from foreign-government-sponsored initiatives and federal advisory positions into domestic non-profits and policy-making nodes is detailed in the table below. Timeline / Era Key Individual Origin / Foreign Agency Linkage Domestic Non-Profit Role Current Federal / Policy Interface 2019 Adam E. Beren Owner, Berexco LLC; Republican Donor Founded Combat Hate Foundation and CAM Appointed to the U. S. Holocaust Memorial Council (2019) 2019–Present Sima Vaknin-Gil Former IDF Chief Censor & Director-General, Ministry of Strategic Affairs Board Member, Combat Antisemitism Movement Coordinates informal U. S. advocacy strategies via Voices of Israel 2021–2025 Aaron Keyak Jewish Engagement Director, Biden Campaign (2020) Special Representative, CAM U. S. Advisory Board (2025) Served as Deputy Special Envoy, State Department (2021–2025); runs Capitol K Consulting 2025 Arie Lipnick Strategic Campaign Advisor & Lee Zeldin Gubernatorial Aide Board of Governors & Chair of U. S. Advisory Board, CAM (2025) Senior Advisor to Rep. Elise Stefanik, managing policy and fundraising 2025–2026 Luke Moon Business Manager, Institute on Religion and Democracy Executive Director, Philos Project Co-Chair, National Taskforce to Combat Antisemitism (reformed independently in 2025) Timeline / Era Key Individual Origin / Foreign Agency Linkage Domestic Non-Profit Role Current Federal / Policy Interface 2025–2026 Sharona Nazarian Public Works Commissioner, Beverly Hills Member, CAM Mayors Advisory Board (Oct 2025) Mayor of Beverly Hills; implements local educational and speech policies 2025–2026 Scott Singer Mayor of Boca Raton, Florida Member, CAM U. S. Advisory Board Attorney and municipal leader; advocates for local speech policies Through this dual-track strategy, the network ensures that local municipal governments (through the Mayors Advisory Board) and federal agencies work in tandem. For instance, the Department of Justice’s newly announced Anti-Semitism Advisory Committee (ASAC), established under Executive Orders 13899 and 14188 and led by Leo Terrell, is launching a 15-city National Awareness & Action Tour. By coordinating with local mayors already integrated into CAM’s Advisory Board, ASAC’s federal tour can implement policy changes directly within local school districts, teacher unions, and municipal law enforcement agencies, bypassing traditional legislative channels. Strategic Synthesis and Future Policy Trajectories The structural, financial, and personnel cross-linkages documented in this report reveal a highly sophisticated transnational influence model. Rather than relying on overt diplomatic lobbying, which is subject to FARA tracking and disclosure laws, the foreign state apparatus has successfully integrated its operational directives into domestic U. S. 501(c)(3) structures. This model achieves its objectives through three main mechanisms: ● Financial Shielding via Domestic Intermediaries: The use of private family foundations (such as the Beren Sea Foundation and the Vine & Fig Tree Fund) to channel millions of dollars into organizations like the Combat Hate Foundation, Philos, and Merona creates a powerful layer of financial shielding. This structure allows these groups to execute foreign-aligned campaigns while maintaining the legal status of independent, domestic charities. ● Bypassing FARA through Informal Coordination: Leaked legal strategies from the Ministry of Strategic Affairs confirm that the domestic non-profit model was intentionally chosen to bypass FARA. By relying on informal, oral coordination and grant-making via public-private partnerships like Concert (Voices of Israel), the network avoids creating the paper trail of foreign direction that would trigger federal registration requirements. ● Localized Policy Implementation: By establishing structures like the Mayors Advisory Board, the network successfully bypasses federal oversight to implement its policy goals at the municipal level. This allows city-level ordinances and policy indices to be used to suppress political activism and enforce specific definitions of speech, effectively bypassing constitutional protections through localized administrative rules. Ultimately, this integrated network demonstrates how transnational actors can utilize the legal, financial, and political structures of an open society to build a highly coordinated, domestic policy-shaping apparatus. Works cited 1. 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