I was talking with someone who served on the board of a local nonprofit organization. During our conversation they mentioned that everything seemed to be running smoothly. Donations were coming in, bills were being paid, volunteers were happy, and the organization's mission continued moving forward.
Then they said something that caught my attention. "Unlike a few other NGOs, we've never really worried about fraud. Fortunately, everyone here knows each other." I thought to myself, “You may be surprised my friend!” Then I thought “Is my opinion of NGOs just being swayed by a few bad eggs in the news?”
The truth is, trust is one of the characteristics that makes nonprofit organizations so effective. People donate because they trust the organization. Volunteers give their time because they believe in the mission. Board members often serve without compensation because they genuinely want to improve their communities.
Ironically, that same atmosphere of trust can sometimes create opportunities for financial mistakes or, in rare situations, intentional misconduct that goes unnoticed longer than it otherwise would. Of course this does not mean nonprofit organizations are inherently prone to fraud.
A quick ChatGPT search will tell you that currently there are approximately 1.9 to 2.0 million registered nonprofit organizations operating in the United States. The U.S. generally tracks nonprofits rather than NGOs as a separate legal category. The Federal Trade Commission (FTC) recorded 11,019 charitable-solicitation reports in 2024, but those are consumer reports, not confirmed fraudulent NGOs.
The IRS publishes organizations whose exemption was automatically revoked, but that is usually for failure to file Form 990 for three consecutive years, not proof of fraud. The IRS also lists revoked 501(c)(3) determinations, but those revocations can involve many compliance issues, not necessarily fraud.
There is no reliable official count of how many U.S. NGOs/nonprofits are “fraudulent, but a practical estimate of confirmed fraudulent NGOs is likely to be a tiny fraction of all nonprofits, probably well under 1% in any given year.
As you can see, the overwhelming majority of nonprofit organizations are operated by honest, hardworking people who care deeply about serving others. Nevertheless, history has shown that every organization, regardless of size or mission, benefits from good governance, sound accounting, and appropriate internal controls.
The purpose of this article is to explore how experienced CPAs and Enrolled Agents can recognize when an organization's financial records begin telling a story that deserves a closer look.

Could You Spot Non For Profit NGO Fraud
If it is too good to be true....it is probably a fraud. - Ron Weber
Financial Statements Tell Stories
One of the most interesting aspects of accounting is that financial statements often reveal questionable patterns long before anyone notices a problem with the organization. A single unusual transaction can go unnoticed. However, when several unusual transactions begin appearing together, they may trigger additional questions.
Experienced financial professionals often become skilled at recognizing these patterns. Like a physician reviewing laboratory results, an EA or CPA generally does not jump to conclusions based on a couple of unusual transactions alone. Instead, they’ll look for trends, inconsistencies, and relationships between different accounts.
Many times these questions uncover nothing more than bookkeeping errors, and they identify an opportunity to improve internal controls. Then again, in rare cases they may reveal something requiring further investigation.
What Might an EA or CPA Notice?
One of the first areas many financial professionals should review is the organization's cash activity.
Unusual Cash Transactions?
Yes, cash remains one of the highest risk assets because it is easily transferred and often difficult to trace.
Some possible observations might include:
Numerous cash withdrawals with limited supporting documentation.
Large cash reimbursements instead of payments through normal purchasing procedures.
Repeated smaller transactions occurring just below the approval thresholds.
Cash receipts that do not appear consistent with fundraising activity.
Make no mistake, none of these items automatically indicate fraud. They simply raise questions, such as why was the cash needed? Or why wasn’t proper documentation maintained? Did someone review and approve the expenditure?
Often there is a perfectly reasonable explanation. Good accounting begins by asking questions, but not by making unfounded accusations.
Vendor Relationships
Vendor payments can also reveal useful information.
Here are some red flags that Financial Crimes Enforcement Network (FinCen) says financial professionals should look out for:
Unexplained money movement between related companies, owners, trusts, or nonprofits.
Circular transactions where money leaves one account and comes back through another entity.
Loans on the books with no real loan documents or no evidence cash was actually advanced.
Large related-party receivables/payables that stay open with no explanation.
Clients using shell companies or complex ownership structures with no clear business reason.
All-cash real estate purchases by LLCs, trusts, or entities, especially when the true beneficial owner is unclear.
Funds coming from high-risk jurisdictions or from unrelated third parties.
Client reluctance to provide ownership, source-of-funds, or identity information.
Transactions inconsistent with the client’s business model, revenue level, or normal activity.
False, vague, or changing explanations for transfers, donations, loans, or expenses.
These transactions may suggest that vendor files deserve more review. Simple verification procedures, confirming addresses, reviewing invoices, and validating vendor existence can significantly reduce risk.
Payroll Observations
Payroll is another area where strong internal controls become extremely valuable.
Experienced practitioners may notice:
Payroll expenses are increasing faster than staffing levels.
Overtime appearing inconsistent with operations.
Employees receiving payments after termination.
Multiple direct deposits using the same bank account.
Missing personnel documentation.
Significant bonus payments without board approval.
Payroll errors are many times often just mistakes. Nonetheless, because payroll typically represents one of an organization's largest expenses, periodic review is simply good financial management.
Grant Accounting
Many nonprofit organizations operate using grants that contain very specific restrictions.
Financial professionals should pay close attention to:
Restricted funds being used for unrelated purposes.
Missing documentation supporting grant expenditures.
Budget categories exceeding grant limitations.
Late grant reporting.
Inconsistent reporting between financial statements and grant reports.
Most grant agreements clearly define how funds may be used. Maintaining separate accounting for restricted funds helps ensure compliance while giving grant providers confidence that resources are being used as intended.
Governance Sometimes Reveals More Than Just Numbers
One lesson repeated throughout both the financial profession and fraud research is that governance matters.
Healthy organizations generally demonstrate:
Active board participation.
Regular review of financial statements.
Independent oversight.
Documented meeting minutes.
Annual conflict-of-interest disclosures.
Clearly defined approval authority.
A sign of weak governance sometimes appear when:
One individual controls every financial function.
Board meetings rarely review financial reports.
Supporting documentation is difficult to locate.
Policies exist but are not followed consistently.
Questions about finances are discouraged and or punished.
None of these circumstances prove misconduct alone. Unfortunately the organization may be just sloppy, simply reducing transparency. When these start to add up to a pattern, something may be causing your warring bells to go off. Taking a closer look is really your job. Good governance protects the honest public, just as much as it protects the organization’s assets.
The Fraud Triangle
One concept frequently discussed by fraud examiners is known as the Fraud Triangle. It suggests three conditions often exist when occupational fraud occurs:
Pressure
Financial hardship, unrealistic performance expectations, or personal circumstances.
Opportunity
Weak internal controls or insufficient oversight.
Rationalization
An individual's ability to justify inappropriate behavior.
Organizations usually have much greater influence over opportunity than over the other two elements. Strong governing systems, approval procedures, reconciliations, and board oversight can reduce the opportunity for fraud while simultaneously protecting the organization and its employees.
Practical Internal Controls Every Organization Can Implement
Fortunately, effective controls cost very little.
Separate Duties
Whenever practical, different individuals should:
Approve purchases.
Write checks.
Record transactions.
Reconcile bank accounts.
Even small organizations can often divide responsibilities among volunteers or board members.
Perform Monthly Bank Reconciliations
Reconciling every bank account monthly remains one of the most effective internal controls available. Independent review of reconciliations provides additional assurance that unusual items receive timely attention.
Review Financial Statements
Board members do not need accounting degrees, but they do need to be curious.
They need to ask questions like:
"Why did fundraising expenses increase?"
"Why are travel costs higher than last quarter?"
"Why did payroll increase when staffing remained unchanged?"
Questions like these will encourage healthy discussions.
Maintain Written Policies
Organizations benefit from documented policies covering:
Expense reimbursements.
Credit card usage.
Purchasing authority.
Travel expenses.
Document retention.
Conflicts of interest.
Consistency becomes an organization's greatest strengths.
Mistakes to Avoid
First, don’t rely exclusively on trust. Yes trust is essential, but internal controls protect that trust. Second, postponing reconciliations until year end is a big mistake, because errors become much easier to resolve when discovered quickly. Third, allowing one individual to control every accounting function is not the wisest thing to do. Checks and balances are a good thing.
Even the appearance of independence will strengthen an organization’s credibility. Finally, and it goes without saying, but I’ll say it anyway, having an internal and external audit is a great thing to do.
What Is A CPA or EA To Do?
If a financial professional notices several unusual patterns. What do they do then? Rather than assuming wrongdoing, a practitioner should begin by gathering additional information, by requesting supporting documentation.
They can ask management to explain the unusual transactions. They can recommend strengthening internal controls or improving documentation. If concerns remain unresolved, practitioners should follow the ethical standards of their profession, which are to document your observations in detail, and consider whether additional consultation, legal advice, or reporting obligations apply after referring to the applicable laws, and professional standards.
The objective is not to prove guilt. The objective is to ensure accurate financial reporting while protecting the organization and everyone involved.
Questions Every Board Member Should Ask
Before approving financial statements, board members might consider asking:
Were all bank accounts reconciled this month?
Were financial statements reviewed independently?
Were restricted funds used appropriately?
Have significant budget variances been explained?
Are payroll records current?
Were new vendors properly approved?
Have conflicts of interest been disclosed?
Is documentation available to support significant expenditures?
These questions rarely require accounting expertise. They simply encourage thoughtful oversight.
Final Thoughts
Most nonprofit organizations exist because people genuinely want to improve the lives of others.
That mission deserves strong financial stewardship. Good bookkeeping cannot eliminate every risk. Neither can annual audits, but it helps.
However, thoughtful governance, accurate accounting, regular reconciliations, transparent reporting, and healthy curiosity can significantly reduce opportunities for mistakes while strengthening public confidence. Maybe that’s one of the greatest benefits accounting professionals provide.
They do not simply prepare tax returns or financial statements. They help organizations build systems that allow charitable missions to continue serving communities for years to come. I know this was a lot of information, so thanks for hanging in there.
Ways The Smith Advisory Can Help
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Disclaimer
This article is provided solely for informational and educational purposes and is intended to encourage discussion about nonprofit governance, accounting, and taxation. It is not legal, tax, accounting, or investment advice and is not directed toward any specific individual, organization, or factual situation. Every nonprofit organization operates under its own unique circumstances. Readers should consult a qualified CPA, Enrolled Agent, attorney, or other professional advisor before making financial, tax, governance, or compliance decisions.
Selected References
Internal Revenue Code § 501(c)
Internal Revenue Code §§ 511–514 (Unrelated Business Income Tax)
Internal Revenue Code § 6033 (Annual Information Returns)
Internal Revenue Code § 4958 (Intermediate Sanctions)
IRS, Tax Exempt Organization Search
IRS, Instructions for Form 990
IRS, Instructions for Form 990-T
Association of Certified Fraud Examiners (ACFE), Occupational Fraud Reports
AICPA guidance on nonprofit governance and internal controls
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