Barack Obama didn’t personally type up a fake invoice. He didn’t personally invent “meals served” that never existed. He didn’t personally staff every nonprofit with grifters and cousins and “community leaders” who magically become grant administrators the second the check clears. But if you’re asking the more important question: who built the architecture that made this kind of fraud scalable, repeatable, and almost impossible to unwind once it metastasized? The answer, predictably, keeps coming back to Obama.
Because that’s when the United States took a pre-existing refugee model and turbocharged it. That’s when Washington leaned even harder into outsourcing core government functions to “partners.” That’s when the federal government turned the Office of Refugee Resettlement into a high-volume grant-and-contract distribution hub, and treated “how many bodies moved” as a success metric while treating oversight as a paperwork nuisance. By the time the system was fully built out, the fraud didn’t need a mastermind. It needed a template. And the template was already sitting there, paid for, staffed up, and politically protected.
Fast-forward to now. The Treasury Department is publicly describing an “unprecedented Somali organized crime scheme” in Minnesota—so severe it triggered federal financial countermeasures and warnings to financial institutions about fraud tied to federally funded benefit streams. That’s not a blogger’s fever dream. That’s Treasury, in writing, talking about organized fraud connected to taxpayer-funded programs.
So what happened in between? The short version: a humanitarian relief framework was converted into an incentives machine. The long version is the story the political class doesn’t want told, because too many powerful people—bureaucrats, contractors, NGOs, corporate “partners,” and the politicians who launder policy through them—benefited from the pipeline.
The pipeline was built on outsourcing the state:
Refugee resettlement in the U.S. has long been a public-private arrangement. Refugees are referred and processed through an international and federal pipeline, then placed with the help of “
” and local nonprofits that provide services in American communities. The point isn’t that NGOs were suddenly invented in 2009; the point is that under Obama, the federal government expanded the scale and deepened the dependency, making NGOs not merely helpers—but the operating system.
And then the umbrella got bigger. It wasn’t just “refugees” in the narrow sense. The Wilson-Fish alternative model, explicitly described as a “
” where a single agency administers cash, medical, employment services, and case management, was operating in 13 states by the Obama period, and ORR used single-source grants to keep those programs running at scale. Read that again: a single agency, administering multiple benefit streams, on a model designed to bypass state administration when the feds want an alternative.
Then came the unaccompanied minor surge machine. The William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 shifted responsibilities toward HHS/ORR. In early 2009, the federal government formally delegated and re-delegated authority under that law—explicitly envisioning “
” with nongovernmental organizations and creating new lanes for ORR-led activity. And within weeks, ORR was issuing urgent grants to expand NGO-run shelter and foster care capacity, explicitly stating that “existing grantees” were the only entities with the infrastructure to meet the “
”
That is the Obama pattern in a nutshell: crisis + urgency + “only the incumbents can do it” = rapid growth of a contractor ecosystem with minimal competition and maximal political cover.
Paid by the head, protected by the narrative
Now let’s talk incentives.
In 2015, ORR’s Voluntary Agencies Matching Grant Program was structured so that participating voluntary agencies could receive up to $2,200 in federal funds per client,
with ORR awarding $2 for every $1 raised by the agency in cash and in-kind support. It is also explicit that competition is limited to the voluntary agencies already providing Reception & Placement services—meaning the same small set of national players kept the franchise.
That matters. Because when the government funds per capita and limits competition to the “approved” club, what do you get? You get a permanent resettlement industry. You get entities that can plausibly claim moral authority (“humanitarian relief”) while operating under a business model where more arrivals equals more funding, more staff, more subcontractors, more political leverage. More people. More grants. More “capacity building.” More pressure to keep the spigot open.
And those per-capita incentives aren’t abstract. In 2009, ORR issued “
” explicitly because there were “higher number[s] of arrivals than anticipated.” One award was $414,041 for the USCRI Vermont program; another was $181,184 for North Dakota’s Wilson-Fish program. The notice states that ORR policy and the Refugee Act framework mandated reimbursements tied to arrivals and the costs of assistance. In other words: arrivals drive supplements; supplements drive capacity; capacity drives the argument for more arrivals.
You don’t need a conspiracy when you have a flywheel.
ORR didn’t just grow; it became a pass-through
Here’s the part that should sober you up:
Congress appropriated nearly $1.6 billion for ORR’s Refugee and Entrant Assistance Programs in FY2015, “
That’s not a rounding error. That’s an entire parallel welfare-and-services state, constructed inside an office most Americans couldn’t name, almost entirely executed through contractors and grantees.
And when you build a system that moves that much money through grants and contracts, you inevitably create what every investigator recognizes: a target-rich environment. You’re not just funding services; you’re funding rent-seeking. You’re funding grant writers. You’re funding compliance theater. You’re funding sub-grants, subcontracts, “consultants,” “navigators,” and every form of middleman who learns exactly which forms to file, which boxes to check, and which sympathetic buzzwords to use.
Then, to complete the cycle, ORR and related programs also seeded and supported refugee-led and ethnic community-based organizations as eligible grantees—organizations that, by definition, can be founded and led by current or former refugees. That may be well-intentioned. But in an accountability-light ecosystem, it also creates an obvious vulnerability: the same networks that receive funds can also control access, referrals, language navigation, community “
” and political pressure campaigns when scrutiny arrives.
Was this “the plan”? Maybe not in the cartoon-villain sense. But did the Obama administration build and defend a structure that predictably expanded taxpayer funding flows to noncitizens and to NGOs operating as gatekeepers and service monopolies? Yes. The effect is measurable: higher ceilings, higher throughput, higher funding, more outsourced authority, and a thicker “nonprofit” layer between taxpayer and outcome.
The Oversight Vacuum
When government becomes a check-writing operation, oversight becomes the only thing standing between “public-private partnership” and “organized extraction.”
And we have official documentation showing oversight failures and warning signs. In the unaccompanied children space, GAO reported problems with monitoring and oversight in ORR’s care arrangements and made recommendations for improvement, exactly the kind of alarm bell you’d expect when the government rapidly expands a network of grantees and facilities under pressure.
CRS also documents
of the UAC surge and the strain it put on the system. The federal response was to open more shelters, expand capacity, and pour more money through ORR. That may solve an immediate bottleneck. But it also normalizes emergency procurement as a permanent operating mode, and emergency procurement is where accountability goes to die.
Then you get the “lottery effect” across locations. You get inconsistent standards. You get subcontracting chains so long nobody can tell you where the money ended up without a forensic accountant and a subpoena. And—critically—you get political insulation, because anyone raising oversight questions can be smeared as “anti-refugee” rather than “pro-taxpayer.”
That’s how fraud ecosystems grow: not because everyone is corrupt, but because the system is designed to treat scrutiny as cruelty.
Somali resettlement: the numbers matter, and the politics weaponize them
At this point, the exact headcounts are a distraction, and a deliberate one. The political class loves to argue numbers because it keeps the conversation safely away from structure. What matters is not whether a particular statistic is exaggerated or understated. What matters is that the Obama-era framework embedded large populations into a dense web of federally funded benefits, then outsourced the administration of those benefits to NGOs and community-based organizations that operate with limited competition, limited transparency, and enormous political insulation.
You can accept every “fact check” and still arrive at the same conclusion: when you combine sustained federal funding, per-capita incentives, outsourced authority, and moralized enforcement, you create a system that is structurally vulnerable to abuse. That vulnerability has nothing to do with race or ethnicity and everything to do with governance. This is not a cultural argument. It is a systems argument. And the system was built to be exploited.
The Fraud Template Goes National
If you want a real-world example of how “nonprofit” becomes a mask for industrial fraud, look at Minnesota’s Feeding Our Future scandal.
In September 2022, the Department of Justice announced federal charges against 47 defendants for their alleged roles in a $250 million fraud scheme exploiting a federally funded child nutrition program during COVID, described as the largest pandemic relief fraud scheme charged at the time, involving “
” The allegations include conspiracy, wire fraud, money laundering, and bribery.
By 2025, the lesson wasn’t about one nonprofit or one program, it was about the environment. The Feeding Our Future prosecutions demonstrated that Minnesota’s nonprofit and federal funding ecosystem could be exploited at industrial scale, with inflated claims, layered subcontracting, and minimal real-time oversight. That matters because SomaliFraud follows the same structural logic. Different programs. Different justifications. Same playbook. What we are investigating now is not a surprise, it is what happens when a decade of outsourced administration, per-capita incentives, and moral insulation finally meets organized exploitation.
Now, be careful and honest: Feeding Our Future was not an ORR program. It was a child nutrition program fraud. But the mechanism is the same mechanism: government money routed through nonprofit entities, inflated claims, weak oversight, and networks that learn how to monetize bureaucracy.
That’s the point. The Obama-era refugee/entrant model didn’t have to be the exact program being looted for it to be the training ground. It normalized the idea that “community nonprofits” are both the moral shield and the financial conduit. Once that’s normalized, the same playbook migrates across agencies and funding streams.
And now Treasury is talking about “Somali organized crime” schemes and taking financial countermeasures in Minnesota. You can argue over politics. You can argue over rhetoric. But you can’t argue with the core fact: the fraud is big enough that federal agencies are taking extraordinary steps.
So what did Obama actually do?
He expanded the throughput and defended it with moral language.
He strengthened the role of NGOs as quasi-government administrators, including through models like Wilson-Fish that centralize benefits and services under single agencies via single-source awards.
He presided over a period where refugee ceilings and admissions surged—culminating in the FY2017 ceiling of 110,000 (
) and a major ramp-up late in 2016, according to Pew’s analysis and CRS reporting.
He helped build a political economy around resettlement, including explicit efforts to recruit private sector “
” and corporate partnerships as part of the refugee expansion narrative.
That is the “greenlight” in real life: not a secret memo, but a structure that rewards scale, relies on intermediaries, and grows faster than accountability.
Where Do We Go Now?
If we want to stop the next “Feeding Our Future,” the next “SomaliFraud,” the next alphabet-soup nonprofit laundering operation, we need to stop pretending this is an accident.
First, end per-capita funding structures that treat human throughput as a revenue model for NGOs. The moment “more clients” equals “more money,” you’ve created a conflict between service and self-interest.
Second, cut the subcontracting chains. If a federal dollar is spent, the public should be able to see the prime recipient, every subrecipient, the deliverables, and the audit results in plain English.
Third, return more control to states and localities that actually live with the consequences, while requiring transparent performance metrics that aren’t written by the very organizations being paid.
Fourth, enforce penalties that are not symbolic. Clawbacks. Debarment. Prison. No more “settlements.” No more “mismanagement.” Fraud is theft. Theft is theft.
Obama didn’t need to “plan” a fraud ring for this to happen. He built a sprawling, outsourced, moralized bureaucracy where the money moved faster than the oversight and where questioning the pipeline became taboo. That’s how you manufacture a fraud economy. And once you build it, it doesn’t stay “humanitarian.” It gets harvested.
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