The auditors noted that “some interviewees reported conflicts of those raising funds or donors, some of whom may have an expectation of quid pro quo benefits in return for gifts.” They also flagged a potential problem in the charity’s IRS filing:
… the IRS Form 990, which is signed under penalties of perjury and is publicly available, asks (a) whether the Foundation has a written conflict-of-interest policy, (ii) whether directors, officers, and key employees are required to annually disclose interests that could give rise to conflicts of interest, and (iii) whether the Foundation regularly and consistently monitors and enforces compliance with its conflict-of- interest policy. The Foundation indicated on its 2010 Form 990 that it has a written conflict-of- interest policy, requires annual disclosure of potential conflicts of interest, and monitors and enforces compliance with the policy. However, we did not find evidence of that enforcement.
…Other problems with the Clinton Foundation at the time included that its board did not have a chair, and was not very involved in running the charity. In a footnote, the audit commented: “We were also told that at CHAI [the Clinton Health Access Initiative], [CEO] Ira Magaziner set his own salary.”