Humpty Dumpty Institute

The central relationship is with Jeffrey Epstein, mediated through his brother Mark Epstein. According to the 2015 IRS 990 return, Mark is identified as an HDI director, and the return bears his signature as “Mark L Epstein, Director” ⁵². According to Epstein-file documents, Mark loaned HDI over $100,000 in 2014 and participated in the 2013 Bahrain and 2014 Azerbaijan CODELs ⁹⁶. In a December 22, 2014 email to Jeffrey, Mark wrote: “We (Humpty Dumpty Institute) led a congressional delegation to Bahrain to meet with ministers and the president (king/head poobah), opposition leaders, senate, head of the US Navy 5th fleet (headquartered in Bahrain) etc” ⁶. He added: “I did not know you were doing this kind of stuff; I was also on one to Azerbaijan, and might go on one to Turkey/Cypress in March” ⁶. According to analysis of that exchange by Epstein-file reviewers, the phrasing “I did not know you were doing this kind of stuff” implies Jeffrey had separate involvement in similar diplomatic-access activities ⁹.

Amir Dossal, former United Nations Chief of Partnerships and chairman of the Global Partnership Forum, appears as ex officio director on the HDI 2015 990 ⁵. On June 20, 2013, Dossal co-hosted a UN Conference Building event on oceans and Sustainable Development Goals alongside Ghislaine Maxwell, representing the TerraMar Project, and Stuart Beck, Palau’s ambassador ¹⁶¹⁷. That event placed an HDI director in direct programmatic collaboration with Maxwell at the United Nations ¹⁶. Fifteen months earlier, on August 30, 2011, Dossal appeared alongside Deutsche Bank Global Head of Asset Management Kevin Parker and Russian Duma member Ilya Ponomarev at the New York Academy of Sciences “Science & the City Gala,” honoring UN Secretary-General Ban Ki-moon, with James Simons, James Watson, and Jack Rosen also in attendance ¹⁸¹⁹.

Cross-reference of the 2015 990 filing and HDI board listings indicates a 14-member body chaired by Al Khalafalla, with chairman emeriti Constance Milstein — later a Biden ambassador nominee to Malta — and Sonnenfeldt ⁵²⁰². According to the same HDI board compilation, co-founder William Rouhana served as chairman since 2010 and as CEO of Chicken Soup for the Soul Entertainment, with other directors including former Congressman Benjamin Gilman, Walter Arbib of SkyLink Group, and Jay Snyder of HBJ Investments ²⁰. According to the 2015 return, co-founder and president since 1998 Ralph Cwerman drew $145,458 in annual compensation at 40 hours per week ⁵². According to the Epstein-file compilation of HDI personnel, Executive Director Joseph Merante, a former State Department Foreign Service officer, managed CODEL operations and served as the point of contact for delegation logistics and the Taihe Institute partnership ²⁰¹¹.

HDI’s core operational activity is the organization of private Congressional Delegations. Cross-reference of HDI-produced agendas and Epstein-file emails indicates HDI organized 52 or more CODELs to over 30 countries over roughly two decades, hosting more than 250 Members of Congress and 400 senior Congressional staff members to the UN and countries across the Middle East, Africa, the former Soviet Union, the Caribbean, and Asia ³⁹. According to the same cross-reference, documented destinations include Azerbaijan, Bahrain, Turkey, Cyprus, and UN headquarters in New York ³²¹. According to CODEL recruitment emails recovered from Epstein’s files, these trips were “entirely first class with all first class accommodations” ⁸.

The Azerbaijan CODEL running from May 30 through June 4, 2014, is the most fully documented example. According to the agenda recovered from Epstein’s document files, the delegation met with President Ilham Aliyev, US Ambassador Richard Morningstar, Foreign Affairs Minister Elmar Mammadyarov, and parliamentary committees ²¹⁴. According to analysis of the May 22, 2014 email chain, when participants dropped out, HDI Executive Director Joseph Merante emailed seeking replacements from “media, finance, banking, education” ⁷⁸. According to that same email chain, Mark Epstein forwarded Merante’s email to Jeffrey Epstein on May 22, 2014 with the note “In case you know someone and want to do them a favor: (let me know)” ⁷⁸. According to the Epstein-file reviewers’ analysis of that forward, Jeffrey was offered the ability to fill empty seats on a delegation scheduled to meet a head of state ⁷⁹.

According to the Epstein-file reviewers’ compilation of HDI Congressional Advisory Board membership, as listed in 2022 the board included 33 or more current and former lawmakers from both parties: Don Bacon (R-NE), Andre Carson (D-IN), Buddy Carter (R-GA), Judy Chu (D-CA), Yvette Clarke (D-NY), Jim Clyburn (D-SC), Ruben Gallego (D-AZ), Raul Grijalva (D-AZ), Andy Harris (R-MD), Jim Himes (D-CT), Hank Johnson (D-GA), Robin Kelly (D-IL), Gregory Meeks (D-NY), Barry Moore (R-AL), August Pfluger (R-TX), Mark Pocan (D-WI), Bennie Thompson (D-MS), Maxine Waters (D-CA), Debbie Wasserman Schultz (D-FL), and Frederica Wilson (D-FL) ¹⁰. According to the same compilation, former advisory board members included Mark Meadows, Adam Schiff, and Sheila Jackson Lee ¹⁰. Cross-reference of this bipartisan roster with HDI’s zero Lobbying Disclosure Act filings is the basis for the regulatory-gap framing pursued by the Epstein-file reviewers ²²¹².

According to analysis of Epstein-file materials and HDI public statements, in August 2017 HDI formalized a partnership with the Beijing-based Taihe Institute ¹¹. According to the same analysis and the FARA analysis of the record, reviewers characterize Taihe’s senior fellow roster as including 12 or more current and former members of the Chinese Communist Party and the People’s Liberation Army ¹¹¹². According to records of the Taihe Civilizations Forum, HDI Executive Director Joseph Merante presented at the Beijing forum in August 2017 and again at the September 6 through 8, 2019 forum ¹¹. According to the reviewers’ summary of the partnership, Ruby Wang, Senior Vice President at Perfect World, a Chinese gaming company, and a Taihe fellow, joined the HDI board ¹¹.

The partnership drew scrutiny from media and Congress. According to the Epstein-file reviewers, reporting by the Washington Examiner described HDI’s CCP connections and preceded multiple Congressional resignations from the HDI Advisory Board ¹¹¹⁰. According to the FARA analysis of the record, Taihe co-authored a report that called the United States a “failed country” and promoted the claim that COVID-19 leaked from a Maryland military base ¹². According to the same analysis, HDI stated publicly that it “never accepted any funds from the Taihe Institute or any Chinese Government organ or entity” ¹². According to the same FARA analysis, 22 USC 611(c) defines an “agent of a foreign principal” to include any person who acts “at the order, request, or under the direction or control” of a foreign principal, meaning direct funding is not the only trigger ¹².

According to the FARA analysis of the HDI record, cross-reference of HDI’s CODEL operations, the Taihe partnership, and the FARA and LDA rolls is the basis on which Epstein-file reviewers describe HDI as fitting a “shadow lobbying” pattern — an investigator synthesis, not a regulatory determination ¹². According to the same analysis, the China-United States Exchange Foundation, conducting comparable China-US influence activities, registered under FARA with four separate registrants: Capitol Counsel #6328, Wilson Global #6584, BLJ Worldwide #5875, and BGR Government Affairs #5430 ¹². According to the FARA and LDA analysis, the parallel dossier International Peace Institute reflects a closely related pattern, with both institutes showing zero FARA and zero LDA filings despite overlapping Congressional engagement ²².

Cross-reference of HDI’s IRS 990 filings from 2011 through 2023 indicates a steep financial decline ¹³¹⁴². According to the 990-series review, revenue peaked at $1.82 million in 2011, held at $1.64 million in 2012 and $1.70 million in 2013, and then dropped to $1.47 million in 2015, $481,000 in 2016, $401,000 in 2017, and $227,000 in 2018 ¹³. According to the same cumulative analysis, a brief spike to $360,000 in 2019 was followed by $202,000 in 2020, $155,000 in 2021, $174,000 in 2022, and $221,000 in 2023 ¹³¹⁴. According to the same review, total assets peaked at $287,000 in 2011 and stood at $170,000 in 2023, reflecting a revenue decline of roughly 74 to 80 percent from peak to trough depending on the trough year used ¹⁴.

According to the HDI 2014 990 filing, Mark Epstein loaned HDI over $100,000 in 2014 — a personal loan from a sitting board director to the organization he governed ¹². According to the 2015 return signed by Mark Epstein as director, the filing flagged “Yes” on Line 25a for an excess benefit transaction with a disqualified person, “Yes” on Line 5a for participation in a prohibited tax shelter transaction, and disclosed foreign bank accounts ⁵². According to the Epstein-file reviewers, cross-reference of those three disclosures on a single return is anomalous for a nonprofit of HDI’s size ⁵.

According to SBA FOIA records, in April 2020 HDI received a Paycheck Protection Program loan of $40,656 from Cross River Bank, fully forgiven at $41,277.54 with interest, and a second-draw PPP loan of $41,534 ¹⁵. According to the same records, the listed address was 140 Thompson Street, Apt 2E, a SoHo residential unit, with three reported jobs under NAICS 813319, Social Advocacy Organizations ¹⁵. According to analysis by the HDI-file reviewers, three reported jobs is notable for an organization operating dozens of international CODELs, indicating volunteer or contractor-heavy operations ¹⁵. According to the cumulative 990 analysis, the revenue trajectory parallels, at smaller scale, the contraction at International Peace Institute, whose assets fell 73 percent from $12.6 million to $3.9 million over a similar period; both organizations connect to the Epstein network through distinct pathways — HDI through Mark Epstein and Amir Dossal, and IPI through Terje Rod-Larsen and Gratitude America ¹⁴.

According to the FARA and LDA analysis of the record, HDI carries zero FARA registrations and zero filings in Senate Lobbying Disclosure Act records, despite its Taihe Institute partnership and its role facilitating meetings between US lawmakers and foreign heads of state including Azerbaijan’s President Aliyev ¹²²³. According to the same review, the absence of LDA filings is paired with a 33-member Congressional Advisory Board and 52 or more CODELs organized by HDI, with delegation slots offered to non-HDI principals through informal email forwarding ²²⁷⁸. According to the FARA analysis of the record, in this framing the HDI-file reviewers treat the absence of registration as anomalous, not as a determination of violation ¹²²².

According to the FARA analysis of the HDI record, 22 USC 611(c) defines an “agent of a foreign principal” to include any person who acts “at the order, request, or under the direction or control” of a foreign principal ¹². According to the same analysis, HDI’s Taihe partnership involved joint events, shared speakers, and co-produced publications — activities performed by other organizations with Chinese government connections that have triggered FARA registration ¹². According to the same analysis, HDI’s stated position that it received no funds from Taihe or any Chinese government entity addresses only the funding prong and does not resolve whether the partnership constitutes direction, control, or agent-of status under the broader statutory framework ¹².

Review of the 2015 990 return indicates the filing flagged excess benefit transactions, prohibited tax shelter participation, and foreign bank accounts ⁵². According to the Epstein-file reviewers, the return was signed by Mark Epstein — the board member through whom Jeffrey Epstein was offered the ability to place individuals on Congressional delegations ⁷⁸. According to FARA-database searches performed in the same review, no public record of DOJ National Security Division action or Congressional inquiry into HDI’s FARA status has been identified ²³. According to the FARA and LDA analysis, the HDI pattern parallels the one documented at International Peace Institute, where Epstein-file reviewers have applied the same “shadow lobbying” framing to a different set of foreign-government and Congressional interfaces ²².