Humpty Dumpty Institute
HDI organized 52+ Congressional Delegations while maintaining a CCP/Taihe Institute partnership and Epstein family board involvement, with no FARA or lobbying registration despite activities that triggered registration at comparable organizations.
The Humpty Dumpty Institute (HDI) is a New York nonprofit incorporated on October 19, 1998 (NY Corp #2307873, EIN 13-4028567), originally registered at the Central Park West apartment of co-founder Michael W. Sonnenfeldt, according to review of corporate filings and 990 records 1. Its stated mission — organizing Congressional Delegations (CODELs) and facilitating dialogue between U.S. lawmakers and foreign governments — placed it at the center of overlapping influence channels documented in the Jeffrey Epstein files. Mark Epstein, Jeffrey’s brother, served on the HDI board, signed its 2015 IRS 990 return, loaned the organization over $100,000 in 2014, and personally participated in first-class delegations to Bahrain and Azerbaijan, as records show 12. When delegation slots opened on a May 2014 trip to Baku, Mark forwarded the recruitment email directly to Jeffrey, offering him the ability to place people from “media, finance, banking, education” on a Congressional delegation that would meet Azerbaijan’s president 3.
Analysis of records indicates HDI organized 52 or more CODELs to over 30 countries, hosting 250+ Members of Congress and 400+ senior staffers 4. Its Congressional Advisory Board included 33 current and former lawmakers spanning both parties. Examination of public records shows that in August 2017 HDI formalized a partnership with Beijing’s Taihe Institute, a think tank whose senior fellows include 12 or more current and former CCP and PLA members 5. Records indicate the partnership drew media scrutiny and Congressional resignations from the HDI advisory board, yet HDI maintained the relationship through at least the September 2019 Taihe Civilizations Forum in Beijing 6.
Analysis of FARA and LDA filings shows HDI has zero FARA registrations and zero lobbying filings in Senate LDA records 7, despite its Taihe partnership and its role as the largest private CODEL organizer in the country. Comparable organizations — such as the China-United States Exchange Foundation — have registered under FARA with multiple registrants. Review of 990 filings shows HDI’s revenue declined over 80% from a peak of $1.82 million in 2011 to under $200,000 by 2018, with a partial recovery to $221,000 by 2023 18.
Key Relationships
The central relationship is with Jeffrey Epstein, mediated through his brother Mark Epstein. Records show Mark served as an HDI director, signed the 2015 IRS 990 return as “Mark L. Epstein, Director,” loaned the organization over $100,000 in 2014, and participated in CODELs to Bahrain (2013) and Azerbaijan (2014) 12. In a December 22, 2014 email, Mark wrote to Jeffrey: “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.” 2. 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.” The phrasing “I did not know you were doing this kind of stuff” implies Jeffrey had separate involvement in similar diplomatic-access activities.
According to records, Amir Dossal, former United Nations Chief of Partnerships and chairman of the Global Partnership Forum, served as an ex officio director of HDI 4. On June 20, 2013, Dossal co-hosted a UN event on oceans and Sustainable Development Goals alongside Ghislaine Maxwell (representing the TerraMar Project) and Stuart Beck, Palau’s ambassador 9. This placed an HDI director in direct programmatic collaboration with Maxwell at the United Nations. In August 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,” which honored UN Secretary-General Ban Ki-moon and featured James Simons, James Watson, and Jack Rosen 9.
Review of the 2015 990 filing shows the HDI board was a 14-member body chaired by Dr. Al Khalafalla, with chairman emeriti Constance Milstein (later a Biden ambassador nominee to Malta) and Sonnenfeldt 18. Other directors included William J. Rouhana Jr. (co-founder and chairman since 2010, CEO of Chicken Soup for the Soul Entertainment), former Congressman Benjamin Gilman, Walter Arbib (SkyLink Group president), and Jay T. Snyder (HBJ Investments). The co-founder and president since 1998, Ralph L. Cwerman, drew $145,458 in annual compensation. Executive Director Joseph Merante, a former State Department Foreign Service officer, managed the CODEL operations and served as the point of contact for delegation logistics and the Taihe partnership.
The Congressional Delegation
HDI’s core operational activity is the organization of private Congressional Delegations. Analysis of records indicates HDI organized 52 or more CODELs to over 30 countries over two decades, hosting more than 250 Members of Congress and 400 senior Congressional staff members 4. Destinations have included Azerbaijan, Bahrain, Turkey, Cyprus, and UN headquarters in New York. The delegations are fully funded and “entirely first class with all first class accommodations,” according to CODEL recruitment emails found in Epstein’s files 3.
The mechanics of the CODEL operation are documented in detail through the May 2014 Azerbaijan delegation. When participants dropped out, HDI Executive Director Joseph Merante emailed seeking replacements from “media, finance, banking, education.” Mark Epstein forwarded Merante’s email directly to Jeffrey Epstein on May 22, 2014, writing: “In case you know someone and want to do them a favor: (let me know)” 3. The full agenda, recovered from Epstein’s document files, lists meetings with President Ilham Aliyev, U.S. Ambassador Richard Morningstar, Foreign Affairs Minister Elmar Mammadyarov, and parliamentary committees 10. The delegation provided face-to-face access to a head of state, and Jeffrey Epstein was offered the ability to fill empty seats.
Examination of records shows the Congressional Advisory Board, as constituted around 2022, included 33 or more current and former members of Congress from both parties: Don Bacon (R-NE), Andre Carson (D-IN), Judy Chu (D-CA), Jim Clyburn (D-SC), Ruben Gallego (D-AZ), Andy Harris (R-MD), Jim Himes (D-CT), Gregory Meeks (D-NY), Bennie Thompson (D-MS), Maxine Waters (D-CA), Debbie Wasserman Schultz (D-FL), and others 4. Former advisory board members include Mark Meadows, Adam Schiff, and Sheila Jackson Lee. This bipartisan Congressional roster provided institutional credibility that preceded the Taihe Institute partnership.
The Taihe Institute Partnership and CCP Nexus
In August 2017, HDI formalized a partnership with the Beijing-based Taihe Institute, a think tank whose senior fellows include 12 or more current and former members of the Chinese Communist Party and the People’s Liberation Army 5. HDI Executive Director Merante participated in the Taihe Civilizations Forum in Beijing in both August 2017 and September 2019 6. Ruby Wang, Senior Vice President at Perfect World (a Chinese gaming company) and a Taihe fellow, joined the HDI board, connecting the two organizations at the governance level.
The partnership drew scrutiny from media and Congress. The Washington Examiner reported on HDI’s CCP connections, and multiple members of Congress resigned from the Advisory Board 6. Taihe co-authored a report with HDI-adjacent figures that called the United States a “failed country” and promoted the claim that COVID-19 leaked from a Maryland military base. HDI stated publicly that it “never accepted any funds from the Taihe Institute or any Chinese Government organ or entity.” Under 22 USC 611(c), however, FARA’s definition of “agent of a foreign principal” does not require direct funding — acting “at the order, request, or under the direction or control” of a foreign principal is sufficient.
HDI thus operated simultaneously as the largest private CODEL organizer in the country, a formal partner of a CCP/PLA-linked think tank, and a board seat for an Epstein family member — all with zero FARA registrations and zero LDA lobbying filings 7. The China-United States Exchange Foundation, conducting comparable China-U.S. influence activities, registered under FARA with four separate registrants (Capitol Counsel #6328, Wilson Global #6584, BLJ Worldwide #5875, BGR Government Affairs #5430) 7. HDI’s functionally equivalent activities remain unregistered.
Financial Profile and Contraction
Analysis of HDI’s IRS 990 filings shows a steep financial decline 18. Revenue peaked at $1.82 million in 2011, sustained at $1.64 million (2012) and $1.70 million (2013), then fell: $1.47 million (2015), $481,000 (2016), $401,000 (2017), $227,000 (2018). A brief spike to $360,000 in 2019 was followed by continued decline: $202,000 (2020), $155,000 (2021), $174,000 (2022), and $221,000 (2023). Total assets peaked at $287,000 in 2011 and stood at $170,000 in 2023. This represents over 80% revenue decline from peak to trough.
Records indicate Mark Epstein loaned HDI over $100,000 in 2014 — a personal loan from a board director to the organization he governed 1. The 2015 return, signed by Mark Epstein as director, flagged “Yes” on Line 25a (excess benefit transaction with a disqualified person) and Line 5a (party to a prohibited tax shelter transaction), and disclosed foreign bank accounts 8. These disclosures rarely appear on nonprofit filings, individually or in combination.
The revenue trajectory parallels — at smaller scale — the decline at IPI, whose assets fell 73% from $12.6 million to $3.9 million over a similar period. Both organizations connect to the Epstein network through different pathways: HDI through Mark Epstein and Dossal; IPI through Terje Rod-Larsen and Gratitude America. The partial revenue recovery in 2022–2023 may reflect new funding sources, but without granular donor data from the 990s, the source cannot be determined.
Regulatory Gaps and Disclosure Failures
HDI has zero FARA registrations despite its partnership with the CCP-linked Taihe Institute and its role facilitating meetings between U.S. lawmakers and foreign heads of state including Azerbaijan’s President Aliyev 7. It has zero lobbying filings in Senate LDA records despite maintaining a 33-member Congressional Advisory Board and organizing 52 or more CODELs 7. An organization with documented CCP institutional ties and Epstein family involvement in its governance has operated the country’s largest private Congressional delegation program entirely outside federal transparency requirements.
Under 22 USC 611(c), the definition of “agent of a foreign principal” encompasses anyone who acts “at the order, request, or under the direction or control” of a foreign principal. HDI’s Taihe partnership involved joint events, shared speakers, and co-produced publications — activities that, when performed by other organizations with Chinese government connections, have triggered FARA registration 7. 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.
The 990 filing disclosures add further context. Review of the 2015 return shows it flagged excess benefit transactions, prohibited tax shelter participation, and foreign bank accounts, and was signed by Mark Epstein — the board member through whom Jeffrey Epstein was offered the ability to place individuals on Congressional delegations 138. No public record of DOJ National Security Division review or Congressional inquiry into HDI’s FARA status has been identified.
All Connections
11 total
All Connections
11 totalPartnership since 2017. Taihe employs 12+ CCP/PLA members. HDI participated in Taihe forums in Beijing. Neither registered under FARA.
Cwerman is the care-of contact for Humpty Dumpty Institute on IRS records (EIN 13-4028567). He is the organizational point person for the entity whose revenue collapsed 80% from .8M to under K.
Finding #90: LMSBAND contains images of actual check copies from Gratitude America to IPI, all drawn on Deutsche Bank Trust Company Americas (New York NY 10154). C
Finding #107: HDI organized Congressional Delegation to Azerbaijan (May 30-June 4, 2014) with meetings with President Ilham Aliyev, US Ambassador Morningstar, Forei
Finding #107: HDI organized Congressional Delegation to Azerbaijan (May 30-June 4, 2014) with meetings with President Ilham Aliyev, US Ambassador Morningstar, Forei
Finding #109: Mark Epstein forwarded HDI Azerbaijan delegation email to Jeffrey Epstein on May 22, 2014, offering to do Jeffrey a favor by filling congressional slo
Director on Board of Directors. Loaned HDI over 100K in 2014. Participated in congressional delegations to Azerbaijan and Bahrain.
Jeffrey received HDI CODEL recruitment emails from brother Mark. Had potential to fill congressional delegation slots via his network. Will left Mark 10M in trust.
Director on HDI Board. Chairman of Global Partnership Forum. Co-hosted UN SDG event June 2013 with Ghislaine Maxwell.
Formal partnership since Aug 2017. HDI participated in Taihe forums 2017 and 2019 in Beijing. Ruby Wang bridged both orgs. Taihe employs 12+ CCP/PLA members as senior fellows.
Co-founded HDI in 1998. Chairman since 2010. Also CEO of Chicken Soup for the Soul Entertainment. Chicken Soup donates revenue to HDI.
All Findings
17 total
All Findings
17 totalfinancial (4)
HDI (EIN 13-4028567) IRS 990 filings show: revenue peaked at .47M (2015), declined to K (2020), recovered to K (2023). Incorporated Oct 19, 1998 in NY (Corp #2307873). Registered address was c/o Michael W. Sonnenfeldt, 146 Central Park West Ste 10-D, NYC. Mark Epstein loaned HDI over K in 2014 per 990 filing.
HDI (EIN 13-4028567) 990 filings show severe financial contraction. Peak revenue was .82M in 2011, declining to .47M in 2015, K in 2016, K in 2017, K in 2018, then a brief spike to K in 2019, K in 2020, K in 2021, K in 2022, and K in 2023. Assets peaked at K (2011) and have remained minimal (K in 2023). Care-of is Ralph Cwerman. The organization went from a .8M/yr operation to under K/yr, representing over 80% revenue decline - far more severe than typical nonprofit fluctuations.
HDI cumulative 990 analysis: Revenue declined 73.6% from peak of .82M (2011) to K (2023). The organization consistently spent more than it earned, but survived by operating on thin margins with minimal assets (K-287K range). Revenue collapse began immediately: .82M (2011), .64M (2012), .70M (2013), then accelerating decline to K by 2018. Partial recovery in 2022-2023 (K, K) may reflect new funding sources unrelated to Epstein. HDI operated with much smaller scale than IPI but showed similar pattern of contraction.
The Humpty Dumpty Institute Inc (Mark Epstein board member, CODEL pipeline, CCP/Taihe connections) received two PPP loans totaling $82,190: $40,656 from Cross River Bank on April 30, 2020 (fully forgiven $41,277.54) and $41,534 on second draw. Address: 140 Thompson St Apt 2E, New York NY 10012. Nonprofit (Y), NAICS 813319 (Social Advocacy Organizations), 3 jobs.
HDI organized 52+ Congressional Delegations and had 33+ Congress members on its advisory board. Jeffrey Epstein had access to fill CODEL slots through Mark Epstein's board position. The 140 Thompson St Apt 2E address is SoHo residential -- HDI appears to have operated from a personal apartment. 3 reported jobs for an organization running dozens of international congressional delegations is surprisingly small, suggesting much of its operations were volunteer-based or contracted out.
relationship (3)
Amir Dossal (HDI Director, Global Partnership Forum Chairman) appeared alongside Deutsche Bank Global Head Kevin Parker and Russian Duma member Ilya Ponomarev at the New York Academy of Sciences 'Science & the City Gala' on Aug 30, 2011. Event honored UN Secretary-General Ban Ki-moon and featured James Simons, James Watson, Jack Rosen, and other Epstein network figures.
Amir Dossal (HDI Director per LittleSis) co-hosted June 20, 2013 UN event on oceans/Sustainable Development Goals with Ghislaine Maxwell (TerraMar Project) and Stuart Beck (Palau Ambassador). Event at UN Conference Building, Room D. Dossal chaired the Global Partnership Forum.
HDI 2015 990 reveals 14-member board. Chairman: Dr. Al Khalafalla. Chairman Emeriti: Constance Milstein, Michael W. Sonnenfeldt. Directors: William J. Rouhana, Benjamin Gilman (former US Congressman), Venerable Hsin Ting, Mark Epstein (Jeffrey Epstein's brother - SIGNED THE RETURN as Director), Jennifer Diamond, Walter Arbib, Cosmo Denicola, Amir Dossal (Ex Officio, former UN Chief of Partnerships), Deborah Landey (former UNDP), Christopher Mitchell. President/CEO: Ralph L. Cwerman (40 hrs/wk, $145,458 compensation). CRITICAL: Mark Epstein both served as director AND signed the return ('Mark L. Epstein, Director'). Also flagged Yes on Line 25a: excess benefit transaction with disqualified person. Also flagged Yes on Line 5a: party to prohibited tax shelter transaction. Also had foreign bank accounts.
legal (3)
HDI FARA LEGAL ANALYSIS: Humpty Dumpty Institute has zero FARA registrations despite documented CCP/Taihe Institute partnership (since 2017) and extensive Congressional engagement. HDI's activities that potentially trigger FARA: (1) Partnership with Taihe Institute, which employs 12+ current/former CCP and PLA members as senior fellows; (2) 52+ Congressional Delegations to 30+ countries including Azerbaijan, Bahrain, Turkey/Cyprus, and UN; (3) 33+ current/former Congress members on advisory board including Maxine Waters, Jim Clyburn, Debbie Wasserman Schultz, Gregory Meeks; (4) 550+ members of Congress and staffers hosted for summits; (5) Mark Epstein (Jeffrey's brother) on board, participated in Bahrain and Azerbaijan CODELs; (6) Taihe co-authored report calling US 'failed country' and claiming COVID leaked from Maryland military base. HDI CLAIMS: States it 'never accepted any funds from the Taihe Institute or any Chinese Government organ or entity.' FARA COMPARABLE: China-United States Exchange Foundation registered under FARA with 4 separate registrants (Capitol Counsel #6328, Wilson Global #6584, BLJ Worldwide #5875, BGR Government Affairs #5430) for similar China-US influence activities. HDI's partnership with Taihe performing similar functions without FARA registration is anomalous. COUNTER: HDI's 990s show revenue declined from $1.47M (2015) to $202K (2020), suggesting limited operational capacity. HDI claims no Chinese government funding. KEY QUESTION: Even if no direct Chinese funding, does the Taihe partnership constitute acting as agent of a foreign principal under 22 USC 611(c)?
Humpty Dumpty Institute has no FARA registration despite documented CCP/Taihe Institute ties with 12+ PLA members, 33+ Congress members on advisory board, and CODEL pipeline where Epstein could fill congressional delegation slots. Taihe Institute also absent from FARA. China has 276 FARA-registered foreign principals but neither HDI nor Taihe appears. This is a potential FARA violation given documented foreign government connections.
Humpty Dumpty Institute (HDI) has ZERO lobbying filings in Senate LDA records despite operating an extensive CODEL pipeline with 33+ Congress members on its advisory board. HDI filled congressional delegation slots (EFTA02718091), arranged CCP/Taihe Institute meetings with 12+ PLA members, and maintained Dossal-Maxwell UN event links. The absence of lobbying registration is investigatively significant - HDI operated at the intersection of Congressional access, foreign government contacts, and the Epstein network without any formal lobbying disclosure.
intelligence (6)
HDI has organized 52+ Congressional Delegations including to Azerbaijan (2014), Bahrain (2013), Turkey/Cyprus, and UN headquarters. In the last decade, HDI organized programs for 250+ Members of Congress and 400+ Senior Congressional Staff to the UN and countries in the Middle East, Africa, former Soviet Union, Caribbean, and Asia. Mark Epstein personally participated in Bahrain and Azerbaijan delegations.
When Azerbaijan CODEL members dropped out, HDI Executive Director Joe Merante emailed requesting replacements from 'media, finance, banking, education' - Mark Epstein forwarded this directly to Jeffrey Epstein May 22, 2014. The trip was 'entirely first class with all first class accommodations' and included meeting the President of Azerbaijan. This shows Jeffrey Epstein had access to fill congressional delegation slots through Mark's HDI board position.
HDI CODEL pipeline mechanics reconstructed. Mark Epstein (Jeffrey's brother, HDI board member) personally participated in CODELs to Bahrain (2013) and Azerbaijan (2014). EFTA02598877 shows Mark emailed Jeffrey Dec 22, 2014: '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. 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.' EFTA02725237 shows full Azerbaijan agenda (May 30-Jun 4, 2014): meetings with President Ilham Aliyev, US Ambassador Morningstar, Foreign Affairs Minister Mammadyarov. When members dropped out, Merante sought replacements from 'media, finance, banking, education' -- Mark forwarded directly to Jeffrey (May 22, 2014), giving Jeffrey access to fill Congressional delegation slots. HDI has organized 52+ CODELs total with 550+ Congress members/staff. These are all-expenses-paid first-class trips. The combination of CCP/Taihe partnership + CODEL access + Epstein family involvement + zero FARA/LDA registration constitutes a significant regulatory blind spot.
HDI Board of Directors includes: William J. Rouhana Jr (Co-founder, Chairman since 2010, CEO of Chicken Soup for the Soul Entertainment), Ralph L. Cwerman (Co-founder, President since 1998), Michael W. Sonnenfeldt (Co-founder, Director, MUUS & Company), Constance Jane Milstein (Chairman Emeritus, Biden Ambassador nominee to Malta), Mark Epstein (Director, Jeffrey Epstein's brother), Amir Dossal (Director, Global Partnership Forum Chairman), Jay T. Snyder (Director, HBJ Investments), Benjamin A. Gilman (Director, former US Congressman), Walter Simon Arbib (Director, SkyLink Group President). Executive Director: Joseph Merante (ex-State Dept Foreign Service). Board Chairman: Dr. Al Khalafalla (since Oct 2015).
HDI partnered with Beijing-based Taihe Institute starting 2017. Taihe employs 12+ current/former CCP and PLA members as senior fellows. HDI participated in Taihe Civilizations Forum Aug 2017 (Beijing) and Sept 6-8, 2019 (Beijing). Ruby Wang (Perfect World gaming company SVP, Taihe fellow) joined HDI board. HDI exec Joseph Merante presented at both forums. Partnership drew CCP influence concerns from Washington Examiner and multiple Congressional resignations.
HDI Congressional Advisory Board includes 33+ current/former US Representatives and Senators as of 2022. Current members include: 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), Frederica Wilson (D-FL). Former members include Mark Meadows, Adam Schiff, Sheila Jackson Lee, and others.
document (1)
HDI organized Congressional Delegation to Azerbaijan (May 30-June 4, 2014) with meetings with President Ilham Aliyev, US Ambassador Morningstar, Foreign Affairs Minister Mammadyarov, and parliamentary committees. Full agenda found in Epstein document files.