EWF is committed to transparency, integrity and the proper representation of our mission and status. We take seriously any instances of fraud, impersonation or misuse of our name or identity. If you believe that an individual or organization is impersonating EWF, using our name without authorization, or misrepresenting themselves as affiliated with us (or with an inter-governmental organization or NGO status) you are encouraged to report this immediately.

Impersonation or mis-representation may include, but is not limited to:

• falsely claiming to represent EWF or an inter-governmental organization (IGO) or non-governmental organization (NGO) in affiliation with EWF;
• using our logos, name, email address, website links, or other brand-assets without permission;
• posing as EWF or an IGO/NGO to solicit funds, services, access or other benefit;
• falsely claiming a relationship with a foreign government, foreign principal, inter-governmental agency or international body in the U.S. context without proper registration or disclosure;
• offering services (“we are an inter-governmental organization”, “we are exempt from regulation”, etc.) that mislead persons into believing a special status exists when it does not.

Under U.S. federal law, it is a crime to impersonate certain roles or present false claims of authority. For example:

• Title 18 U.S.C. § 912 makes it unlawful to falsely impersonate an officer or employee of the United States. law.cornell.edu+1
• Title 18 U.S.C. § 913 covers one who falsely represents himself as an officer or employee of the United States and, in such assumed character, arrests or detains any person or property. uscode.house.gov+1
• The broader set of statutes in Chapter 43 of Title 18 provide criminal liability for various impersonations of officers, diplomats or other authorised persons. law.cornell.edu+1
  Thus, if a party falsely claims to be an authorised representative of a U.S. or foreign government entity, or an official of EWF or an IGO/NGO in a way that misleads and harms others, criminal liability may apply.

At the U.S. federal regulatory level, the Federal Trade Commission (FTC) has adopted rules that prohibit materially and falsely posing as, or implying affiliation with, a government entity or officer thereof, in or affecting commerce. Specifically:

• Under 16 CFR § 461.2: “[i]t is a violation … to materially and falsely pose as, directly or by implication, a government entity or officer thereof, in or affecting commerce…” ecfr.gov+1
• Under 16 CFR § 461.3: “[i]t is a violation … to materially and falsely pose as, directly or by implication, a business or officer thereof, in or affecting commerce…” law.cornell.edu+1
  In practice, this means that fraudsters who represent themselves as an IGO/NGO (or affiliated with one) in order to solicit funds, services or trust, may also run afoul of these regulations.

FARA is a key law when organizations or persons in the U.S. act on behalf of “foreign principals” (including foreign governments, foreign political parties, or entities organized under foreign laws) and engage in certain defined activities around representation, advocacy, publicity, or lobbying. Some key points:

• FARA was enacted to protect U.S. national defence, internal security and foreign relations by requiring disclosure of certain persons engaging in propaganda or other activities for or on behalf of foreign principals. GovInfo+1
• Under 22 U.S.C. § 611 et seq., the law defines a “foreign principal” and requires certain agents of foreign principals to register with the U.S. Department of Justice (DOJ). congress.gov+1
• FARA does not prohibit the activities themselves, but mandates registration and full disclosure of relationships, finances and activities. GovInfo
• Failing to register or comply when required may subject the person or organization to injunctive relief by DOJ, and criminal penalties. Department of Justice+1
• Recent enforcement trends show heightened attention by DOJ and the FARA Unit. winston.com+1

If EWF or any entity falsely claims to be an IGO/NGO with special status, or claims foreign-government affiliation, or acts on behalf of a foreign principal without proper disclosure/treatment under FARA, this could create serious compliance risk.

• EWF affirms that we operate in full compliance with all relevant United States federal laws and regulations, including non-impersonation rules and transparency obligations under FARA if applicable.
• EWF is not a foreign governmental body; we are a inter-governmental organization (IGO) properly registered in accordance with applicable U.S. law and state law, with internal governance, filings, audits (as required) and ethical fundraising practices.
• Any representation of EWF should clearly state our legal status, our mission, our public disclosures and association with any legitimate non-governmental organisation (NGO) must be authorized in writing by our Board.
• EWF maintains internal policies, record-keeping and oversight to ensure:
  1. That we do not act as an unregistered “agent” for a foreign principal under FARA (unless appropriate registration has been completed).
  2. That we do not misrepresent our status or that of any IGO/NGO.
  3. That any partnerships, joint activities or representations which might involve foreign government funding or advocacy are assessed for FARA implications.

• If you believe someone is falsely claiming to act on behalf of EWF, our Board of Directors or affiliated IGO/NGO partner, please inform us immediately using the contact details below so we can investigate and take action.

If you believe a person or organization is impersonating EWF, or falsely claiming to represent us, please:

1. Gather as much evidence as you can (emails, website screenshots, solicitation documents, logos, names, bank account details, dates of contact).
2. Submit a complaint to EWF by emailing ewf@theethiopianworldfederation.org (or your designated contact) with subject line: “Fraud Complaint – Impersonation”.
3. Provide your contact details (you may request confidentiality) and describe the nature of the suspicion, the name of the individual or organization, the asserted affiliation, and any supporting documentation.
4. EWF will review the matter, may liaise with law enforcement or federal regulators as appropriate, and take steps to protect our name, reputation and stakeholders.

• Impersonating a U.S. federal officer, government employee, or falsely claiming governmental or IGO status may lead to criminal prosecution, fines or imprisonment under Title 18 U.S.C. Chapter 43. Department of Justice+1
• Materially impersonating a government entity or officer in commerce, or misrepresenting affiliation with a government entity or officer, is a violation of 16 CFR Part 461. FTC enforcement may seek civil penalties or recovery of consumer redress. Federal Trade Commission+1
• Under FARA, acting as an agent of a foreign principal without timely registration or continuing disclosure can lead to injunctive relief, civil sanctions and criminal penalties (including prison terms of up to 5 years for willful violations). kslaw.com+1
• Organizations that market themselves as IGOs or NGOs with special status, but in fact are mis-representing themselves, may be subject to additional state law or non-profit regulation actions (fraud, mis-representation, charitable solicitation violations) in New York or other jurisdictions. Charity & Security Network

While the federal laws above apply widely, in New York City and State there may also be civil liability under state statutes for misrepresentation, fraud, deceptive practices or charitable solicitation violations. Organizations claiming to be IGOs or internationally recognized NGOs must ensure that their solicitation, fundraising and disclosure practices comply with state charity laws. EWF maintains compliance with New York State Department of Law (Charities Bureau) requirements and solicits only in accordance with valid registration and reporting obligations.

EWF takes any mis-use or impersonation of our name, brand or status extremely seriously. We will actively investigate any reports of impersonation, mis-representation or fraudulent affiliation, and will cooperate with federal and state law enforcement, regulators and other authorities as needed. We appreciate your vigilance and willingness to help protect the integrity of our organization and the wider NGO sector.