INVESTIGATIVE SUMMARY: Former NGO Human Resources Vice President Sentenced to Four Years Probation, Forfeiture of $425,000, False Claims Civil Settlement of $160,000, and Three-Year U.S. Government Debarment

Investigative Summary

A joint OIG and Department of State OIG investigation revealed Carleena Graham, former Vice President of Human Resources for World Learning, defrauded the organization of approximately $425,000, of which approximately $272,500 was directly or partially funded by the U.S. Government. World Learning was a recipient of USAID funded programming.

Beginning in approximately 2016 and continuing until the middle of 2022, Graham orchestrated a scheme to defraud World Learning of hundreds of thousands of dollars. As part of the scheme, Graham arranged for goods and services to be delivered to third-party organizations, and then fraudulently arranged for World Learning to pay for these goods and services via electronic transfers from its Vermont bank account. Graham falsified invoices vendors submitted for payment of the goods and services to make them appear as though World Learning was the recipient of the goods and services. Additionally, Graham often misused her access to World Learning’s credit cards causing World Learning to pay the expenses incurred by the third-party organizations. 

On March 8, 2024, Graham was sentenced in federal court to four years of probation following a guilty plea to one count of wire fraud. Graham was also ordered to pay $425,000 in restitution as part of her plea agreement. Following sentencing, Graham was debarred from receiving U.S. government funds for a period of three years. On July 17, 2026, Graham entered into a civil settlement with the Department of Justice and agreed to pay $160,000 to resolve allegations that she violated the False Claims Act by submitting fraudulent claims for payment to the U.S. Government. The civil settlement concludes our investigation.

USAID-OIG, a statutorily independent law enforcement agency, continues to investigate fraud, corruption, diversion, and other misconduct impacting U.S.-funded foreign assistance programs and operations across multiple agencies. Please report any alleged misuse of U.S. taxpayer dollars impacting American foreign assistance to the OIG Hotline through https://oig.usaid.gov/report-fraud.

For more on OIG’s investigative activities, please visit https://oig.usaid.gov/our-work/investigations.

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