---
alias:
- Counter Extremism Project
- CEP
- Counter Extremism Project United
- Counter Extremism Project United Inc
- CEPU
- The Green Light Project
- Green Light Project
category: Private Organization
created: 2026-10-01
location: New York, United States
relations:
- fn: 1
  reverse: true
  role: chief executive officer
  start: 2014-09-22
  type: founded
  with: '[[Mark Wallace]]'
- fn: 1
  reverse: true
  role: board member at the launch
  start: 2014-09-22
  type: director_of
  with: '[[Frances Townsend]]'
- fn: 1
  reverse: true
  role: board member at the launch
  start: 2014-09-22
  type: director_of
  with: '[[Joseph Lieberman]]'
- fn: 1
  reverse: true
  role: the one backer Wallace named at the launch
  start: 2014-09-22
  type: funded
  with: '[[Thomas Kaplan]]'
- end: 2023
  fn: 2
  role: grants by Counter Extremism Project United Inc of 2,000,000, 5,160,900, 9,100,500
    and 7,462,350 dollars for 2020 to 2023
  start: 2020
  type: funded
  with: '[[DonorsTrust]]'
- end: 2021
  fn: 8
  role: grants by Counter Extremism Project United Inc to ACANI Inc of 5,000,000 dollars
    (2017), 5,500,000 (2018), 2,220,000 (2020) and 250,000 (2021)
  start: 2017
  type: funded
  with: '[[United Against Nuclear Iran]]'
- end: 2023
  fn: 13
  reverse: true
  role: strategic consulting, 140,005 dollars in the return for 2018 and 140,004 in
    the return for 2023
  start: 2018
  type: contractor_to
  with: '[[Joseph Lieberman]]'
- end: 2017
  fn: 8
  reverse: true
  role: advisory board and consulting, 130,000 dollars
  start: 2017
  type: contractor_to
  with: '[[John Bolton]]'
- end: 2023
  fn: 12
  reverse: true
  role: Jeb Bush and Associates LLC, strategic consulting, 120,000 dollars (2020,
    2022) and 109,000 (2023)
  start: 2020
  type: contractor_to
  with: '[[Jeb Bush]]'
- end: 2022
  fn: 24
  reverse: true
  role: paid by The Green Light Project Inc, 160,000 dollars (2020) and 120,000 (2022)
  start: 2020
  type: contractor_to
  with: '[[Hany Farid]]'
- fn: 31
  reverse: true
  role: funding for the hash-matching software, per Defense One
  start: 2016-06
  type: funded
  with: '[[Microsoft]]'
- fn: 35
  reverse: true
  role: fiscal year 2020 Targeted Violence and Terrorism Prevention grant
  start: 2020
  type: funded
  with: '[[Department of Homeland Security]]'
- fn: 39
  role: named in the Project ENDGAME document, per Fox News Digital; the firm's lawyer
    denies wrongdoing
  start: 2017-03
  type: subject_of
  with: '[[Global Risk Advisors]]'
start: 2014-09-22
summary: New York advocacy organisation launched in September 2014 by Mark Wallace,
  Frances Townsend and Joseph Lieberman on the model of United Against Nuclear Iran,
  whose 501(c)(4) granted millions to DonorsTrust and two charities.
tags:
- Organization
- CounterExtremism
- Section501c4
- MarkWallace
- ThomasKaplan
- UANI
- DonorsTrust
- HanyFarid
- ContentModeration
- PoliticalFinance
updated: 2026-10-01
---

The Counter Extremism Project (CEP) is a [New York City](/places/new-york-city/) advocacy organisation launched on 22 September 2014 by Mark Wallace, a former [United States](/places/united-states/) ambassador to the [United Nations](/organizations/united-nations/), with Frances Townsend, a former Homeland Security adviser to [George W. Bush](/people/george-w-bush/), and the former senator Joseph Lieberman as board members.[^1] It operates through Counter Extremism Project United Inc (CEPU), a 501(c)(4) social welfare organisation with the employer identification number 81-0878718, and through The Green Light Project Inc, a 501(c)(3) charity with the number 46-4631639, whose Form 990 describes it as "a non-partisan organization focused on countering extremism".[^2][^3] Its model was an earlier Wallace organisation, United Against Nuclear Iran (UANI): Wallace told a House subcommittee in January 2015 that CEP was modeled "in part on advocacy efforts to counter Iran's efforts to acquire nuclear weapons".[^4]

### Launch and Board

The Jewish Telegraphic Agency reported on 22 September 2014 that Wallace was chief executive of both CEP and UANI, that Lieberman and Townsend sat on both boards, and that the project had opened offices in New York and [Brussels](/places/brussels/). Other board members of both organisations named in the report were Gary Samore, a former [White House](/places/white-house/) coordinator for arms control and weapons of mass destruction, August Hanning, a former director of Germany's secret service, the [Bundesnachrichtendienst](/organizations/bundesnachrichtendienst/) (BND), Dennis Ross, an adviser on [Middle East](/places/middle-east/) affairs to Presidents [Bill Clinton](/people/bill-clinton/) and Barack Obama, and Irwin Cotler, a former Canadian justice minister. The report states that Wallace "declined to identify the project's sources of funding except for Thomas Kaplan, a billionaire commodities investor who also backs United Against Nuclear Iran and, along with Wallace, runs the Tigris Financial Group", and that the project was "backed by a host of pro-Israel stalwarts" while Wallace sought to distance it from Israel.[^1]

CEP's website as captured on 30 September 2014 listed al-Qaeda, Boko Haram, ISIS and the Muslim Brotherhood under the heading "The Threat".[^5] The biography filed with Wallace's written testimony of 28 October 2015 records that he was Deputy Campaign Manager of the Bush campaign in 2004, a senior adviser to Senator John McCain in 2008, general counsel of the Federal Emergency Management Agency and of the Immigration and Naturalization Service, and general counsel of the City of [Miami](/places/miami/)'s Emergency Financial Oversight Board.[^6]

### Corporate Structure

The Form 990 returns of the group show a layered structure. CEPU files as a 501(c)(4), and its returns list as related organisations CEPUMedia Inc (media production, Delaware, controlled by CEPU), Counter Extremism Project Germany gGmbH (Berlin) and CEPU Cayman LLC, a disregarded entity in the [Cayman Islands](/places/cayman-islands/) whose stated activity is "provides a platform for international activities". The return for 2021 gives the Cayman entity a total income of 2,999,950 dollars and end-of-year assets of zero; the return for 2023 gives it zero for both. The German entity reported total income of 60,519 dollars and end-of-year assets of 117,126 dollars in 2021, and 59,653 and 194,436 in 2023.[^2][^7] The Green Light Project's return for 2023 lists an "investment in CEP UK".[^3]

CEPU, The Green Light Project, UANI's charity ACANI Inc (formerly the American Coalition Against a Nuclear Iran, EIN 26-2387657) and its sister 501(c)(4) United Against a Nuclear Iran Action Inc use the same New York post box addresses, PO Box 3980 and PO Box 1028, on their returns. ACANI Inc's return for 2018 describes its purpose as informing the public about the nature of the Iranian regime and names United Against a Nuclear Iran as its project.[^8][^9][^10][^11] The returns of CEPU for 2020 to 2023 list Wallace as chief executive officer and director, Robert Benton as secretary, whose compensation in the return for 2023 was recorded as payment for legal services rather than service as secretary, David Ibsen as executive director (to December 2023), and Jolie J. Davis and Henley Old as directors.[^2][^12] The directors of The Green Light Project in the returns for 2016 to 2023 include Michael Neifach and Brian Stack.[^3][^9]

### Revenue and Grant Flows

CEPU's Form 990 for 2017 reports contributions and total revenue of 22,230,000 dollars, expenses of 14,702,134 dollars, grants paid of 12,230,000 dollars and year-end assets of 14,567,076 dollars. The grants were 5,000,000 dollars to ACANI Inc and 7,230,000 dollars to The Green Light Project.[^8] For 2018 revenue was 15,568,814 dollars, with grants of 5,500,000 dollars to ACANI Inc, 7,500,000 dollars to The Green Light Project and 5,353 dollars to the UANI action organisation.[^13] For 2020 revenue was 6,058,608 dollars and expenses 8,774,302 dollars, with grants of 2,220,000 dollars to ACANI Inc, 2,350,000 dollars to The Green Light Project and 2,000,000 dollars to DonorsTrust.[^12] For 2021 revenue was 8,068,313 dollars, with grants of 250,000 dollars to ACANI Inc, 462,159 dollars to The Green Light Project and 5,160,900 dollars to DonorsTrust.[^7] For 2022 revenue was 11,034,793 dollars, with grants of 9,100,500 dollars to DonorsTrust and 49,500 dollars to the UANI action organisation.[^14] For 2023 revenue was 8,080,751 dollars and expenses 9,100,195 dollars, with a grant of 7,462,350 dollars to DonorsTrust, which the return describes as "general support to carry out educational and charitable purposes".[^2] The returns for 2019 and 2016 were not retrieved for this entry. Schedule B, which lists donors, is not part of the public copy of a 501(c)(4) return.

The Form 990 returns of DonorsTrust list grants for general operations to the same two recipients. For 2020 the return lists 1,980,000 dollars to ACANI Inc. For 2021 it lists 1,950,000 dollars to ACANI Inc and 3,150,000 dollars to The Green Light Project; for 2022, 4,300,000 and 4,650,000 dollars; for 2023, 3,685,000 and 3,680,000 dollars; and for 2024, 2,770,000 and 2,600,000 dollars.[^15][^16][^17][^18][^19] The DonorsTrust returns do not identify the source of any grant. The 7,462,350 dollars that CEPU granted to DonorsTrust in 2023 compares with 7,365,000 dollars that DonorsTrust's return for that year lists for ACANI Inc and The Green Light Project together.[^2][^18]

The Green Light Project's own revenue, as published by ProPublica's Nonprofit Explorer, was 5,490,979 dollars for 2014, 7,513,809 for 2016, 7,807,428 for 2017, 8,573,629 for 2018, 2,374,043 for 2020, 3,668,086 for 2021, 5,436,774 for 2022 and 4,173,499 for 2023. ACANI Inc reported 5,788,478 dollars for 2016 and 3,704,564 for 2023.[^20][^21] The Intercept reported that the network of organisations brought in "over $101 million between 2009 and 2019", according to its review of tax filings.[^22] CEPU's grants to ACANI Inc and The Green Light Project are of a similar size to the contributions reported by the recipients for the same years: The Green Light Project reported 7,807,428 dollars for 2017, against 7,230,000 dollars granted to it by CEPU.[^8][^20]

### Compensation and Contractors

CEPU's returns report Wallace's compensation from the organisation at 165,000 dollars for 2017, 355,000 for 2018, 390,000 for 2020 and 2021, 331,500 for 2022 and 356,500 for 2023. The Green Light Project's returns report 455,000 dollars for 2016, 475,000 for 2017, 250,000 for 2020 and 2021 and 212,500 for 2022 and 2023.[^2][^3][^7][^8][^9][^12][^13][^14][^23][^24][^25][^26]

The independent contractors paid more than 100,000 dollars and listed on CEPU's returns include, for 2017, Vulcan Consulting Ltd of Dublin (supervision of European operations, 170,005 dollars), Darlink of Bnei Brak, Israel ("strategic consulting/security advisor", 162,500), Beacon Global Strategies LLC of Washington ("strategic political and media services", 130,000), DDC Advocacy (130,000) and John Bolton ("advisory board/consulting", 130,000).[^8] For 2018 they include Pharos Strategic Consulting LLC (366,000), Vulcan (280,157), Darlink (242,990), Joseph Lieberman ("strategic consulting", 140,005) and Dennis Ross (130,000).[^13] For 2020 they include Jeb Bush and Associates LLC of [Coral Gables, Florida](/places/coral-gables-florida/) ("strategic consulting", 120,000), and for 2022 and 2023 Jeb Bush and Associates at 120,000 and 109,000 dollars. Lieberman is listed at 140,004 dollars for 2020, 128,337 for 2021 and 2022, and 140,004 for 2023.[^2][^7][^12][^14]

The Green Light Project's returns list contractors including, for 2016, Mercury Public Strategies (761,383 dollars), FP1 Public Affairs (300,000), Concord Strategic Solutions of [Tel Aviv](/places/tel-aviv/) (299,920) and Beacon Global Strategies (120,000); for 2017, Wiley Rein LLP for legal services (286,834); and for 2020 to 2023 Plus Communications, Red Flag Consulting of Dublin, The Brick Factory (website hosting), Frances Fragos Townsend ("strategic consulting", 240,000 dollars for 2020, 200,000 for 2021, 260,000 for 2022 and 170,000 for 2023) and Hany Farid (160,000 dollars for 2020 and 120,000 for 2022).[^3][^9][^23][^24][^25][^26] ACANI Inc's returns list as a contractor the Miami law firm Stack Fernandez Anderson and Harris for legal services at 436,002 dollars for 2016 and 197,233 dollars for 2017; Brian Stack is listed as a director of The Green Light Project in its returns for the same years.[^9][^10][^23][^27]

### Statements on Donors

On 22 September 2014 Wallace named Thomas Kaplan as the one backer he would identify.[^1] In September 2015 Rosie Gray reported in BuzzFeed News that a Twitter spokesperson had said the company declined to partner with CEP because of "undisclosed funding", and that Wallace called it "irresponsible" for Twitter to push for donor disclosure, saying "We keep our donors confidential for security reasons". Wallace described a "multi-million dollar budget" and "over 35 people".[^28] Eli Clifton and Murtaza Hussain wrote in The Intercept in November 2021 that Wallace filed a "truth in testimony" disclosure with the House Foreign Affairs Committee in 2015 stating "We have only received to date individual and private contributions. CEP has received no monies from foreign governments."[^22] The only truth-in-testimony form located for this entry is a House Foreign Affairs Committee form for a hearing on 25 November 2017 that lists the represented organisation as United Against Nuclear Iran.[^29]

Clifton wrote that UANI donor rolls published in 2015 showed trusts controlled by Kaplan contributing 843,000 dollars to UANI in 2013, about half of that year's revenue, and that Kaplan employs Wallace as a senior adviser at the Electrum Group.[^22] The Intercept also reported that the United States government quashed a 2013 lawsuit against Kaplan and UANI that claimed they were financed by undisclosed foreign interests, intervening as a third party in a civil suit and invoking state secrets.[^22]

### Online Takedown Advocacy and Hany Farid

Wallace testified on 27 January 2015 before the House Foreign Affairs Subcommittee on Terrorism, Nonproliferation and Trade on the use of social media by extremist groups, and on 28 October 2015 before the House Oversight Subcommittee on National Security, chaired by [Ron DeSantis](/people/ron-desantis/), in a hearing titled "Radicalization: Social Media and the Rise of Terrorism". In the second statement he said CEP had written three letters to Twitter requesting a meeting, that Twitter had ignored all but one, and that its reply "was indifferent at best".[^4][^6][^30]

In June 2016 CEP, "working with Dartmouth University computer scientist Hany Farid and funding from Microsoft", announced software to match known extremist images and videos by robust hashing, an approach Farid had invented in 2008 for child sexual abuse imagery with Microsoft.[^31] CEP's website lists Farid as a senior adviser.[^32] The Green Light Project's returns list Farid as a contractor for "strategic and policy analysis" at 160,000 dollars for 2020 and for "strategic consulting" at 120,000 dollars for 2022.[^24][^26]

CEP and Farid filed a brief as amici curiae in support of the petitioners in Gonzalez v. Google LLC (No. 21-1333) on 7 December 2022, represented by Kimberly Lambert Adams of the Pensacola firm Levin, Papantonio, Rafferty, Proctor, Buchanan, O'Brien, Barr and Mougey. The brief states that no counsel for a party authored it and that no person other than the amici and their counsel made a monetary contribution to fund it. It describes Farid as a Berkeley professor who "has testified before Congress five times", advises "many of the largest tech companies on content moderation" and is a member of TikTok's Content Advisory Council and Snap's Safety Advisory Board, and states that CEP "has advocated against broad Section 230 immunity for tech companies that algorithmically amplify terrorist content".[^33]

CEP states that it reports weekly on the methods extremists and terrorist groups use on the Internet to spread propaganda. Its press release of 21 January 2025 is titled "Extremist Content Online: White Supremacist Telegram Channels Identify Need for Alternative Platform After [State Department](/organizations/state-department/)'s Terrorgram Collective Designation", concerning channels on [Telegram](/organizations/telegram/) and the [Terrorgram Collective](/organizations/terrorgram-collective/).[^34]

### Government Grants

A report prepared for the [Department of Homeland Security](/organizations/department-of-homeland-security/) by RTI International evaluated CEP's fiscal year 2020 Targeted Violence and Terrorism Prevention grant. It records that CEP developed a curriculum called Alternative Pathways with Parallel Networks and Dr John Horgan, that CEP "was unable to identify a prison or other correctional institution willing to pilot its in-person AP course", and that ten incarcerated people completed a written version.[^35] The Green Light Project's return for 2020 lists a grant of 88,384 dollars to Parallel Networks of Alexandria, Virginia, for "combat extremism in respective communities".[^24]

### Gulf States and Turkey

LobeLog published on 21 July 2017 emails that it attributed to the account of the [United Arab Emirates](/places/united-arab-emirates/) ambassador to Washington, Yousef Al Otaiba, released by the group GlobalLeaks. Its author, Eli Clifton, wrote that on 3 September 2014 Wallace sent Otaiba cost estimates for a forum and wrote "Believe that this will be self-funding in short order with donors"; that on 8 January 2015 Townsend thanked Otaiba and Richard Mintz for "ongoing support of the CEP effort"; and that on 8 August 2016 the former senator Norm Coleman wrote to Otaiba at the suggestion of the [Saudi](/places/saudi-arabia/) foreign minister, "The Counter Extremism Project is a 501c4".[^36] Clifton wrote that UANI, CEP, Townsend, the embassy and Coleman did not respond to written requests for comment. The authenticity of the emails was not established in the article.[^37]

CEP's report "Qatar, Money, and Terror" and its QATAR-HARBORS campaign called on Qatar to arrest, expel or cut off support to sanction-designated or wanted individuals domiciled there and to halt support to Hamas, the Muslim Brotherhood and other groups.[^38] Fox News Digital reported on 20 January 2024 that a March 2017 document titled "Project ENDGAME", prepared for Qatar by the firm Global Risk Advisors, founded by the former [CIA](/organizations/central-intelligence-agency/) employee Kevin Chalker, also focused on CEP in an effort to "Mitigate Attacks" against Qatar. Wallace told Fox News Digital that after the Qatari operation "hacked accounts that contained email correspondence with members of CEP leadership, they engaged in a PR campaign to destroy us and paid Americans to do their bidding". Chalker's lawyer told Fox News Digital that no indictment was pending against Chalker or the firm and that allegations of wrongdoing were "just false".[^39]

The Intercept reported in November 2021 that Wallace also headed the Turkish Democracy Project, launched in summer 2021, which had no Turkish members on its leadership board, and that eight of its eleven senior leaders and advisers held positions with UANI, CEP or both. It reported that Kaplan has "extensive business and philanthropic ties to the United Arab Emirates" and, in the Responsible Statecraft version of the article, that none of the groups had registered under the Foreign Agents Registration Act.[^22][^36]

### Databases and Reports on Far-Right Groups

CEP's website lists research databases titled "White Supremacy Groups in the United States", "White Supremacy Groups in Europe" and "Far-Left Extremist Groups in the United States", a program named "ARCHER at House 88", and a German branch, CEP Germany.[^34] The Green Light Project's return for 2023 describes its program as countering support for extremist groups "by pressuring their financial support networks, building a best-in-class clearinghouse and database of extremist groups and their supporters, countering the narrative of extremists and their online recruitment, and advocating for strong laws, policies and regulations".[^3]

[^1]: Uriel Heilman, "Backers of anti-Iran group create mirror group against violent Islamists", Jewish Telegraphic Agency, 22 September 2014, as published by the AZ Jewish Post. https://azjewishpost.com/2014/backers-of-anti-iran-group-create-mirror-group-against-violent-islamists/
[^2]: Form 990 of Counter Extremism Project United Inc (EIN 81-0878718) for the tax year ended 31 December 2023 (IRS e-file object 202433269349301433; Part I, Part VII, Schedule I, Schedule R), IRS Tax Exempt Organization Search bulk XML, 2024_TEOS_XML_11A.zip. https://apps.irs.gov/pub/epostcard/990/xml/2024/2024_TEOS_XML_11A.zip; index at https://projects.propublica.org/nonprofits/organizations/810878718
[^3]: Form 990 of The Green Light Project Inc (EIN 46-4631639) for the tax year ended 31 December 2023 (IRS e-file object 202413269349301351; Part III program description, Part VII, Part VII Section B, Schedule R), IRS bulk XML, 2024_TEOS_XML_11A.zip. https://apps.irs.gov/pub/epostcard/990/xml/2024/2024_TEOS_XML_11A.zip
[^4]: Mark D. Wallace, written testimony, House Committee on Foreign Affairs, Subcommittee on Terrorism, Nonproliferation, and Trade, hearing of 27 January 2015, docs.house.gov. https://docs.house.gov/meetings/FA/FA18/20150127/102855/HHRG-114-FA18-Wstate-WallaceM-20150127.pdf
[^5]: Counter Extremism Project, home page, Internet Archive capture of 30 September 2014 (menu "The Threat": al-Qaeda, Boko Haram, ISIS, Muslim Brotherhood; joint statement of Wallace, Townsend and Lieberman). https://web.archive.org/web/20140930092602/http://www.counterextremism.com:80/
[^6]: Mark D. Wallace, written testimony, House Committee on Oversight and Government Reform, Subcommittee on National Security, hearing of 28 October 2015, with biography. https://oversight.house.gov/wp-content/uploads/2015/10/10-28-2015-Natl-Security-Subcommittee-Hearing-on-Radicalization-Wallace-CEP-Testimony.pdf
[^7]: Form 990 of Counter Extremism Project United Inc for the tax year ended 31 December 2021 (IRS e-file object 202233199349331448; Part VII, Part IX, Schedule I, Schedule R), IRS bulk XML, 2022 cycles. https://apps.irs.gov/pub/epostcard/990/xml/2022/2022_TEOS_XML_02A.zip
[^8]: Form 990-O of Counter Extremism Project United Inc for the tax year ended 31 December 2017 (IRS e-file object 201823199349316562; Part I, Part VII, Schedule I), IRS bulk XML. https://projects.propublica.org/nonprofits/organizations/810878718
[^9]: Form 990 of The Green Light Project Inc for the tax year ended 31 December 2016 (IRS e-file object 201703459349300950), IRS bulk XML. https://projects.propublica.org/nonprofits/organizations/464631639
[^10]: Form 990 of ACANI Inc, then American Coalition Against a Nuclear Iran Inc (EIN 26-2387657), for the tax year ended 31 December 2016 (IRS e-file object 201713459349300326; Part VII contractors), IRS bulk XML. https://projects.propublica.org/nonprofits/organizations/262387657
[^11]: Form 990 of ACANI Inc for the tax year ended 31 December 2018 (IRS e-file object 201923089349301112; Part III: "To inform the public about the nature of the Iranian regime"; "UANI publishes research and daily news summaries"), IRS bulk XML. https://projects.propublica.org/nonprofits/organizations/262387657
[^12]: Form 990 of Counter Extremism Project United Inc for the tax year ended 31 December 2020 (IRS e-file object 202113199349328996; Part VII, Schedule I), IRS bulk XML, 2021 "Redo" cycles. https://apps.irs.gov/pub/epostcard/990/xml/2021/2021_TEOS_XML_01A.zip
[^13]: Form 990 of Counter Extremism Project United Inc for the tax year ended 31 December 2018 (IRS e-file object 201933089349301113; Part VII, Schedule I, Schedule R), IRS bulk XML. https://projects.propublica.org/nonprofits/organizations/810878718
[^14]: Form 990 of Counter Extremism Project United Inc for the tax year ended 31 December 2022 (IRS e-file object 202343199349331654; Part I, Part VII, Schedule I), IRS bulk XML, 2023_TEOS_XML_11A.zip. https://apps.irs.gov/pub/epostcard/990/xml/2023/2023_TEOS_XML_11A.zip
[^15]: Form 990 of Donors Trust Inc (EIN 52-2166327) for the tax year ended 31 December 2020 (IRS e-file object 202133199349305758; Schedule I: ACANI Inc 1,980,000 dollars), IRS bulk XML, 2021 cycles. https://apps.irs.gov/pub/epostcard/990/xml/2021/2021_TEOS_XML_01A.zip
[^16]: Form 990 of Donors Trust Inc for the tax year ended 31 December 2021 (IRS e-file object 202243199349308799; Schedule I: ACANI Inc 1,950,000 and Green Light Project 3,150,000 dollars), IRS bulk XML, 2022 cycles. https://apps.irs.gov/pub/epostcard/990/xml/2022/2022_TEOS_XML_02A.zip
[^17]: Form 990 of Donors Trust Inc for the tax year ended 31 December 2022 (IRS e-file object 202323049349300742; Schedule I: ACANI Inc 4,300,000 and Green Light Project 4,650,000 dollars), IRS bulk XML, 2023_TEOS_XML_11A.zip. https://apps.irs.gov/pub/epostcard/990/xml/2023/2023_TEOS_XML_11A.zip
[^18]: Form 990 of Donors Trust Inc for the tax year ended 31 December 2023 (IRS e-file object 202423189349304787; Schedule I: ACANI Inc 3,685,000 and Green Light Project 3,680,000 dollars), IRS bulk XML, 2024_TEOS_XML_11A.zip. https://apps.irs.gov/pub/epostcard/990/xml/2024/2024_TEOS_XML_11A.zip
[^19]: Form 990 of Donors Trust Inc for the tax year ended 31 December 2024 (IRS e-file object 202513179349312256; Schedule I: ACANI Inc 2,770,000 and Green Light Project 2,600,000 dollars), IRS bulk XML, 2025_TEOS_XML_11D.zip. https://apps.irs.gov/pub/epostcard/990/xml/2025/2025_TEOS_XML_11D.zip
[^20]: ProPublica Nonprofit Explorer, API record for The Green Light Project Inc (EIN 46-4631639), filings 2014 to 2023, queried 1 October 2026. https://projects.propublica.org/nonprofits/api/v2/organizations/464631639.json
[^21]: ProPublica Nonprofit Explorer, API record for ACANI Inc (EIN 26-2387657), filings 2011 to 2023, queried 1 October 2026. https://projects.propublica.org/nonprofits/api/v2/organizations/262387657.json
[^22]: Eli Clifton and Murtaza Hussain, "Dark-Money Group Linked to Anti-Iran, Pro-Israel Network Targets Turkey but Has No Turks", The Intercept, 26 November 2021 (also published by Responsible Statecraft as "Dark money network pushes pro-UAE/Saudi policies from New York"). https://theintercept.com/2021/11/26/turkish-democracy-project-mark-wallace-thomas-kaplan/
[^23]: Form 990 of The Green Light Project Inc for the tax year ended 31 December 2017 (IRS e-file object 201803199349316560), IRS bulk XML. https://projects.propublica.org/nonprofits/organizations/464631639
[^24]: Form 990 of The Green Light Project Inc for the tax year ended 31 December 2020 (IRS e-file object 202133199349329703; Part VII Section B: Hany Farid 160,000 dollars, Frances Fragos Townsend 240,000; Schedule I: Parallel Networks 88,384 dollars), IRS bulk XML, 2021 cycles. https://apps.irs.gov/pub/epostcard/990/xml/2021/2021_TEOS_XML_01A.zip
[^25]: Form 990 of The Green Light Project Inc for the tax year ended 31 December 2021 (IRS e-file object 202233199349331048), IRS bulk XML, 2022 cycles. https://apps.irs.gov/pub/epostcard/990/xml/2022/2022_TEOS_XML_02A.zip
[^26]: Form 990 of The Green Light Project Inc for the tax year ended 31 December 2022 (IRS e-file object 202343199349328544; Part VII Section B: Hany Farid 120,000 dollars), IRS bulk XML, 2023_TEOS_XML_11A.zip. https://apps.irs.gov/pub/epostcard/990/xml/2023/2023_TEOS_XML_11A.zip
[^27]: Form 990 of ACANI Inc for the tax year ended 31 December 2017 (IRS e-file object 201813199349315096), IRS bulk XML. https://projects.propublica.org/nonprofits/organizations/262387657
[^28]: Rosie Gray, "Anti-Extremism Group Gets State Department Support, But Twitter Remains Wary", BuzzFeed News, 27 September 2015. https://www.buzzfeednews.com/article/rosiegray/anti-extremism-group-gets-state-department-support-but-twitt
[^29]: House Committee on Foreign Affairs, "Truth in Testimony" disclosure form of Mark Wallace for a hearing dated 25 November 2017, organisation represented "United Against Nuclear Iran", file HHRG-115-FA13-TTF-WallaceM-20171025, docs.house.gov. https://docs.house.gov/meetings/FA/FA13/20171025/106544/HHRG-115-FA13-TTF-WallaceM-20171025.pdf
[^30]: House Committee on Oversight and Government Reform, Subcommittee on National Security, "Radicalization: Social Media and the Rise of Terrorism", hearing of 28 October 2015, official transcript. https://www.govinfo.gov/content/pkg/CHRG-114hhrg97977/html/CHRG-114hhrg97977.htm
[^31]: Patrick Tucker, "How to Stop the Next Viral Jihadi Video", Defense One, 17 June 2016. http://www.defenseone.com/technology/2016/06/how-stop-next-viral-jihadi-video/129210/
[^32]: Counter Extremism Project, tag page "eGLYPH" (items describing "CEP Senior Advisor Dr. Hany Farid"), counterextremism.com, accessed 1 October 2026. https://www.counterextremism.com/news-free-tags/eglyph
[^33]: Brief of Amici Curiae Counter Extremism Project (CEP) and Hany Farid in Support of Petitioners, Gonzalez v. Google LLC, No. 21-1333 (U.S. Supreme Court), filed 7 December 2022, Interest of Amici Curiae and footnote 1. https://www.supremecourt.gov/DocketPDF/21/21-1333/249378/20221207151224344_No.%2021-1333_Brief%20of%20Amici%20Curiae.pdf
[^34]: Counter Extremism Project, press release "Extremist Content Online: White Supremacist Telegram Channels Identify Need for Alternative Platform After State Department's Terrorgram Collective Designation", 21 January 2025, with site navigation listing databases and programs. https://www.counterextremism.com/press/extremist-content-online-white-supremacist-telegram-channels-identify-need-alternative
[^35]: RTI International for the Department of Homeland Security, "Counter Extremism Project Site Profile: FY2020 Targeted Violence and Terrorism Prevention (TVTP) Grantee Evaluation", November 2023. https://www.dhs.gov/sites/default/files/2023-11/23_1108_st_CEP_SiteProfile.pdf
[^36]: Eli Clifton and Murtaza Hussain, "Dark money network pushes pro-UAE/Saudi policies from New York", Responsible Statecraft, 26 November 2021 (quotes the 2015 truth-in-testimony statement of Wallace, the August 2016 Coleman email to Otaiba, and the statement that none of the groups had registered under FARA). https://responsiblestatecraft.org/2021/11/26/dark-money-network-pushes-pro-uae-saudi-policies-from-new-york/
[^37]: Eli Clifton, "Hacked Emails Reveal Close Ties Between UAE and Anti-Iran/Qatar Advocacy Groups", LobeLog, 21 July 2017. https://lobelog.com/hacked-emails-reveal-close-ties-between-uae-and-anti-iranqatar-advocacy-groups/
[^38]: Counter Extremism Project, "Qatar, Money, and Terror" (key findings; "CEP's QATAR-HARBORS Campaign"), counterextremism.com, accessed 1 October 2026. https://www.counterextremism.com/content/qatar-money-and-terror
[^39]: Benjamin Weinthal, "Exclusive: Alleged Qatar spy operation said to have targeted GOP lawmakers opposed to Muslim Brotherhood", Fox News Digital, 20 January 2024. https://www.foxnews.com/world/exclusive-alleged-qatar-spy-operation-said-to-have-targeted-gop-lawmakers-opposed-to-muslim-brotherhood
