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Marc J. Lane: Capital & Conscience · Aug 12, 2026

Where Did the $10 Billion Go?

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Marc J. Lane · Marc J. Lane: Capital & Conscience

Somewhere, a donor believed they were funding children’s health care.

Another believed they were supporting climate solutions.

Another believed they were helping alleviate poverty, expanding educational opportunity or advancing the United Nations Sustainable Development Goals.

Together, they helped build what was reported to be one of the largest charitable funds in America.

Today, many are still asking a simple question:

What happened to the money?

The question arises from the extraordinary saga of the SDG Impact Fund, a crypto-based donor-advised fund that reported more than $10 billion in assets before Georgia regulators alleged extensive misuse of charitable funds and barred its chief executive from operating a charity in the state.

But the scandal is not that regulators may now be struggling to account for $10 billion.

The scandal is that a charitable organization could claim to possess $10 billion without a system capable of verifying that claim before the questions began.

That is not merely an SDG problem.

It is an American philanthropy problem.

For decades, Americans have accepted an implicit bargain. Wealth generated in private markets can be redirected toward public purposes through charitable institutions. In return, those institutions receive extraordinary benefits: tax exemption, deductible contributions and something even more valuable than either.

Public trust.

Every charitable deduction represents a public subsidy. Taxpayers forgo revenue because charities are expected to advance public purposes.

The arrangement works only if accountability keeps pace with privilege.

Yet one of the great paradoxes of modern America is that some of the nation’s largest pools of tax-advantaged wealth can operate with less transparency than many publicly traded corporations.

As philanthropy has grown larger, more sophisticated and increasingly intertwined with financial markets, oversight has not always kept pace.

The SDG controversy exposes what can happen when it does not.

The fund’s growth was astonishing. Public filings indicate that SDG Impact Fund reportedly grew from roughly $117,000 in assets in 2017 into an organization claiming more than $10 billion only a few years later, placing it among the largest charitable funds in the country.

In its last publicly available IRS filing, covering 2022, the fund continued to report assets exceeding $10 billion despite the collapse in cryptocurrency prices that had erased significant value across the digital-asset market.

Then came the questions.

In June 2026, Georgia Secretary of State Brad Raffensperger’s office ordered the fund to cease soliciting charitable contributions in the state, imposed a civil penalty and barred its chief executive, Anthony Suber, from operating a charity in Georgia. Investigators alleged that charitable funds had been commingled with personal accounts and used for expenses that included private-school tuition, real estate and personal purchases.

Those allegations remain subject to investigation.

But regardless of how the facts are ultimately resolved, one reality is already clear.

A charitable organization reportedly holding assets comparable to major financial institutions was able to operate for years amid uncertainty that should concern every donor, regulator and taxpayer.

The deeper problem is structural.

Responsibility for overseeing charities is spread among the Internal Revenue Service, state attorneys general, secretaries of state and other agencies. Oversight is fragmented, and accountability often disappears in the gaps.

The result is a system in which extraordinarily large charitable organizations can grow across multiple jurisdictions while meaningful scrutiny remains divided among regulators that may not effectively share information.

A financial institution reporting tens of billions of dollars in assets would face extensive disclosure requirements and ongoing verification.

Why should an institution entrusted with charitable assets dedicated to public purposes face less scrutiny?

Charities are different.

They should be held to a higher standard.

Banks protect private wealth.

Charities steward resources intended for the public good.

The assets entrusted to philanthropic institutions belong, morally speaking, not to managers but to missions.

That fact makes transparency more important, not less.

The lesson of the SDG saga is not that donor-advised funds are inherently flawed. Nor is it that cryptocurrency and philanthropy are incompatible.

Both can serve worthwhile purposes.

The lesson is that innovation without accountability eventually erodes confidence.

And confidence is the nonprofit sector’s most valuable asset.

When citizens lose faith in charitable institutions, the consequences extend far beyond any single organization. Honest nonprofits face greater skepticism. Fundraising becomes harder. Public support for charitable incentives weakens. The credibility of the entire sector suffers.

Trust, once lost, is difficult to regain.

That does not mean every charity requires new regulation. A neighborhood food pantry should not face the same reporting obligations as an institution claiming to manage billions of dollars in tax-advantaged assets.

But scale matters.

Organizations entrusted with extraordinary amounts of charitable capital should accept extraordinary obligations of transparency.

Large charities and donor-advised fund sponsors should provide more timely disclosures of assets, major holdings and grantmaking activity. Organizations managing billions should demonstrate not merely that assets exist but that adequate safeguards exist to protect them.

Digital assets deserve particular attention. If a charity claims to hold billions of dollars in cryptocurrency, independent auditors should be able to verify those holdings through custodial records, blockchain-based confirmation and transparent valuation methods.

Information sharing among regulators should improve as well. A charity executive sanctioned in one jurisdiction should not be able to relocate operations elsewhere without regulators having access to relevant enforcement history.

The Internal Revenue Service cannot police every charity.

But when an organization reports extraordinary growth, extraordinary assets or unusually large digital holdings, regulators should have the resources to ask questions before uncertainty becomes scandal.

These reforms do not require a vast new bureaucracy.

They require a simple principle:

The larger the pool of tax-advantaged charitable capital, the greater the obligation to demonstrate transparency, accountability and stewardship.

If an organization claims to hold billions of dollars in charitable assets, regulators and independent auditors should be able to verify where those assets are held, how they are valued, who oversees them and whether they are being administered consistently with charitable purposes.

That is not regulatory overreach.

It is the minimum price of public trust.

The mystery surrounding SDG is larger than one fund and larger than one executive.

It is a test of whether Americans can still distinguish between wealth held for private benefit and wealth held in trust for the public.

Investigators may ultimately determine where every dollar went.

But that is no longer the central question.

The central question is whether a philanthropic sector entrusted with trillions of dollars in tax-advantaged wealth can continue to rely on trust without providing transparency equal to its scale.

Somewhere, donors believed they were helping children receive medical care.

Somewhere, donors believed they were supporting climate solutions, expanding educational opportunity, reducing poverty and advancing humanity’s shared aspirations.

They were entitled to believe that the institutions safeguarding those resources were worthy of their trust.

The future of American philanthropy depends not on the size of charitable fortunes, but on the strength of the public trust that sustains them.

And public trust begins with a simple proposition:

If an organization claims to hold billions of dollars for charitable purposes, the public should never have to wonder where the money is.

When charitable wealth receives significant public benefits through the tax code, what level of transparency should the public be entitled to in return? How can we ensure that standard is met? I’d love to hear more about your thoughts and ideas in the comments.

And, if this essay resonated with you, please consider sharing it with someone who might enjoy Capital & Conscience and the conversations we’re building around the ways we can drive positive social change through innovation, law, capital, and policy.

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