After Epstein: Who holds global philanthropy accountable?

Key reasons to read this article

• The Epstein files did not accuse philanthropists of crimes, but they raised an uncomfortable question: why is there so little public oversight in philanthropy?
• Billions of private dollars fund global health, science and development, and yet this sector is poorly regulated.
• Unlike governments, philanthropists answer to no voters, no parliament, so who actually holds them accountable?
• Since philanthropy, intended to solve problems, helps to build global policy, shouldn’t it be regulated?

When the U.S. Department of Justice released roughly 3.5 million pages from its investigation into the late financier and convicted sex offender Jeffrey Epstein in January 2026, the documents revealed correspondence involving a number of prominent donors and figures from global philanthropy.

None of those named in the files were accused of wrongdoing. But their appearance in the records has forced a deeper question. Who holds powerful philanthropists accountable when their wealth increasingly shapes public policy, research agendas, and international development priorities?

This question arises at a sensitive moment for the aid system. As traditional donor governments retreat from multilateral development commitments, a concentrated class of ultra-wealthy philanthropists has stepped in, funding global health initiatives, climate programs and efforts towards poverty reduction.

Yet, while public aid is subject to parliamentary scrutiny, freedom of information laws and diplomatic oversight, much of the private capital now filling the funding gap operates within a far more fragmented system of accountability.

Who regulates global philanthropy?

Despite its massive global footprint, the sector appears to be operating in a governance vacuum. In 2023, the world’s 10 largest development-focused foundations disbursed a combined total of US$10.3 billion, according to Organisation for Economic Co-operation and Development data. United States foundations alone gave US$109.8 billion domestically in 2024, according to Giving USA. In terms of global health, food security, and scientific research, private philanthropic capital has not simply supplemented public aid, it has come to define it.

However, formal oversight remains thin on the ground. According to the IFR4NPO Project, a global initiative led by Humentum, 92% of countries lack national-level guidance for non-profit financial reporting. The primary international body that oversees philanthropic flows, the Financial Action Task Force, focuses on money laundering and terrorist financing with its regulations affecting non-profits only incidentally.

The OECD tracks self-reported development spending by major foundations which although a meaningful step, has no enforcement power behind it. There is no other equivalent body to ensure donor accountability, governance standards, or mission integrity across borders.

What that gap in reporting and accountability can enable is precisely what the Epstein files have forced into view. Scholars Rizwan Bukhari and Muhammad Hamayoun, writing in the Journal of Regional Studies Review, argue that Epstein’s case illustrates how philanthropic affiliation can function as a legitimizing instrument, while institutions that are dependent on private capital may become structurally reluctant to scrutinize its origins.

Patricia Illingworth, author of Giving Now, describes a related psychological dynamic, writing that donors who view giving primarily as an expression of virtue may accumulate what she calls “moral credits”, a perception that charitable acts can offset other less laudable behavior.

The concern is not that philanthropy attracts bad actors by design. It is that a system with limited transparency and no cross-border oversight offers few mechanisms to distinguish between the good and the bad.

How donor power became concentrated

The concentration of philanthropic power is not an accident of markets. Gabriela Sandoval of the Excessive Wealth Disorder Institute and Rajasvini Bhansali of the Solidaire Network argue it is a direct consequence of tax policy, where public exemptions that subsidize private foundations and donor-advised funds have enabled an accumulation of giving power that has never been democratically sanctioned.

Donor-advised funds, which carry no mandatory payout requirements, have exponentially grown over the past decade. U.S. foundation assets now approach US$1.7 trillion, with average investment returns of 7.1% annually, meaning that endowment compounding more quickly than they are disbursed.

That financial scale increasingly translates into agenda-setting power inside multilateral institutions. Major foundations now help to shape priorities, co-design public-private programs, and in some cases fund a substantial share of global institutions’ budgets.

Between 2000 and 2024, for instance, the Gates Foundation made 640 grants worth US$5.5 billion to the World Health Organization, making it the organization’s second-largest funder after the United States, which has since withdrawn from WHO.

Linsey McGoey, Professor of Sociology at the University of Essex, noted that when a significant portion of a multilateral institution’s budget comes from a private foundation, the power to stipulate how the money is spent comes with it, and questions of conflict of interest then follow structurally, not incidentally.

A study by BMJ Global Health confirmed that priority-setting power in global health is now almost exclusively held by those with financial control, leaving recipient communities with limited agency over the interventions designed for their benefit.

As Rob Reich of Stanford University argues, philanthropy at this scale represents private power over public goods, subsidized by tax exemptions, and answerable to no electorate.

For supporters, this financial scale is precisely philanthropy’s advantage. The Philanthropy Roundtable, which represents more than 600 donors, foundations, and philanthropic organizations, argues that private foundations provide a level of speed and flexibility that government programs often struggle to match.

When the safety net is no longer safe

As governments reduce development spending, non-governmental organizations are increasingly turning to private foundations and ultra-high-net-worth donors for support. But this shift has not necessarily broadened the philanthropic landscape.

Suparna Chaudhry of Lewis and Clark College observed in Foreign Policy that although foundations have stepped forward after the reductions in aid, the pledges can be measured in millions against gaps that are measured in billions, and funds often flowed to the same established actors.

It was into this landscape that the Epstein files arrived. Charities competing for private donor relationships suddenly found themselves examining the backgrounds of the very donors on whom they depended. According to the law firm, Foley and Lardner, the Department of Justice disclosures have prompted organizations to review donor lists for links to individuals named in the documents and to assess potential reputational risks. Several UK-based charities have already begun to review historical donations.

John-Arne Røttingen, CEO of the Wellcome Trust, has also emphasised the structural limits of philanthropy to replace state capacity. “The scale of the U.S. role, in both money and technical and institutional capacity, means that no one can fill that gap,” he explained.

The sector is therefore being asked to carry greater responsibility precisely at a moment when the scrutiny of its largest actors is intensifying.

The path to reform

At the Institute for Policy Studies, researchers have called for the mandatory foundation payout rate to be raised by 5-10% and for account-by-account disclosure of donor-advised fund identity and payouts, arguing the current framework allows wealth to compound while shielding consequential giving behind a layer of anonymity.

However, Ken Kies, a tax policy advocate, argues that donor-advised funds should be spared from what he calls burdensome regulations.

Scientists and researchers have called for a new framework of funder accountability in research, proposing that institutions adopt principles that allow researchers the explicit right to terminate funding relationships without consequence if a funder holds a criminal conviction.

None of these proposals is imminent. However, they are all more feasible now than prior to January 2026, not because the Epstein files proved wrongdoing by any foundation but because they forced a question the sector has long put off facing. At what scale of public consequence does private philanthropy require public governance?