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The Police Foundation’s Rise: Implications of Public Policing’s Dark Money

The Police Foundation’s Rise: Implications of Public Policing’s Dark Money Abstract A new kind of organization has emerged in public policing across the United States and Canada: the ‘police foundation’. The foundation’s private, nonprofit legal status allows it to engage in private fundraising activities that police, as public bodies, cannot. In many municipalities, police foundations raise funds directed toward police procurement practices and operations. We discuss reasons for and detail the rise and growth of these foundations as they have modeled the New York Police Department’s Foundation and changes in that foundations’ expenditures over time, and examine the key claim that police foundations reduce corruption by maximizing transparency. We draw from literature on financial obfuscation and explore controversies centered on police foundation solicitation and use of private funds in North America. Conceptualizing these private entities as shell corporations that permit transactions in dark money, we raise questions about police foundation transparency. We conclude by discussing the implications for public policy as well as police transparency across North America. Police foundations are a new phenomenon in the United States (US) and Canada. Their number and impact are growing rapidly. As a prominent police foundation advocate writes: ‘a new paradigm is emerging in the face of today’s economic challenges, in which police leaders are leveraging private resources to fill budget gaps’ (Delaney 2010). One way police organizations are accomplishing this leverage is through establishing municipal police foundations. These foundations operate as private, nonprofit charities that amass monies mostly from the private corporate sphere. Funds are raised through private events (e.g. galas), advertising, direct solicitation and other strategies typical of the nonprofit sector. Without a foundation, police departments can accept donations from private entities, but risk undermining the department’s integrity or breaking conflict of interest policies. Police policies that aim to prevent bribery, collusion, corruption and conflict of interest often deter acceptance of donations directly from private entities. However, no similar rules and laws exist for police foundations, which ‘are uniquely positioned to serve as vehicles for donations from private sources, while helping to safeguard the integrity of police departments’ (Delaney 2010). Though some monies raised by foundations are channeled toward other charities, much is transferred to police departments for procurement of new equipment and technologies, to outfit units, or fund new initiatives. The flows of capital are currently small compared to overall public police budgets, which in North America are derived from tax revenues, yet there are questions about the ethics and practical issues raised by these opaque ‘vehicles for donations’ in public policing. Little research has examined the emergence and growth of police foundations, their effects on transparency, or their implications for corruption and conflict of interest that result from this brokering between public police and the corporate world. The fact that police foundation staff promote foundations as enhancing transparency and preventing ‘institutional corruption’ (Gray 2013) rather than the opposite is the central theme of this paper. Literature on public police and transparency takes two forms. First, there is research that investigates how police manage media relations to appear transparent (e.g. Mawby 1999). This includes literature on new media and police transparency (e.g. Goldsmith 2010) that explores how public police respond to social media and smart technology visibilities of police work that erode police authority and their capacity to shape news and legal narratives. Second, literature on corruption and police implicitly focuses on transparency (e.g. Dean et al. 2010). Criminology and criminal justice studies have not accounted for the challenges to transparency created by private foundation involvement in public police finances. Examining police foundation establishment and practices, we contribute to the literature on criminal justice and transparency (Hood 2006; Fenster 2006) and to what may soon be a growing literature on the phenomenon of police foundations. To interpret the establishment and practices of police foundations in North America, and to enrich literature on private sponsorship of policing and private influence on public police (Coleman 2004; Lippert and Walby forthcoming; Luscombe et al. forthcoming; Crawford 2006; Ayling et al. 2009), we draw from literature on financial obfuscation and domestic shell corporations. Sponsorship of police through foundations differs from direct sponsorship explored in existing literature in key ways. Foundations protect public police from accusations of receiving taboo private monies from corporations, and in this sense the foundation obfuscates or renders opaque a disreputable exchange (Rossman 2014) that would otherwise be unethical and illegal. Whereas reputable exchanges maintain the boundary between sacred and profane, where profane is understood as something culturally and institutionally ‘set apart’ (Rossman 2014: 44), disreputable transactions involve taboo exchanges of sacred for profane goods or services, like a gift or bribe (profane) exchanged for publicly funded services (sacred) (Fridman and Luscombe forthcoming; Grabosky 2007). Under these circumstances, the former are perhaps best termed ‘dark money’ (Mayer 2016). Rossman (2014) discusses three strategies of financial obfuscation: bundling, brokerage and gift exchange. The second, brokerage, involves two parties sequentially and indirectly exchanging sacred for profane goods through an intermediary broker. Foundation staff can thus engage in brokering that public police cannot. Jancsics (2016) refers to such brokerage organizations as ‘domestic shell corporations’, which enable public-private financial relationships that would otherwise be deemed undemocratic and contrary to the public interest. Foundations can become ‘cash cows’ (Jancsics and Javor 2012; Jancsics 2015) for public police by amassing and circulating corporate revenues that might otherwise be deemed illegitimate. Despite these concerns, the rising phenomenon of police foundations has not yet been a focus in literature on private sponsorship of and influence on public policing (Grabosky 2007; Ayling et al. 2009). We argue police foundations facilitate a corporate approach to police funding representing an emerging exemplar of corporatization (Lippert and Walby forthcoming; Luscombe et al. forthcoming; O’Malley and Hutchinson 2007) of criminal justice. Conceptualizing police foundations this way allows inquiry to move beyond the claim that police foundations promote transparency, shifting attention to empirical questions about how these organizations emerge, the relations and capital they conceal and what might check or at least partly resolve the deepening of this private influence on public policing. We begin the article by describing our methodological choices and some challenges encountered in studying police foundations. Second, we provide a history and explanation for the police foundation’s rise in North America including the relationship with neoliberalism. Third, we assess advocates’ claims about police foundations and their transparency. We conclude by discussing implications for public policy and literature on police transparency and accountability. Data and Method We examine municipal police foundations and exclude from our sample police sports, pipe band, memorial, canine, police history/museum, officer scholarship and award, reserve and police youth foundations. In contrast to police foundations’ broad mandates and funding capabilities, these other foundations focus their funding and only rarely if ever contribute to police procurement or operational support, which is our core concern. We also exclude from our sample US state- and national-level foundations (e.g. American Police Foundation, Illinois Association of Chiefs of Police Foundation), though these should be examined in future research. We draw from several data sources on the establishment of police foundations in the United States and Canada. Secondary data sources were primarily used due to the relatively cagey nature of police foundation operations and communications. We analyzed news articles (generated through NewsBank, Lexis Nexis and Canadian Newsstream); websites of United States and Canadian police foundations; International Association of Chiefs of Police (IACP) publications; almost two decades (1987–2005)1 of the New York City Police Foundation’s annual print journal and its ‘Starting a Police Foundation’ manual; data from GuideStar’s National Database of Charitable Organizations, the National Center for Charitable Statistics database and the Charitable Listing database of the Canada Revenue Agency; US and Canadian tax reporting forms; and City Archives in Seattle, Washington and Vancouver and Delta, British Columbia. We also collected primary data using freedom of information (FOI) requests in the United States and Canada and through interviews with foundation officials and corporate donors. While we were generally unsuccessful with FOI requests for donation, sponsorship and police foundation related data from public police agencies, responses from police departments explaining why we could not access foundation information evince barriers to transparency that we reflect on. We analyzed these data using an ‘abductive’ approach to grounded theory (Tavory and Timmermans 2014). To generate descriptive statistics on and to visualize geographic trends in police foundation establishment across North America, we used Microsoft Excel and QGIS software.2 The Police Foundation’s Rise The first major police foundation in North America was created in New York City in 1971. Two small foundations preceded it in 1966 (Manchester Police Foundation, New Hampshire) and 1968 (Glendale Police Foundation, CA), but did not achieve the international standing of the New York City Police Foundation (NYCP Foundation) which is frequently touted as the first police foundation in North America. According to the foundation’s history, it was created during a time of transition when the NYPD, undergoing corruption investigations, was reformed into a ‘modern’ police force (NYCP Foundation 2017a). In 1971, the foundation was ‘established to reduce corruption and support innovative programs that the NYPD could not readily fund’ (ibid.). The foundation in these early stages granted scholarships to officers, donated horses to the NYPD’s Mounted Unit and provided the first bullet proof vests to the department. During the 1980s and 1990s, the foundation broadened its responsibilities, taking over the Crime Stoppers reward program in the mid-1980s and became increasingly involved in helping the NYPD with training, equipment provision, technology upgrades and community outreach. According to the foundation’s former executive director, Projects initiated or concluded in 1986 include the enhancement of SPECDA [the School Program to Educate and Control Drug Abuse], an opinion survey of the public and the police, the creation of a pilot cardiovascular health program [for officers], and an expansion of a training program of the newly inaugurated police cadet corps (Delaney 1987: 7). None of these could be deemed operational. But in the 1990s, the character of the programs and initiatives reveals a qualitative shift. In this decade, the foundation acquired the first CompStat system and donated it to the NYPD. After the events of 9/11, ‘a clear role for the Police Foundation emerged: modernizing the NYPD to meet the challenges of policing a post 9/11 New York City’ (ibid.). The NYCP Foundation went on to support upgrades to the NYPD’s surveillance and technological infrastructure and supported NYPD’s counterterrorism initiatives. Due to Foundation funding, the NYPD ‘posted detectives overseas, taught others exotic languages and acquired a mobile lab to detect chemical or biological attacks’ (Wiessenstein 2003). More recently, the NYCP Foundation helped fund the NYPD’s Real Time Crime Center that opened in 2005 (NYCP Foundation 2017b). As the history section NYCP Foundation’s website concludes, ‘As we look to the future, we are more committed than ever to supporting new strategies and enhancing technical capacities. The foundation will continue to uphold the NYPD’s reputation as the paragon for 21st century law enforcement’ (ibid.). The police foundation’s rise corresponds with a concomitant ascendency of neo-liberal reforms. As White and Gill (2013) write, ‘it is undeniable that the policing sector has been ever more penetrated by market rationalities over the past couple of decades’ (p. 89–90). They note that ‘neo-liberal reforms’, which often emerge with cuts to public services, led to changes in police agencies, including ‘the sale of police services in the marketplace on a ‘user-pays’ basis’ (Lippert and Walby 2013; Lippert and Walby 2014: 79). But besides cuts to municipal police department budgets in many North American and other jurisdictions commencing in the 1980s consistent with neo-liberalism’s rise and its attendant downsizing and embrace of free market solutions in North America, there are two key sources of police foundation growth and ‘isomorphism’ (DiMaggio and Powell 1983) in North America. The first is foundation-specific entities such as the NYCP Foundation and the National Police Foundation Network and broader police networks such as the International Association of Chiefs of Police.3 Since its establishment in 1971, the NYCP Foundation has furthered establishment of police foundations elsewhere. It was not until the late 1990s that most US cities became interested in police foundations (Figure 2), and many looked to the NYCP Foundation as a model. In the five years preceding 2003, partially as a consequence of this Foundation’s seminars, ‘at least 10 foundations were launched in cities nationwide’ including Oakland, Atlanta, Detroit, Omaha and Portland (Weissenstein 2003). In 2004, the NYCP Foundation published its ‘Starting a Police Foundation Guidebook’, a lengthy step-by-step manual about how to create a police foundation, and began distributing these free of charge upon request. In 2013, Pamela Delaney, who had served as the president of the NYCP Foundation from 1983–2009 that followed extensive experience with the NYPD, started the National Police Foundation Network (NPFN). Through the NPFN, Delaney uses her NYCP Foundation experience to encourage the spread of municipal police foundations throughout the United States. On the NPFN’s website, one finds a growing body of resources on police foundation best practices, strategies and notices of workshop, training and networking opportunities for police, foundation officials or anyone interested in starting a foundation. Second, federal agencies and professional associations such as the International Association of Chiefs of Police (IACP) have spearheaded police foundation expansion. The IACP has a ‘Police Foundations Section’ whose mission is ‘to promote networking and the exchange of ideas and best practices among executives and police foundation professionals’ (IACP 2017). The IACP accordingly hosts meetings and conferences for police foundation professionals, police officials and business executives; conducts research on police foundation practices and ethics, and encourages ‘discussion for the establishment of standards and best practices for police foundations’ (IACP 2017). In 2010, the IACP’s in-house publication, The Police Chief, featured several articles on police foundations (Delaney 2007; Davis 2010; Butler and Delaney 2010).4 The US Department of Justice’s Office of Community Oriented Policing Services (COPS) has also actively promoted police foundation creation across the United States. In September 2010, the COPS office joined with the Target Corporation to launch the National Police Foundations Project, providing ‘training workshops and technical assistance to communities to sustain community policing crime reduction and crime prevention efforts by establishing or expanding existing police foundations’ (Delaney 2011). Foundations emerged in larger cities like New York and Los Angeles. Soon smaller jurisdictions followed. As the Chief of the Ottawa Police Department in Kansas and a founding member of the Ottawa Police Foundation wrote with a colleague: ‘In the past, many chief executives felt that a police foundation was only for big cities like Los Angeles and Atlanta’ (Butler and Delaney 2010). Foundations are now established in cities as small as Los Gatos, CA, Amherst, NY, as well as Ottawa, KS. Using GuideStar’s National Database of Charitable Organizations and data from the National Center for Charitable Statistics (NCCS) in the United States, we were able to identify 251 police foundations in 43 states plus Washington, DC.5 The largest number of US police foundations was established between 2014 and 2016 (37.2 per cent or 89 foundations) (Figure 2). To date, most foundations have been established in California (17.9 per cent or 45 foundations), with Virginia (7.2 per cent or 18 foundations) and Florida (7.2 per cent or 18 foundations) tied for a distant second (Figure 1). Note that across the United States there were cuts to public funding of police linked to the 2008 financial crisis. While the trend of foundation growth commenced much earlier (Figure 2), 2009 marks the beginning of its acceleration to new heights. We contend that police foundation growth has emerged in lockstep with cuts to public police funding noted earlier, the latter of which have been neither as deep nor as wide in Canada where public funding of police has been more stable than in the United States. This is reflected in, for example, much higher municipal public police officer salaries in Canada (AMO 2015: 13). Fig. 1 View largeDownload slide US and Canada police foundations by state/province, by total number of police foundations, excluding Alaska and Canadian Territories. Fig. 1 View largeDownload slide US and Canada police foundations by state/province, by total number of police foundations, excluding Alaska and Canadian Territories. Fig. 2 View largeDownload slide Number of US Police Foundations by Year, dates mark the year the foundation was granted 501(c)3 status by the IRS. Fig. 2 View largeDownload slide Number of US Police Foundations by Year, dates mark the year the foundation was granted 501(c)3 status by the IRS. For these 251 police foundations, we also examined organizational income data.6 The GuideStar database on US charities collects data on income and assets from the IRS’s Exempt Organizations Business Master File (EOBMF).7 We identified 237 of the 251 police foundations using the GuideStar database. The remaining 14 we identified using the NCCS’s database and then manually collected information on income from the EOBMF. EOBMF income data, based on 2015 Form 990s, shows most police foundations we identified, despite being structurally modeled after larger foundations like the NYCP Foundation, were not yet receiving high levels of private and/or corporate donations. Of the 251 total foundations we located in the US, 27.1 per cent (68 foundations) had a reported income of > $100,000 USD, what we used as our threshold for an active and lucrative foundation, 28.3 per cent (71 foundations) reported < $100,000 USD in income and 44.6 per cent (112 foundations) reported an income of zero. Of 112 foundations reporting zero income, 53 per cent were relatively new, established between 2014 and 2016. Finally, of 251 foundations, 4.3 per cent (11 foundations) reported incomes of > $1,000,000 USD, with the NYCP Foundation reporting $19.9 million USD in 2015 (Table 1). Table 1 US police foundations with > $1,000,000 USD in reported income in 2015 Police foundation Income (revenue) Year Est. New York City Police Foundation $19,936,333 ($7,936,387) 1971 Atlanta Police Foundation $7,129,001 2003 Los Angeles Police Foundation $4,970,392 1998 Saint Paul Police Foundation $3,463,874 2005 Palm Beach Police Foundation $2,512,212 2006 Houston Police Foundation $2,372,057 2004 New Orleans Police and Justice Foundation $2,042,613 1996 St Louis Police Foundation $1,556,317 2007 Boston Police Foundation $1,463,147 1994 Detroit Public Safety Foundation $1,312,485 2003 Seattle Police Foundation $1,157,513 2002 Police foundation Income (revenue) Year Est. New York City Police Foundation $19,936,333 ($7,936,387) 1971 Atlanta Police Foundation $7,129,001 2003 Los Angeles Police Foundation $4,970,392 1998 Saint Paul Police Foundation $3,463,874 2005 Palm Beach Police Foundation $2,512,212 2006 Houston Police Foundation $2,372,057 2004 New Orleans Police and Justice Foundation $2,042,613 1996 St Louis Police Foundation $1,556,317 2007 Boston Police Foundation $1,463,147 1994 Detroit Public Safety Foundation $1,312,485 2003 Seattle Police Foundation $1,157,513 2002 View Large Table 1 US police foundations with > $1,000,000 USD in reported income in 2015 Police foundation Income (revenue) Year Est. New York City Police Foundation $19,936,333 ($7,936,387) 1971 Atlanta Police Foundation $7,129,001 2003 Los Angeles Police Foundation $4,970,392 1998 Saint Paul Police Foundation $3,463,874 2005 Palm Beach Police Foundation $2,512,212 2006 Houston Police Foundation $2,372,057 2004 New Orleans Police and Justice Foundation $2,042,613 1996 St Louis Police Foundation $1,556,317 2007 Boston Police Foundation $1,463,147 1994 Detroit Public Safety Foundation $1,312,485 2003 Seattle Police Foundation $1,157,513 2002 Police foundation Income (revenue) Year Est. New York City Police Foundation $19,936,333 ($7,936,387) 1971 Atlanta Police Foundation $7,129,001 2003 Los Angeles Police Foundation $4,970,392 1998 Saint Paul Police Foundation $3,463,874 2005 Palm Beach Police Foundation $2,512,212 2006 Houston Police Foundation $2,372,057 2004 New Orleans Police and Justice Foundation $2,042,613 1996 St Louis Police Foundation $1,556,317 2007 Boston Police Foundation $1,463,147 1994 Detroit Public Safety Foundation $1,312,485 2003 Seattle Police Foundation $1,157,513 2002 View Large To lend further insight into how the NYCP Foundation arrived at this extraordinary amount, we analyzed data reported in its exclusive annual print journal (1987–2005). This journal with evocatively themed volumes (e.g. ‘Honor’ (1987), ‘Partners’ (1989), ‘True Blue’ (1990), ‘Commitment’ (1991) and ‘Pride’ (1993)) is primarily a corporate advertising venue comprising revenue-generating ads by transnational corporations such as Budweiser, Revlon, Smith and Wesson and Philip Morris (mostly claiming to ‘salute’ the NYPD), as well as more locally-named but iconic firms like the New York Yankees Baseball Club. Even the Trump Organization in a 1987 full page ad gave ‘their deep appreciation to New York’s Finest’ unbeknownst that 30 years later the NYPD would be spending considerable resources ($308,000 USD daily) providing protection for Trump Tower and its occupants from regular street protests in Manhattan (Reuters 2017). These advertisement based sponsorships grew over time. The 1990 volume of the NYCP Foundation’s journal displays ads from 60 major corporations, the 2001 volume has 84 and the 2016 volume (available only on NYPF website) lists 96. As well, by the 1990s the NYCP Foundation had commenced—mimicking practices well established in the larger charitable fundraising world—publication in this journal of a donor hierarchy of Major 3 Star Donors ($75k and over US), 2 star ($25–75k US), 1 Star ($10–25k), Gold Shields ($10–5k US) and Silver Shields ($1–5k US), with each year the number of donors in the three-Star category steadily increasing after 1992. In 1997, a new four star donor level appears ($100k to 1 million US and over), later called ‘platinum,’ that includes 10 corporations and corporate foundations. In 2011–2012 fiscal year, the last year this information was reported, there are 14 platinum donors of $100k or more (followed by numerous listed gold, silver, bronze, benefactors and donors). This hierarchical system of incentivizing donor rewards (i.e. stars, shields, precious metals) has been emulated by other police foundations throughout the United States and Canada (e.g. Vancouver 2017). In Canada, there are fewer police foundations (see Table 2), but more are being established. Using the online Charities Listing database of Canada Revenue Agency,8 we identified seven Canadian municipal police foundations: Abbotsford, Calgary, Delta, Edmonton, Vancouver, RCMP Foundation (formerly Mounted Police Foundation) and the Fondation du service de la ville de Montreal (SPVM Foundation). In 1976, the Vancouver Police Foundation became the first foundation in Canada only 5 years after the NYCP Foundation. The Vancouver Foundation began modestly, receiving only about $20,000 CDN from donors in its first months (Vancouver 1976), but since has undergone exponential growth in private funds. Between 2011 and 2013, the Vancouver Police Foundation reported about $1,000,000 CDN in annual revenues, over $3,000,000 CDN in 2014, and roughly $8,200,000 CDN in 2015. The next foundation established after Vancouver was the national RCMP Police Foundation (1994),9 followed by foundations in Edmonton (2000), Delta (2004), Abbotsford (2005), Montreal (2008) and Calgary (2010). The province of BC has seen the most (3) police foundations emerge (Table 2). Other municipal and provincial police forces in Canada are planning to establish foundations. At a recent police conference attended by one of us, two impromptu discussions among participants broke out about the merits of police foundations. The exuberance for establishing foundations was palpable. The feeling was summed up by a former Chief Constable of the Vancouver Police Department (VPD) on the foundation website: ‘When the public needs help, they call the police. When the VPD needs help, they call the Vancouver Police Foundation.’ Table 2 Canadian police foundations with reported revenue in 2015 Police foundation Province Est. 2015 Revenue (CDN) Vancouver Police Foundation BC 1976 $8,198,426 RCMP Foundation ON 1994 $1,201,737 Edmonton Police Foundation AB 2000 $492,730 Delta Police Foundation BC 2004 $40,626 Abbotsford Police Foundation BC 2005 $51,193 SPVM (Montreal) Foundation QC 2008 $2,705 Calgary Police Foundation AB 2010 $2,630,270 Police foundation Province Est. 2015 Revenue (CDN) Vancouver Police Foundation BC 1976 $8,198,426 RCMP Foundation ON 1994 $1,201,737 Edmonton Police Foundation AB 2000 $492,730 Delta Police Foundation BC 2004 $40,626 Abbotsford Police Foundation BC 2005 $51,193 SPVM (Montreal) Foundation QC 2008 $2,705 Calgary Police Foundation AB 2010 $2,630,270 View Large Table 2 Canadian police foundations with reported revenue in 2015 Police foundation Province Est. 2015 Revenue (CDN) Vancouver Police Foundation BC 1976 $8,198,426 RCMP Foundation ON 1994 $1,201,737 Edmonton Police Foundation AB 2000 $492,730 Delta Police Foundation BC 2004 $40,626 Abbotsford Police Foundation BC 2005 $51,193 SPVM (Montreal) Foundation QC 2008 $2,705 Calgary Police Foundation AB 2010 $2,630,270 Police foundation Province Est. 2015 Revenue (CDN) Vancouver Police Foundation BC 1976 $8,198,426 RCMP Foundation ON 1994 $1,201,737 Edmonton Police Foundation AB 2000 $492,730 Delta Police Foundation BC 2004 $40,626 Abbotsford Police Foundation BC 2005 $51,193 SPVM (Montreal) Foundation QC 2008 $2,705 Calgary Police Foundation AB 2010 $2,630,270 View Large Establishing a police foundation is not without challenges for would-be founders and advocates. An article in the Saskatoon Star Phoenix newspaper reported in January 2016 that the provincial Saskatchewan Police Commission had terminated its policy of allowing citizens and police departments to establish police foundations. Previously, it was reported Saskatoon city Councilor Charlie Clark had discussed with the Saskatoon Board of Police Commissioners about establishing a police foundation to boost that police department’s budget. According to the Chair of Saskatchewan Police Commission, Neil Robertson, it was decided to prohibit police foundations in Saskatchewan to prevent favoritism and corruption allegations that might accompany their creation. As Robertson put it: ‘Policing isn’t a charity. It’s an essential public service’ (Tank 2016). The Winnipeg Police Service (WPS) has similarly considered creating a foundation. In 2006, Corrine Scott, a former WPS employee, wrote a graduate thesis about the need for a Winnipeg Police Foundation (Scott 2006). Not surprisingly, Scott consulted resources like the NYCP Foundation’s (2004) ‘Guidebook’ noted above. Scott considered the practical and ethical difficulties of starting a foundation for the WPS, and intended the thesis as groundwork for its creation. To date, however, a foundation for the WPS has not (yet) arisen. Police foundations in the US and Canada fund various initiatives, from purchasing equipment like bullet proof vests, to supporting technological upgrades to police facilities, to more community outreach and youth-oriented programs. Police foundations, premised on funding programs outside a police department’s regular budget may begin by funding more officer well-being, community and at-risk youth oriented programs, a trend we discerned regarding the NYCP Foundation discussed above. As foundations grow and receive more donations, however, the focus can broaden, especially as large private corporations with vested interests in police acquisition of their products, equipment or technological capacities enter the fold. The Los Angeles Police Foundation, for example, funded purchase of bomb detection X-ray equipment for the department’s counter-terrorism section in 2000, tactical microphones for the metropolitan division in 2002 and pro-laser speed devices for the Central Traffic Division in 2005, an eight week ‘boot camp’ program for at-risk youth in 2006, a Harvard survey of public satisfaction with police and other matters in Los Angeles in 2009, the Los Angeles Police Department’s (LAPD) Annual Victims Overcoming Injustice of Child Abuse and Endangerment holiday party in 2013, and 860 body-worn cameras in 2014 (Los Angeles Police Department 2017). In the donation lists of major police foundations in Vancouver, New York and Atlanta, there is a similar diversity of supported projects, initiatives and purchases. While difficult to argue that many foundation initiatives obviously commenced with a conflict of interest, or necessarily have a corrupting effect on policing, the logic and mechanisms through which police foundations operate increases opportunities for misconduct, abuse of due process and erosion of public trust. Many police foundations like the NYCP Foundation misleadingly claim they are part of an anti-corruption and pro-transparency drive in policing. The original idea for the NYCP Foundation came from Eliot Lumbard, a private New York City attorney, in the early 1970s. Lumbard presented the idea to the Police Commissioner who then embraced the idea of creating a police foundation as ‘an anti-corruption opportunity’ (Delaney et al. 2014: vi). NYPD Commissioner Patrick Murphy indicated at the time that ‘his department would apply to the new foundation [and is]…interested in minority recruitment, development of community relationships and training programs’ (Ranzal 1972). While donations to police are perhaps better managed by a legally independent foundation, these foundations do more than this. Police foundations actively solicit donations, a practice from which most police departments are prohibited (Davis 2010). They also seek to capitalize on the symbolic and professional capital and network connections of corporate actors recruited for or otherwise sitting on their boards (Butler and Delaney 2010). Thus, foundations raise questions about private influence on public police budgets and operations, especially because of the foundations’ corporate orientation which as discussed below is dissonant with claims about transparency in foundations’ originating mission statements and company histories. Private Foundations, Public Policing’s Dark Money and Transparency Deficits According to practitioner literature on police foundations, there are many benefits of having donations funneled through an arms-length non-profit organization, though many police departments continue to allow direct donations under certain circumstances. Davis (2010), in his IACP article ‘Thoughts on launching a police foundation,’ calls this the ‘formal structure’ advantage: ‘A police foundation usually stands separate from an agency or from the individuals who formed it and exists as a legal entity in its own right.’ Police foundations additionally enable police to capitalize on the expertise of hired fundraisers and connections as well as symbolic capital of corporate actors who oversee the foundation as board members. By working for a foundation, these fundraising experts solicit donations from individuals and companies. Police foundations also benefit from having a board of directors, who often connect the foundation to transnational corporations and other private foundations, and can leverage these connections to channel funds into the foundation and later to the police department. Tax exempt status of the organization and limited liability of founders, directors, members and staff are other benefits of a nonprofit police foundation (Davis 2010). Another benefit of foundations, contrary to police foundation rhetoric, is the increased secrecy these legal arrangements provide to police officials, effectively permitting transactions to happen in the dark. Many advocates claim creating a foundation allows police to accept outside monies while transparently avoiding actual or alleged corruption and conflicts of interest. As former executive vice president of the NYCP Foundation Gregg Roberts remarked: ‘We [the NYCP Foundation] were created to be a hedge against corruption… By having donations go through us, we take out any implication of impropriety’ (quoted in the Monterey Herald 2007). The NYCP Foundation’s website claims a foundation’s role is to decrease corruption: ‘The Police Foundation was established to reduce corruption and support innovative programs that the NYPD could not readily fund’ (NYCP Foundation 2017). A key aspect of achieving these purported anti-corruption goals is transparency. ‘Nonprofit foundations depend on public confidence, and transparency is a key to building that trust,’ argues the COPS Office in its guidelines for creating a police foundation (Delaney et al. 2014: 25). The importance of transparency in avoiding conflicts of interest and sustaining public trust is a theme in every practitioner publication on police foundations to date. Here we assess these transparency claims. The evidence presented below on foundation secrecy runs contrary to claims of Butler and Delaney (2010) that ‘[t]he transparency offered by foundations in financial management and the tax break for the donor make a foundation a win-win for everyone.’ In the IACP’s and Los Angeles Police Foundation’s ethical guidelines for police foundations, the importance of openness and transparency is similarly emphasized (Wagener 2010). Transparency ‘is essential to successful foundation management’ (Wagener 2010). Among other practices, the guidelines suggest foundation officials make detailed meeting minutes ‘available to anyone who wants to read them’ (Wagener 2010). Transparency can allegedly help avoid conflicts of interest that police foundations might foment: ‘While most police foundations are not required to do business in the same manner as local city, town, or village governments, and they may have different procedures or contract policies, avoiding conflicts of interest in all dealings is essential to a foundation’s success’ (Wagener 2010). In our research examining financial aspects of police donations and sponsorship (also see Lippert and Walby forthcoming; Luscombe et al. forthcoming; Grabosky 2007; Ayling et al. 2009), we encountered numerous barriers to transparency and information access. Our FOI requests to police departments about donations and sponsorship were regularly denied or severely restricted on the grounds that most donation and sponsorship records are held by police foundations that by definition are not public institutions. Intentional or not, it is undeniable that a police department benefits from this layer of obfuscation and opacity. In Canada and the United States, police foundations are typically registered as non-profit organizations. Apart from disclosure of tax returns, police foundations are exempt from public access and FOI laws that apply to public police departments they ‘partner’ with. Two examples of our efforts to gain access to foundation-related records through FOI in Canada come from Abbotsford, BC and Edmonton, Alberta. The Abbotsford Police Department denied us access to donation-related information by claiming foundation records were outside their legal purview: Abbotsford Police Department does not accept donations or sponsorships directly; however, you may contact Abbotsford Police Foundation… for information regarding any donations or sponsorships they may handle. We cannot release information belonging to Abbotsford Police Foundation as it does not belong to Abbotsford Police Department. The separation of foundation from police department is used to negate the responsibility to release records, deflecting it onto a private entity outside the scope of FOI, an unstated benefit of Davis’s (2010) ‘formal structure’ argument. As the president of this same foundation wrote to us: The Abbotsford Police Foundation… is not subject to the Freedom of Information and Protection of Privacy Act and has no legislated obligation to provide the public with access to its documents or records…. It is beyond doubt that the APD and the Foundation are separate legal entities. The Department does not ‘own’ the Foundation…. For those and a variety of other reasons, the Department does not have custody or control of any Foundation records and has no right or authority to release them. The Edmonton Police Service blocked our FOI request on similar grounds: The EPS does not have a foundation or fundraising arm. The Edmonton Police Foundation is an arms-length Foundation that fundraises to support policing activities and provides scholarships related to police education and for police recruits based on merit. Donors may provide donations to the Edmonton Police Foundation directly to specific programs or to support the aims of the Foundation in general…The Edmonton Police Service does not host or solicit any fundraising activities. Fundraising activities are hosted exclusively by the Edmonton Police Foundation. The Edmonton Police Service does receive many unsolicited donations through the course of the year generally either to a specific program or to the Service in general… Requests for Edmonton Police Foundation records must be submitted directly to their office. When we spoke with an Edmonton Police Service FOI coordinator by telephone, this staff member asked if we would be approaching the Edmonton Police Foundation for information. We replied we might but that it was difficult given the foundation is non-profit and not subject to FOI legislation. She replied bluntly: ‘that is true’. Our efforts to contact foundations directly have received varied responses, from silence, to denial (explaining donor information is confidential), to what we interpreted as hostility (asking us to cease contacting donors and the foundation). In essence, police foundations treat access to information and transparency as a problem, and prefer to adopt a trade secrecy orientation (Luscombe, Walby and Lippert forthcoming) consistent with serving as a shell under which dark money can be exchanged. Another foundation we contacted first denied us information. When we inquired directly with its ‘sponsors’, the foundation became less and less friendly toward us. We wrote to the foundation explaining our research and asked for clarity about its ‘sponsorship opportunities packages’ (we sought to determine how much money a lead sponsor had provided for a police event). The foundation’s coordinator denied politely: ‘[W]e made special arrangements to accommodate specific needs of our leadership sponsors. I am unable to release any additional information. Good luck with your analysis!’ We then rephrased our inquiry, only to receive a similar reply: ‘As per my original email, we are unable to release additional information.’ Next, we asked the sponsor how much money they had provided by leaving a telephone message. We then received a less friendly response from the foundation’s executive director: It was brought to my attention that you have been, and continue to be, inquiring with our corporate supporter… about their level of contribution… I believe… our office has been in touch with you, explaining that [the corporation’s] support was structured as a sponsorship as well as a directed donation in honour of the former Chief [of police]. The information… was intended as a reference only for potential sponsors, and was in no way affirmative of the total contribution committed by each sponsor. The Foundation…aims to make its best possible efforts to adapt the recognition options and benefits associated with a sponsorship level to the specific needs and objectives of a corporate partner. If an individual or a corporate partner wants to remain anonymous and/or do not disclose their specific contribution, we respect their wishes and privacy. (emphasis in original) We later requested an interview with this executive director but received no response. The issues raised in our efforts to access foundation records and the case of Baltimore we describe next are not isolated. In 2014, when the LAPD Commissioner began soliciting funds from Dreamworks Animation to purchase 860 body cameras from Taser International, Inc. through the foundation, news media outlets raised questions about potential conflicts of interest and corruption (Reicher 2014; Winston and Graham 2014). Previously, Taser (now called Axon) had made numerous donations to the Los Angeles Police Foundation and questions were then raised about the influence of these transactions (Winston and Graham 2014). Also in 2014, the Los Angeles Police Foundation purchased a new horse for the LAPD’s mounted unit. When news emerged the horse had been bought from the LAPD Chief’s daughter, and that the Chief had approved it, controversy again arose over the Foundation’s lack of transparency (Parker 2014). Earlier questions had emerged in 2007 when the LAPD used the Foundation to purchase controversial surveillance software, originally designed for spy agencies, from Palantir, a firm partly funded by the Central Intelligence Agency. As Winston and Graham (2014) argue: ‘The LAPD could have used a small portion of its multibillion-dollar annual budget to purchase the software, but that would have meant going through a year-long process requiring public meetings, approval from the City Council and, in some cases, competitive bidding.’ Winston and Graham (2014) raise similar questions about the NYCP Foundation’s practices and Weissenstein (2003) earlier identified a link between NYCP Foundation donations and a NYPD operational unit operating to benefit corporate donors: Without question, some contributions beef up police enforcement that benefits the donors. Among the largest contributors to the New York City Police Foundation are Coach, Major League Baseball and the Motion Picture Association of America. Their donations go directly to the police department’s six-person trademark infringement unit, which uses a roughly $200,000 Police Foundation account to fund undercover purchases of counterfeit CDs, DVDs, clothes and other goods. Police Foundation Transparency Rather than accepting that police foundations are vessels of transparency, we use literature on financial obfuscation (Rossman 2014), shell corporations (Jancsics 2016) and dark money to conceptualize how these entities enable financial and public–private relationships that would otherwise contravene laws and policies restricting donations and sponsorship (see also Fridman and Luscombe forthcoming). We contend police foundations as shell corporations broker private, corporate funds to flow to public police without violating laws or rules about direct donations. Far from dissolving the possibility of conflict of interest (Grabosky 2007) or corruption (Punch 2009), foundations may enhance this network characteristic, leading to controversies for police foundations, police services and an ‘erosion of legitimacy’ (Grabosky 2007: 5). Compared to the United States, where there are at least 251 municipal police foundations, the handful of police foundations in Canada have been subjected to less public criticism over their lack of transparency and potential for conflicts of interest. Infrequent, minor criticisms in news media can be found, but nothing like a full-fledged scandal has yet occurred in Canada. When the Calgary Police Foundation went public in 2012, a Calgary Herald newspaper article raised questions about potential special police treatment of donors as ‘insiders,’ but concluded by defending its creation (Corbella 2012). Two years after it had been established in 2010, the foundation had received $6.5 million CDN in donations from ‘big-hearted people and corporations’ (Corbella 2012) like Canadian Natural Resources Ltd, Cenovus Energy, Enbridge Inc., Encana Corporation, MEG Energy, Talisman Energy and Canadian Imperial Bank of Commerce. The article also suggested that concerns about special police treatment for donors were unreasonable given the Foundation’s focus (at the time) on supporting community programs for at-risk youth. The article concluded after discussing potential conflicts of interest the Foundation might create, stating: ‘This Calgary Police Foundation… need not be viewed with any cynicism at all. We should be grateful to all involved. The services that will help at-risk kids will undoubtedly stick with them in a positive way for their entire lives’ (Corbella 2012). In this Canadian city of one million the local police foundation and the fourth estate ride the same train, one greasing the other’s wheels as they move down a seemingly uncontroversial track. The only larger controversy over a police foundation in Canada happened in 1995 with the signing of an agreement between the RCMP Foundation and Walt Disney Co. (Canada) Ltd giving Disney licensed control over the famous ‘Mountie’ image (CBC 1995). The Mounted Police Foundation that owned these rights failed to proceed through public tendering which yielded considerable negative publicity (CBC 1995). A wealth of news articles criticized the Foundation and this deal with Disney. An article in Toronto’s major newspaper, the Globe and Mail, for example, criticized the foundation’s Disney arrangement as well as numerous other deals the Foundation had made with corporations that raised questions of impropriety. This included a sponsorship arrangement that made Canadian Pacific Ltd a ‘partner’ in its Musical Ride: ‘In exchange for undisclosed sponsorship fees, Canadian Pacific—described by an RCMP spokesman as a corporation with a history of values ‘consistent with ours’—will get signs at Musical Ride performances, mention in public-address announcements and guest passes’ (Valpy 1995). The article went as far as to call the Foundation’s board of directors ‘unreconstructed, loose-cannonball capitalists’ (Valpy 1995). As the article concludes: ‘It seems odd that a police force should be in this business’ (Valpy 1995). On the whole, however, critical media coverage of police foundations is rare in Canada. When the Mounted Police Foundation was established in 1994, no Canadian journalist covered the story, though it was reported by CNN in the United States (Valpy 1995). The growth and operations of foundations in Canada and the United States is happening largely under the news media’s radar, with little to no public opposition or probing. Yet, some recent controversies over foundation transparency in the United States are worth illuminating. They serve as exemplars of what can happen when private charitable agencies are secretly misused by police officials and rich corporate ‘philanthropists.’ Below we discuss the recent example of Baltimore. Baltimore Police foundation controversy in Baltimore began in the early 2000s when former commissioner Edward T. Norris was tried and convicted of misusing private donations held in the Department’s charity account. The funds had been donated to the police to ‘provide money for the needy’ (Donovan 2016a). The then Baltimore Police Foundation, although not directly involved with this controversy, was deeply affected by it leading to its dissolution shortly thereafter. Norris had initiated the Baltimore Police Foundation in 2000, an idea acquired from working for the NYPD (Wilber 2000). The Baltimore Police Foundation had ‘for years covered the cost of equipment and initiatives that the city’s tight budget couldn’t cover’ (Donovan 2016a). As with other police foundations, it had operated as a separate 501(c)(3) non-profit fundraising arm of the police with an executive director and board of directors. After the controversy involving Norris, ‘the integrity of the charity crumbled’ (Donovan 2016a). Norris moved to Baltimore from New York City in May 2000, where he had worked for the NYPD, and rose from deputy commissioner to commissioner of the Baltimore Police Department in several months (Kilborn 2003). In August 2002, The Baltimore Sun began reporting on Norris’s use of the charity account for expenditures not beneficial to the department (e.g. paying overtime of the commissioner’s driver) (Wilber 2003; Gibson and Wilber 2004). An independent audit paid for by the City of Baltimore identified $7,663 USD in misspent funds and deducted it from Norris’s pay. Norris then left the Baltimore Police for the Maryland State Police (Wilber 2003). Federal investigators later unraveled the extent of Norris’s spending. It was found Norris had misused upwards of $30,000 USD in charitable donations on personal gifts, private travel and accommodations, visits with girlfriends and excessive overtime hours for his six-member security protection team, among other things (Kilborn 2003; Rich 2004). Norris plead guilty and was sentenced to six months in prison in 2004 (Rich 2004). This was only the first donation-related controversy in the City of Baltimore. Despite closing the Baltimore Police Foundation, private donations continued to flow through two Baltimore Community Foundation accounts created to channel funds to the police department: the ‘Baltimore Police Endowment Fund’ and the ‘Baltimore Police Special Grants Fund’ (Fenton and Donovan 2016). Between 2011 and 2013, Baltimore Police, through the Baltimore Community Foundation, had received roughly $900,000 USD in donations. In 2011, for example, Under Armour donated $300,000 USD for computers, Tasers and other items. Other major corporations known to have donated to the police through this Foundation include Wal-Mart and Target (Fenton and Donovan 2016). Houston billionaire philanthropists, John and Laura Arnold made a more controversial donation in 2015. In true domestic shell corporation fashion, the donation to the Baltimore Police Special Grants Fund was not publicly advertised by the Baltimore Community Foundation (Fenton and Donovan 2016). In November 2015, the Arnolds donated $120,000 USD to this Foundation’s police fund for an aerial surveillance program, conducted by Persistent Surveillance Systems, working with the Baltimore Police Department. John Arnold, after learning about aerial surveillance technologies, contacted Ross McNutt, owner of Persistent Surveillance Systems and expressed interest in developing the company’s services (Dart 2016). McNutt, who had created the surveillance program while in the US Air Force, had been actively approaching police departments in the US since 2012 to secure a contract (Reel 2016). The Arnolds promised to pay for the aerial technology if McNutt could find a police department to partner with (Donovan 2016a, 2016b). McNutt contacted the Baltimore Police Department discovered through a trade-show where he was featuring his company’s services (Reel 2016). During 2016, the plane logged 314 hours of flight time and collected over one million images (Dart 2016). McNutt and his analysts used the aerial footage to help police investigate numerous crimes for six months, though his aid and the program were never publicized (Reel 2016). In April 2016, the Arnolds contacted the Baltimore Community Foundation seeking to donate an additional $240,000 USD to review the program’s effectiveness in reducing crime. After this Foundation declined the funding, claiming it lacked resources to conduct the review, the Arnolds contacted the ‘Police Foundation’ in Washington, DC, a national-level foundation not tied to any one police department, which agreed to accept the donation to review the program (Donovan 2016a). Until Bloomberg Businessweek (Reel 2016) published an article revealing the program in August, neither City Council nor Baltimore’s residents knew about it. There had been no public bidding process, City approval or press statement by police, the Baltimore Community Foundation, Persistent Surveillance Systems or the Arnolds. The use of the aerial surveillance footage was not mentioned by the Baltimore Police either (Reel 2016). When McNutt’s activities with the Baltimore Police Department were exposed in August 2016, controversy broke out over the program (Broadwater and Donovan 2016; Rector and Broadwater 2016). To date, it is unclear whether the Baltimore Police Department will continue the program. Discussion and Conclusion Police foundation staff claim foundations promote transparency and prevent corruption. The NYCP Foundation tells its own history this way: in the early 1970s, when the NYPD was undergoing extensive criticism and reform to deal with systemic, long-standing corruption (the time of the Knapp Commission, which had issued a scathing interim report on July 1, 1971 (New York 1973: 273–276), the foundation emerged as one remedy. A more critical interpretation is that police foundations and the cryptic exchanges they facilitate increase potential risks of corruption and conflict of interest. The work of foundations could even be likened to an organizational form of ‘noble cause corruption’ (Punch 2000: 305) in that they sometimes seemingly encourage ‘illicit means for organizationally and socially approved ends…it is not done for gain but to lubricate the machinery of criminal justice’. Relatedly, Gray (2013: 533) uses the idea of ‘institutional corruption’ to refer to ‘influences that implicitly or purposively serve to distort the independence of a professional in a position of trust’. These efforts are consistent too with the white-collar crime literature that examines the mechanics and opportunity structures that produce white-collar crime (Benson et al. 2009). Shapiro (1990: 346), for example, has called for criminologists of white-collar crime to explore how institutional norms of trust are established and exploited. To help enrich literature on private sponsorship of policing and private influence on public police (Grabosky 2007; Ayling et al. 2009), which has usefully examined the coercive, market and gift-like dimensions of such exchanges, we have used the ideas of shell corporations (Jancsics 2016) and dark money (Mayer 2016) to conceptualize this potential for conflict of interest that police foundations create. We have deployed these notions to illustrate how these organizations mask or buffer disreputable exchanges (Rossman 2014) created by corporate donations to police and that may erode legitimacy or distort the impartial character of police. While undoubtedly these transfers often involve ‘commerce masquerading as gift’ (Ayling et al. 2009: 230) insofar as some donors stand to benefit during later police procurement, the shell corporation and dark money terminology places more emphasis on the surreptitious and corporate nature of these transactions. Police foundations represent a corporate approach to police sponsorship and therefore exemplify criminal justice corporatization (also see Lippert and Walby forthcoming; Luscombe et al. forthcoming; O’Malley and Hutchinson 2007). Police and police foundation officials are aware of the risks of accepting donations from external private sources, even when channeled through an independent foundation. As the IACP’s ethical guidelines on police foundations state: ‘Do not create a perception of entitlement for donors regarding access to department services or the possibility of preferential treatment’ (Wagener 2010). Scott (2006), in her work on creating a Winnipeg Police Foundation, also acknowledged this ‘potential risk’: ‘The perception that affluent donors may gain considerable influence because of their support to the foundation’ (Scott 2006: 61; also see Grabosky 2007). Her solution was for Winnipeg Police Service leadership to ‘mitigate this risk as much as possible’ (Scott 2006: 61–62). For this reason, Walters (2004) argues police foundations should be subject to ethical guidelines and standards. Without validating the notion of transparency given its almost mythical status (Christensen and Cornelissen 2015), and without suggesting other public police issues will disappear if police simply operated more openly, police foundations can minimize the potential for corruption by operating with a higher degree of transparency than presently. IACP best practices and police practitioner rhetoric are quick to encourage transparency in police foundation management. But in practice police foundations are not operating with a high level of transparency. A high degree of openness and transparency are vital given the high stakes and potential for conflict of interest and corruption. Failure of police foundations to garner and secure public trust can result not only in their dissolution but can also create collateral damage to the reputation and trust of a police department too given their close connection. A practical solution to help enact a commitment to transparency for foundations would be to bring them under FOI or sunshine law. Yet reforming FOI law to include police foundation records would be no easy feat and would not necessarily ensure access to relevant records. In Canada, we made numerous appeals to provincial information and privacy commissioners about the transparency problems posed by police foundations but to no avail. There is a precedent in several US states that expose foundations where dark money is exchanged to the sunshine of FOI laws. The Sunshine Law in Florida refers to cases in which private entities such as foundations should be subject to FOI. However, in one case those creating the foundation in question lobbied a City Commission to exempt Sarasota Police Foundation Inc. from the state’s Sunshine Law (Cummings 2014). This decision provides another example of police foundations’ opacity. Decisions such as this and like efforts to bring police foundations under FOI law will have a significant impact on whether the advent of police foundations marks the beginning of a future when private, corporate monies and influence will be transacted under grander shell corporations in the dark and therein be able to reach deeper into public police operations and mandates. Funding This work was supported by a Social Sciences and Humanities Research Council of Canada (SSHRC) Insight Grant, award number 435-2015-0223. References Ayling , J. P. , Grabosky , P. and Shearing , C . ( 2009 ), Lengthening the Arm of the Law: Enhancing Police Resources in the 21st Century . Cambridge University Press . Benson , M. , Madensen , T. and Eck , J . 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Open Source Geospatial Foundation Project. http://www.qgis.org/. 3 One source of emulation was the Washington, DC-based American Police Foundation noted later in this paper (Vancouver 1978). 4 These articles, which since have been removed from the IACP’s website, can be accessed by copying the URLs in the bibliographic entries into the internet database’s ‘Wayback Machine’. https://archive.org/web/. 5 We did not identify foundations in the states of ME, ID, VT, WV, NM, AR or AK. 6 In contrast to revenue, income is prior to subtraction of foundation costs or expenses. We use revenue below in our discussion of Canadian foundations as this was the only statistic available from Canada Revenue Agency’s charity database. 7 https://www.irs.gov/charities-non-profits/exempt-organizations-business-master-file-extract-eo-bmf 8 http://www.cra-arc.gc.ca/ebci/haip/srch/basicsearchresult- eng.action?k=police&s=registered&p=1&b=true. 9 Although federal in orientation, we include the RCMP Foundation in our analysis since the RCMP includes numerous municipal detachments in, e.g. BC, AB, SK, NB and NL. © The Author(s) 2017. Published by Oxford University Press on behalf of the Centre for Crime and Justice Studies (ISTD). All rights reserved. For permissions, please e-mail: [email protected] This article is published and distributed under the terms of the Oxford University Press, Standard Journals Publication Model (https://academic.oup.com/journals/pages/about_us/legal/notices) http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png The British Journal of Criminology Oxford University Press

The Police Foundation’s Rise: Implications of Public Policing’s Dark Money

Walby, Kevin; Lippert, Randy K; Luscombe, Alex
The British Journal of Criminology , Volume Advance Article (4) – Sep 15, 2017
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Oxford University Press
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© The Author(s) 2017. Published by Oxford University Press on behalf of the Centre for Crime and Justice Studies (ISTD). All rights reserved. For permissions, please e-mail: [email protected]
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Abstract

Abstract A new kind of organization has emerged in public policing across the United States and Canada: the ‘police foundation’. The foundation’s private, nonprofit legal status allows it to engage in private fundraising activities that police, as public bodies, cannot. In many municipalities, police foundations raise funds directed toward police procurement practices and operations. We discuss reasons for and detail the rise and growth of these foundations as they have modeled the New York Police Department’s Foundation and changes in that foundations’ expenditures over time, and examine the key claim that police foundations reduce corruption by maximizing transparency. We draw from literature on financial obfuscation and explore controversies centered on police foundation solicitation and use of private funds in North America. Conceptualizing these private entities as shell corporations that permit transactions in dark money, we raise questions about police foundation transparency. We conclude by discussing the implications for public policy as well as police transparency across North America. Police foundations are a new phenomenon in the United States (US) and Canada. Their number and impact are growing rapidly. As a prominent police foundation advocate writes: ‘a new paradigm is emerging in the face of today’s economic challenges, in which police leaders are leveraging private resources to fill budget gaps’ (Delaney 2010). One way police organizations are accomplishing this leverage is through establishing municipal police foundations. These foundations operate as private, nonprofit charities that amass monies mostly from the private corporate sphere. Funds are raised through private events (e.g. galas), advertising, direct solicitation and other strategies typical of the nonprofit sector. Without a foundation, police departments can accept donations from private entities, but risk undermining the department’s integrity or breaking conflict of interest policies. Police policies that aim to prevent bribery, collusion, corruption and conflict of interest often deter acceptance of donations directly from private entities. However, no similar rules and laws exist for police foundations, which ‘are uniquely positioned to serve as vehicles for donations from private sources, while helping to safeguard the integrity of police departments’ (Delaney 2010). Though some monies raised by foundations are channeled toward other charities, much is transferred to police departments for procurement of new equipment and technologies, to outfit units, or fund new initiatives. The flows of capital are currently small compared to overall public police budgets, which in North America are derived from tax revenues, yet there are questions about the ethics and practical issues raised by these opaque ‘vehicles for donations’ in public policing. Little research has examined the emergence and growth of police foundations, their effects on transparency, or their implications for corruption and conflict of interest that result from this brokering between public police and the corporate world. The fact that police foundation staff promote foundations as enhancing transparency and preventing ‘institutional corruption’ (Gray 2013) rather than the opposite is the central theme of this paper. Literature on public police and transparency takes two forms. First, there is research that investigates how police manage media relations to appear transparent (e.g. Mawby 1999). This includes literature on new media and police transparency (e.g. Goldsmith 2010) that explores how public police respond to social media and smart technology visibilities of police work that erode police authority and their capacity to shape news and legal narratives. Second, literature on corruption and police implicitly focuses on transparency (e.g. Dean et al. 2010). Criminology and criminal justice studies have not accounted for the challenges to transparency created by private foundation involvement in public police finances. Examining police foundation establishment and practices, we contribute to the literature on criminal justice and transparency (Hood 2006; Fenster 2006) and to what may soon be a growing literature on the phenomenon of police foundations. To interpret the establishment and practices of police foundations in North America, and to enrich literature on private sponsorship of policing and private influence on public police (Coleman 2004; Lippert and Walby forthcoming; Luscombe et al. forthcoming; Crawford 2006; Ayling et al. 2009), we draw from literature on financial obfuscation and domestic shell corporations. Sponsorship of police through foundations differs from direct sponsorship explored in existing literature in key ways. Foundations protect public police from accusations of receiving taboo private monies from corporations, and in this sense the foundation obfuscates or renders opaque a disreputable exchange (Rossman 2014) that would otherwise be unethical and illegal. Whereas reputable exchanges maintain the boundary between sacred and profane, where profane is understood as something culturally and institutionally ‘set apart’ (Rossman 2014: 44), disreputable transactions involve taboo exchanges of sacred for profane goods or services, like a gift or bribe (profane) exchanged for publicly funded services (sacred) (Fridman and Luscombe forthcoming; Grabosky 2007). Under these circumstances, the former are perhaps best termed ‘dark money’ (Mayer 2016). Rossman (2014) discusses three strategies of financial obfuscation: bundling, brokerage and gift exchange. The second, brokerage, involves two parties sequentially and indirectly exchanging sacred for profane goods through an intermediary broker. Foundation staff can thus engage in brokering that public police cannot. Jancsics (2016) refers to such brokerage organizations as ‘domestic shell corporations’, which enable public-private financial relationships that would otherwise be deemed undemocratic and contrary to the public interest. Foundations can become ‘cash cows’ (Jancsics and Javor 2012; Jancsics 2015) for public police by amassing and circulating corporate revenues that might otherwise be deemed illegitimate. Despite these concerns, the rising phenomenon of police foundations has not yet been a focus in literature on private sponsorship of and influence on public policing (Grabosky 2007; Ayling et al. 2009). We argue police foundations facilitate a corporate approach to police funding representing an emerging exemplar of corporatization (Lippert and Walby forthcoming; Luscombe et al. forthcoming; O’Malley and Hutchinson 2007) of criminal justice. Conceptualizing police foundations this way allows inquiry to move beyond the claim that police foundations promote transparency, shifting attention to empirical questions about how these organizations emerge, the relations and capital they conceal and what might check or at least partly resolve the deepening of this private influence on public policing. We begin the article by describing our methodological choices and some challenges encountered in studying police foundations. Second, we provide a history and explanation for the police foundation’s rise in North America including the relationship with neoliberalism. Third, we assess advocates’ claims about police foundations and their transparency. We conclude by discussing implications for public policy and literature on police transparency and accountability. Data and Method We examine municipal police foundations and exclude from our sample police sports, pipe band, memorial, canine, police history/museum, officer scholarship and award, reserve and police youth foundations. In contrast to police foundations’ broad mandates and funding capabilities, these other foundations focus their funding and only rarely if ever contribute to police procurement or operational support, which is our core concern. We also exclude from our sample US state- and national-level foundations (e.g. American Police Foundation, Illinois Association of Chiefs of Police Foundation), though these should be examined in future research. We draw from several data sources on the establishment of police foundations in the United States and Canada. Secondary data sources were primarily used due to the relatively cagey nature of police foundation operations and communications. We analyzed news articles (generated through NewsBank, Lexis Nexis and Canadian Newsstream); websites of United States and Canadian police foundations; International Association of Chiefs of Police (IACP) publications; almost two decades (1987–2005)1 of the New York City Police Foundation’s annual print journal and its ‘Starting a Police Foundation’ manual; data from GuideStar’s National Database of Charitable Organizations, the National Center for Charitable Statistics database and the Charitable Listing database of the Canada Revenue Agency; US and Canadian tax reporting forms; and City Archives in Seattle, Washington and Vancouver and Delta, British Columbia. We also collected primary data using freedom of information (FOI) requests in the United States and Canada and through interviews with foundation officials and corporate donors. While we were generally unsuccessful with FOI requests for donation, sponsorship and police foundation related data from public police agencies, responses from police departments explaining why we could not access foundation information evince barriers to transparency that we reflect on. We analyzed these data using an ‘abductive’ approach to grounded theory (Tavory and Timmermans 2014). To generate descriptive statistics on and to visualize geographic trends in police foundation establishment across North America, we used Microsoft Excel and QGIS software.2 The Police Foundation’s Rise The first major police foundation in North America was created in New York City in 1971. Two small foundations preceded it in 1966 (Manchester Police Foundation, New Hampshire) and 1968 (Glendale Police Foundation, CA), but did not achieve the international standing of the New York City Police Foundation (NYCP Foundation) which is frequently touted as the first police foundation in North America. According to the foundation’s history, it was created during a time of transition when the NYPD, undergoing corruption investigations, was reformed into a ‘modern’ police force (NYCP Foundation 2017a). In 1971, the foundation was ‘established to reduce corruption and support innovative programs that the NYPD could not readily fund’ (ibid.). The foundation in these early stages granted scholarships to officers, donated horses to the NYPD’s Mounted Unit and provided the first bullet proof vests to the department. During the 1980s and 1990s, the foundation broadened its responsibilities, taking over the Crime Stoppers reward program in the mid-1980s and became increasingly involved in helping the NYPD with training, equipment provision, technology upgrades and community outreach. According to the foundation’s former executive director, Projects initiated or concluded in 1986 include the enhancement of SPECDA [the School Program to Educate and Control Drug Abuse], an opinion survey of the public and the police, the creation of a pilot cardiovascular health program [for officers], and an expansion of a training program of the newly inaugurated police cadet corps (Delaney 1987: 7). None of these could be deemed operational. But in the 1990s, the character of the programs and initiatives reveals a qualitative shift. In this decade, the foundation acquired the first CompStat system and donated it to the NYPD. After the events of 9/11, ‘a clear role for the Police Foundation emerged: modernizing the NYPD to meet the challenges of policing a post 9/11 New York City’ (ibid.). The NYCP Foundation went on to support upgrades to the NYPD’s surveillance and technological infrastructure and supported NYPD’s counterterrorism initiatives. Due to Foundation funding, the NYPD ‘posted detectives overseas, taught others exotic languages and acquired a mobile lab to detect chemical or biological attacks’ (Wiessenstein 2003). More recently, the NYCP Foundation helped fund the NYPD’s Real Time Crime Center that opened in 2005 (NYCP Foundation 2017b). As the history section NYCP Foundation’s website concludes, ‘As we look to the future, we are more committed than ever to supporting new strategies and enhancing technical capacities. The foundation will continue to uphold the NYPD’s reputation as the paragon for 21st century law enforcement’ (ibid.). The police foundation’s rise corresponds with a concomitant ascendency of neo-liberal reforms. As White and Gill (2013) write, ‘it is undeniable that the policing sector has been ever more penetrated by market rationalities over the past couple of decades’ (p. 89–90). They note that ‘neo-liberal reforms’, which often emerge with cuts to public services, led to changes in police agencies, including ‘the sale of police services in the marketplace on a ‘user-pays’ basis’ (Lippert and Walby 2013; Lippert and Walby 2014: 79). But besides cuts to municipal police department budgets in many North American and other jurisdictions commencing in the 1980s consistent with neo-liberalism’s rise and its attendant downsizing and embrace of free market solutions in North America, there are two key sources of police foundation growth and ‘isomorphism’ (DiMaggio and Powell 1983) in North America. The first is foundation-specific entities such as the NYCP Foundation and the National Police Foundation Network and broader police networks such as the International Association of Chiefs of Police.3 Since its establishment in 1971, the NYCP Foundation has furthered establishment of police foundations elsewhere. It was not until the late 1990s that most US cities became interested in police foundations (Figure 2), and many looked to the NYCP Foundation as a model. In the five years preceding 2003, partially as a consequence of this Foundation’s seminars, ‘at least 10 foundations were launched in cities nationwide’ including Oakland, Atlanta, Detroit, Omaha and Portland (Weissenstein 2003). In 2004, the NYCP Foundation published its ‘Starting a Police Foundation Guidebook’, a lengthy step-by-step manual about how to create a police foundation, and began distributing these free of charge upon request. In 2013, Pamela Delaney, who had served as the president of the NYCP Foundation from 1983–2009 that followed extensive experience with the NYPD, started the National Police Foundation Network (NPFN). Through the NPFN, Delaney uses her NYCP Foundation experience to encourage the spread of municipal police foundations throughout the United States. On the NPFN’s website, one finds a growing body of resources on police foundation best practices, strategies and notices of workshop, training and networking opportunities for police, foundation officials or anyone interested in starting a foundation. Second, federal agencies and professional associations such as the International Association of Chiefs of Police (IACP) have spearheaded police foundation expansion. The IACP has a ‘Police Foundations Section’ whose mission is ‘to promote networking and the exchange of ideas and best practices among executives and police foundation professionals’ (IACP 2017). The IACP accordingly hosts meetings and conferences for police foundation professionals, police officials and business executives; conducts research on police foundation practices and ethics, and encourages ‘discussion for the establishment of standards and best practices for police foundations’ (IACP 2017). In 2010, the IACP’s in-house publication, The Police Chief, featured several articles on police foundations (Delaney 2007; Davis 2010; Butler and Delaney 2010).4 The US Department of Justice’s Office of Community Oriented Policing Services (COPS) has also actively promoted police foundation creation across the United States. In September 2010, the COPS office joined with the Target Corporation to launch the National Police Foundations Project, providing ‘training workshops and technical assistance to communities to sustain community policing crime reduction and crime prevention efforts by establishing or expanding existing police foundations’ (Delaney 2011). Foundations emerged in larger cities like New York and Los Angeles. Soon smaller jurisdictions followed. As the Chief of the Ottawa Police Department in Kansas and a founding member of the Ottawa Police Foundation wrote with a colleague: ‘In the past, many chief executives felt that a police foundation was only for big cities like Los Angeles and Atlanta’ (Butler and Delaney 2010). Foundations are now established in cities as small as Los Gatos, CA, Amherst, NY, as well as Ottawa, KS. Using GuideStar’s National Database of Charitable Organizations and data from the National Center for Charitable Statistics (NCCS) in the United States, we were able to identify 251 police foundations in 43 states plus Washington, DC.5 The largest number of US police foundations was established between 2014 and 2016 (37.2 per cent or 89 foundations) (Figure 2). To date, most foundations have been established in California (17.9 per cent or 45 foundations), with Virginia (7.2 per cent or 18 foundations) and Florida (7.2 per cent or 18 foundations) tied for a distant second (Figure 1). Note that across the United States there were cuts to public funding of police linked to the 2008 financial crisis. While the trend of foundation growth commenced much earlier (Figure 2), 2009 marks the beginning of its acceleration to new heights. We contend that police foundation growth has emerged in lockstep with cuts to public police funding noted earlier, the latter of which have been neither as deep nor as wide in Canada where public funding of police has been more stable than in the United States. This is reflected in, for example, much higher municipal public police officer salaries in Canada (AMO 2015: 13). Fig. 1 View largeDownload slide US and Canada police foundations by state/province, by total number of police foundations, excluding Alaska and Canadian Territories. Fig. 1 View largeDownload slide US and Canada police foundations by state/province, by total number of police foundations, excluding Alaska and Canadian Territories. Fig. 2 View largeDownload slide Number of US Police Foundations by Year, dates mark the year the foundation was granted 501(c)3 status by the IRS. Fig. 2 View largeDownload slide Number of US Police Foundations by Year, dates mark the year the foundation was granted 501(c)3 status by the IRS. For these 251 police foundations, we also examined organizational income data.6 The GuideStar database on US charities collects data on income and assets from the IRS’s Exempt Organizations Business Master File (EOBMF).7 We identified 237 of the 251 police foundations using the GuideStar database. The remaining 14 we identified using the NCCS’s database and then manually collected information on income from the EOBMF. EOBMF income data, based on 2015 Form 990s, shows most police foundations we identified, despite being structurally modeled after larger foundations like the NYCP Foundation, were not yet receiving high levels of private and/or corporate donations. Of the 251 total foundations we located in the US, 27.1 per cent (68 foundations) had a reported income of > $100,000 USD, what we used as our threshold for an active and lucrative foundation, 28.3 per cent (71 foundations) reported < $100,000 USD in income and 44.6 per cent (112 foundations) reported an income of zero. Of 112 foundations reporting zero income, 53 per cent were relatively new, established between 2014 and 2016. Finally, of 251 foundations, 4.3 per cent (11 foundations) reported incomes of > $1,000,000 USD, with the NYCP Foundation reporting $19.9 million USD in 2015 (Table 1). Table 1 US police foundations with > $1,000,000 USD in reported income in 2015 Police foundation Income (revenue) Year Est. New York City Police Foundation $19,936,333 ($7,936,387) 1971 Atlanta Police Foundation $7,129,001 2003 Los Angeles Police Foundation $4,970,392 1998 Saint Paul Police Foundation $3,463,874 2005 Palm Beach Police Foundation $2,512,212 2006 Houston Police Foundation $2,372,057 2004 New Orleans Police and Justice Foundation $2,042,613 1996 St Louis Police Foundation $1,556,317 2007 Boston Police Foundation $1,463,147 1994 Detroit Public Safety Foundation $1,312,485 2003 Seattle Police Foundation $1,157,513 2002 Police foundation Income (revenue) Year Est. New York City Police Foundation $19,936,333 ($7,936,387) 1971 Atlanta Police Foundation $7,129,001 2003 Los Angeles Police Foundation $4,970,392 1998 Saint Paul Police Foundation $3,463,874 2005 Palm Beach Police Foundation $2,512,212 2006 Houston Police Foundation $2,372,057 2004 New Orleans Police and Justice Foundation $2,042,613 1996 St Louis Police Foundation $1,556,317 2007 Boston Police Foundation $1,463,147 1994 Detroit Public Safety Foundation $1,312,485 2003 Seattle Police Foundation $1,157,513 2002 View Large Table 1 US police foundations with > $1,000,000 USD in reported income in 2015 Police foundation Income (revenue) Year Est. New York City Police Foundation $19,936,333 ($7,936,387) 1971 Atlanta Police Foundation $7,129,001 2003 Los Angeles Police Foundation $4,970,392 1998 Saint Paul Police Foundation $3,463,874 2005 Palm Beach Police Foundation $2,512,212 2006 Houston Police Foundation $2,372,057 2004 New Orleans Police and Justice Foundation $2,042,613 1996 St Louis Police Foundation $1,556,317 2007 Boston Police Foundation $1,463,147 1994 Detroit Public Safety Foundation $1,312,485 2003 Seattle Police Foundation $1,157,513 2002 Police foundation Income (revenue) Year Est. New York City Police Foundation $19,936,333 ($7,936,387) 1971 Atlanta Police Foundation $7,129,001 2003 Los Angeles Police Foundation $4,970,392 1998 Saint Paul Police Foundation $3,463,874 2005 Palm Beach Police Foundation $2,512,212 2006 Houston Police Foundation $2,372,057 2004 New Orleans Police and Justice Foundation $2,042,613 1996 St Louis Police Foundation $1,556,317 2007 Boston Police Foundation $1,463,147 1994 Detroit Public Safety Foundation $1,312,485 2003 Seattle Police Foundation $1,157,513 2002 View Large To lend further insight into how the NYCP Foundation arrived at this extraordinary amount, we analyzed data reported in its exclusive annual print journal (1987–2005). This journal with evocatively themed volumes (e.g. ‘Honor’ (1987), ‘Partners’ (1989), ‘True Blue’ (1990), ‘Commitment’ (1991) and ‘Pride’ (1993)) is primarily a corporate advertising venue comprising revenue-generating ads by transnational corporations such as Budweiser, Revlon, Smith and Wesson and Philip Morris (mostly claiming to ‘salute’ the NYPD), as well as more locally-named but iconic firms like the New York Yankees Baseball Club. Even the Trump Organization in a 1987 full page ad gave ‘their deep appreciation to New York’s Finest’ unbeknownst that 30 years later the NYPD would be spending considerable resources ($308,000 USD daily) providing protection for Trump Tower and its occupants from regular street protests in Manhattan (Reuters 2017). These advertisement based sponsorships grew over time. The 1990 volume of the NYCP Foundation’s journal displays ads from 60 major corporations, the 2001 volume has 84 and the 2016 volume (available only on NYPF website) lists 96. As well, by the 1990s the NYCP Foundation had commenced—mimicking practices well established in the larger charitable fundraising world—publication in this journal of a donor hierarchy of Major 3 Star Donors ($75k and over US), 2 star ($25–75k US), 1 Star ($10–25k), Gold Shields ($10–5k US) and Silver Shields ($1–5k US), with each year the number of donors in the three-Star category steadily increasing after 1992. In 1997, a new four star donor level appears ($100k to 1 million US and over), later called ‘platinum,’ that includes 10 corporations and corporate foundations. In 2011–2012 fiscal year, the last year this information was reported, there are 14 platinum donors of $100k or more (followed by numerous listed gold, silver, bronze, benefactors and donors). This hierarchical system of incentivizing donor rewards (i.e. stars, shields, precious metals) has been emulated by other police foundations throughout the United States and Canada (e.g. Vancouver 2017). In Canada, there are fewer police foundations (see Table 2), but more are being established. Using the online Charities Listing database of Canada Revenue Agency,8 we identified seven Canadian municipal police foundations: Abbotsford, Calgary, Delta, Edmonton, Vancouver, RCMP Foundation (formerly Mounted Police Foundation) and the Fondation du service de la ville de Montreal (SPVM Foundation). In 1976, the Vancouver Police Foundation became the first foundation in Canada only 5 years after the NYCP Foundation. The Vancouver Foundation began modestly, receiving only about $20,000 CDN from donors in its first months (Vancouver 1976), but since has undergone exponential growth in private funds. Between 2011 and 2013, the Vancouver Police Foundation reported about $1,000,000 CDN in annual revenues, over $3,000,000 CDN in 2014, and roughly $8,200,000 CDN in 2015. The next foundation established after Vancouver was the national RCMP Police Foundation (1994),9 followed by foundations in Edmonton (2000), Delta (2004), Abbotsford (2005), Montreal (2008) and Calgary (2010). The province of BC has seen the most (3) police foundations emerge (Table 2). Other municipal and provincial police forces in Canada are planning to establish foundations. At a recent police conference attended by one of us, two impromptu discussions among participants broke out about the merits of police foundations. The exuberance for establishing foundations was palpable. The feeling was summed up by a former Chief Constable of the Vancouver Police Department (VPD) on the foundation website: ‘When the public needs help, they call the police. When the VPD needs help, they call the Vancouver Police Foundation.’ Table 2 Canadian police foundations with reported revenue in 2015 Police foundation Province Est. 2015 Revenue (CDN) Vancouver Police Foundation BC 1976 $8,198,426 RCMP Foundation ON 1994 $1,201,737 Edmonton Police Foundation AB 2000 $492,730 Delta Police Foundation BC 2004 $40,626 Abbotsford Police Foundation BC 2005 $51,193 SPVM (Montreal) Foundation QC 2008 $2,705 Calgary Police Foundation AB 2010 $2,630,270 Police foundation Province Est. 2015 Revenue (CDN) Vancouver Police Foundation BC 1976 $8,198,426 RCMP Foundation ON 1994 $1,201,737 Edmonton Police Foundation AB 2000 $492,730 Delta Police Foundation BC 2004 $40,626 Abbotsford Police Foundation BC 2005 $51,193 SPVM (Montreal) Foundation QC 2008 $2,705 Calgary Police Foundation AB 2010 $2,630,270 View Large Table 2 Canadian police foundations with reported revenue in 2015 Police foundation Province Est. 2015 Revenue (CDN) Vancouver Police Foundation BC 1976 $8,198,426 RCMP Foundation ON 1994 $1,201,737 Edmonton Police Foundation AB 2000 $492,730 Delta Police Foundation BC 2004 $40,626 Abbotsford Police Foundation BC 2005 $51,193 SPVM (Montreal) Foundation QC 2008 $2,705 Calgary Police Foundation AB 2010 $2,630,270 Police foundation Province Est. 2015 Revenue (CDN) Vancouver Police Foundation BC 1976 $8,198,426 RCMP Foundation ON 1994 $1,201,737 Edmonton Police Foundation AB 2000 $492,730 Delta Police Foundation BC 2004 $40,626 Abbotsford Police Foundation BC 2005 $51,193 SPVM (Montreal) Foundation QC 2008 $2,705 Calgary Police Foundation AB 2010 $2,630,270 View Large Establishing a police foundation is not without challenges for would-be founders and advocates. An article in the Saskatoon Star Phoenix newspaper reported in January 2016 that the provincial Saskatchewan Police Commission had terminated its policy of allowing citizens and police departments to establish police foundations. Previously, it was reported Saskatoon city Councilor Charlie Clark had discussed with the Saskatoon Board of Police Commissioners about establishing a police foundation to boost that police department’s budget. According to the Chair of Saskatchewan Police Commission, Neil Robertson, it was decided to prohibit police foundations in Saskatchewan to prevent favoritism and corruption allegations that might accompany their creation. As Robertson put it: ‘Policing isn’t a charity. It’s an essential public service’ (Tank 2016). The Winnipeg Police Service (WPS) has similarly considered creating a foundation. In 2006, Corrine Scott, a former WPS employee, wrote a graduate thesis about the need for a Winnipeg Police Foundation (Scott 2006). Not surprisingly, Scott consulted resources like the NYCP Foundation’s (2004) ‘Guidebook’ noted above. Scott considered the practical and ethical difficulties of starting a foundation for the WPS, and intended the thesis as groundwork for its creation. To date, however, a foundation for the WPS has not (yet) arisen. Police foundations in the US and Canada fund various initiatives, from purchasing equipment like bullet proof vests, to supporting technological upgrades to police facilities, to more community outreach and youth-oriented programs. Police foundations, premised on funding programs outside a police department’s regular budget may begin by funding more officer well-being, community and at-risk youth oriented programs, a trend we discerned regarding the NYCP Foundation discussed above. As foundations grow and receive more donations, however, the focus can broaden, especially as large private corporations with vested interests in police acquisition of their products, equipment or technological capacities enter the fold. The Los Angeles Police Foundation, for example, funded purchase of bomb detection X-ray equipment for the department’s counter-terrorism section in 2000, tactical microphones for the metropolitan division in 2002 and pro-laser speed devices for the Central Traffic Division in 2005, an eight week ‘boot camp’ program for at-risk youth in 2006, a Harvard survey of public satisfaction with police and other matters in Los Angeles in 2009, the Los Angeles Police Department’s (LAPD) Annual Victims Overcoming Injustice of Child Abuse and Endangerment holiday party in 2013, and 860 body-worn cameras in 2014 (Los Angeles Police Department 2017). In the donation lists of major police foundations in Vancouver, New York and Atlanta, there is a similar diversity of supported projects, initiatives and purchases. While difficult to argue that many foundation initiatives obviously commenced with a conflict of interest, or necessarily have a corrupting effect on policing, the logic and mechanisms through which police foundations operate increases opportunities for misconduct, abuse of due process and erosion of public trust. Many police foundations like the NYCP Foundation misleadingly claim they are part of an anti-corruption and pro-transparency drive in policing. The original idea for the NYCP Foundation came from Eliot Lumbard, a private New York City attorney, in the early 1970s. Lumbard presented the idea to the Police Commissioner who then embraced the idea of creating a police foundation as ‘an anti-corruption opportunity’ (Delaney et al. 2014: vi). NYPD Commissioner Patrick Murphy indicated at the time that ‘his department would apply to the new foundation [and is]…interested in minority recruitment, development of community relationships and training programs’ (Ranzal 1972). While donations to police are perhaps better managed by a legally independent foundation, these foundations do more than this. Police foundations actively solicit donations, a practice from which most police departments are prohibited (Davis 2010). They also seek to capitalize on the symbolic and professional capital and network connections of corporate actors recruited for or otherwise sitting on their boards (Butler and Delaney 2010). Thus, foundations raise questions about private influence on public police budgets and operations, especially because of the foundations’ corporate orientation which as discussed below is dissonant with claims about transparency in foundations’ originating mission statements and company histories. Private Foundations, Public Policing’s Dark Money and Transparency Deficits According to practitioner literature on police foundations, there are many benefits of having donations funneled through an arms-length non-profit organization, though many police departments continue to allow direct donations under certain circumstances. Davis (2010), in his IACP article ‘Thoughts on launching a police foundation,’ calls this the ‘formal structure’ advantage: ‘A police foundation usually stands separate from an agency or from the individuals who formed it and exists as a legal entity in its own right.’ Police foundations additionally enable police to capitalize on the expertise of hired fundraisers and connections as well as symbolic capital of corporate actors who oversee the foundation as board members. By working for a foundation, these fundraising experts solicit donations from individuals and companies. Police foundations also benefit from having a board of directors, who often connect the foundation to transnational corporations and other private foundations, and can leverage these connections to channel funds into the foundation and later to the police department. Tax exempt status of the organization and limited liability of founders, directors, members and staff are other benefits of a nonprofit police foundation (Davis 2010). Another benefit of foundations, contrary to police foundation rhetoric, is the increased secrecy these legal arrangements provide to police officials, effectively permitting transactions to happen in the dark. Many advocates claim creating a foundation allows police to accept outside monies while transparently avoiding actual or alleged corruption and conflicts of interest. As former executive vice president of the NYCP Foundation Gregg Roberts remarked: ‘We [the NYCP Foundation] were created to be a hedge against corruption… By having donations go through us, we take out any implication of impropriety’ (quoted in the Monterey Herald 2007). The NYCP Foundation’s website claims a foundation’s role is to decrease corruption: ‘The Police Foundation was established to reduce corruption and support innovative programs that the NYPD could not readily fund’ (NYCP Foundation 2017). A key aspect of achieving these purported anti-corruption goals is transparency. ‘Nonprofit foundations depend on public confidence, and transparency is a key to building that trust,’ argues the COPS Office in its guidelines for creating a police foundation (Delaney et al. 2014: 25). The importance of transparency in avoiding conflicts of interest and sustaining public trust is a theme in every practitioner publication on police foundations to date. Here we assess these transparency claims. The evidence presented below on foundation secrecy runs contrary to claims of Butler and Delaney (2010) that ‘[t]he transparency offered by foundations in financial management and the tax break for the donor make a foundation a win-win for everyone.’ In the IACP’s and Los Angeles Police Foundation’s ethical guidelines for police foundations, the importance of openness and transparency is similarly emphasized (Wagener 2010). Transparency ‘is essential to successful foundation management’ (Wagener 2010). Among other practices, the guidelines suggest foundation officials make detailed meeting minutes ‘available to anyone who wants to read them’ (Wagener 2010). Transparency can allegedly help avoid conflicts of interest that police foundations might foment: ‘While most police foundations are not required to do business in the same manner as local city, town, or village governments, and they may have different procedures or contract policies, avoiding conflicts of interest in all dealings is essential to a foundation’s success’ (Wagener 2010). In our research examining financial aspects of police donations and sponsorship (also see Lippert and Walby forthcoming; Luscombe et al. forthcoming; Grabosky 2007; Ayling et al. 2009), we encountered numerous barriers to transparency and information access. Our FOI requests to police departments about donations and sponsorship were regularly denied or severely restricted on the grounds that most donation and sponsorship records are held by police foundations that by definition are not public institutions. Intentional or not, it is undeniable that a police department benefits from this layer of obfuscation and opacity. In Canada and the United States, police foundations are typically registered as non-profit organizations. Apart from disclosure of tax returns, police foundations are exempt from public access and FOI laws that apply to public police departments they ‘partner’ with. Two examples of our efforts to gain access to foundation-related records through FOI in Canada come from Abbotsford, BC and Edmonton, Alberta. The Abbotsford Police Department denied us access to donation-related information by claiming foundation records were outside their legal purview: Abbotsford Police Department does not accept donations or sponsorships directly; however, you may contact Abbotsford Police Foundation… for information regarding any donations or sponsorships they may handle. We cannot release information belonging to Abbotsford Police Foundation as it does not belong to Abbotsford Police Department. The separation of foundation from police department is used to negate the responsibility to release records, deflecting it onto a private entity outside the scope of FOI, an unstated benefit of Davis’s (2010) ‘formal structure’ argument. As the president of this same foundation wrote to us: The Abbotsford Police Foundation… is not subject to the Freedom of Information and Protection of Privacy Act and has no legislated obligation to provide the public with access to its documents or records…. It is beyond doubt that the APD and the Foundation are separate legal entities. The Department does not ‘own’ the Foundation…. For those and a variety of other reasons, the Department does not have custody or control of any Foundation records and has no right or authority to release them. The Edmonton Police Service blocked our FOI request on similar grounds: The EPS does not have a foundation or fundraising arm. The Edmonton Police Foundation is an arms-length Foundation that fundraises to support policing activities and provides scholarships related to police education and for police recruits based on merit. Donors may provide donations to the Edmonton Police Foundation directly to specific programs or to support the aims of the Foundation in general…The Edmonton Police Service does not host or solicit any fundraising activities. Fundraising activities are hosted exclusively by the Edmonton Police Foundation. The Edmonton Police Service does receive many unsolicited donations through the course of the year generally either to a specific program or to the Service in general… Requests for Edmonton Police Foundation records must be submitted directly to their office. When we spoke with an Edmonton Police Service FOI coordinator by telephone, this staff member asked if we would be approaching the Edmonton Police Foundation for information. We replied we might but that it was difficult given the foundation is non-profit and not subject to FOI legislation. She replied bluntly: ‘that is true’. Our efforts to contact foundations directly have received varied responses, from silence, to denial (explaining donor information is confidential), to what we interpreted as hostility (asking us to cease contacting donors and the foundation). In essence, police foundations treat access to information and transparency as a problem, and prefer to adopt a trade secrecy orientation (Luscombe, Walby and Lippert forthcoming) consistent with serving as a shell under which dark money can be exchanged. Another foundation we contacted first denied us information. When we inquired directly with its ‘sponsors’, the foundation became less and less friendly toward us. We wrote to the foundation explaining our research and asked for clarity about its ‘sponsorship opportunities packages’ (we sought to determine how much money a lead sponsor had provided for a police event). The foundation’s coordinator denied politely: ‘[W]e made special arrangements to accommodate specific needs of our leadership sponsors. I am unable to release any additional information. Good luck with your analysis!’ We then rephrased our inquiry, only to receive a similar reply: ‘As per my original email, we are unable to release additional information.’ Next, we asked the sponsor how much money they had provided by leaving a telephone message. We then received a less friendly response from the foundation’s executive director: It was brought to my attention that you have been, and continue to be, inquiring with our corporate supporter… about their level of contribution… I believe… our office has been in touch with you, explaining that [the corporation’s] support was structured as a sponsorship as well as a directed donation in honour of the former Chief [of police]. The information… was intended as a reference only for potential sponsors, and was in no way affirmative of the total contribution committed by each sponsor. The Foundation…aims to make its best possible efforts to adapt the recognition options and benefits associated with a sponsorship level to the specific needs and objectives of a corporate partner. If an individual or a corporate partner wants to remain anonymous and/or do not disclose their specific contribution, we respect their wishes and privacy. (emphasis in original) We later requested an interview with this executive director but received no response. The issues raised in our efforts to access foundation records and the case of Baltimore we describe next are not isolated. In 2014, when the LAPD Commissioner began soliciting funds from Dreamworks Animation to purchase 860 body cameras from Taser International, Inc. through the foundation, news media outlets raised questions about potential conflicts of interest and corruption (Reicher 2014; Winston and Graham 2014). Previously, Taser (now called Axon) had made numerous donations to the Los Angeles Police Foundation and questions were then raised about the influence of these transactions (Winston and Graham 2014). Also in 2014, the Los Angeles Police Foundation purchased a new horse for the LAPD’s mounted unit. When news emerged the horse had been bought from the LAPD Chief’s daughter, and that the Chief had approved it, controversy again arose over the Foundation’s lack of transparency (Parker 2014). Earlier questions had emerged in 2007 when the LAPD used the Foundation to purchase controversial surveillance software, originally designed for spy agencies, from Palantir, a firm partly funded by the Central Intelligence Agency. As Winston and Graham (2014) argue: ‘The LAPD could have used a small portion of its multibillion-dollar annual budget to purchase the software, but that would have meant going through a year-long process requiring public meetings, approval from the City Council and, in some cases, competitive bidding.’ Winston and Graham (2014) raise similar questions about the NYCP Foundation’s practices and Weissenstein (2003) earlier identified a link between NYCP Foundation donations and a NYPD operational unit operating to benefit corporate donors: Without question, some contributions beef up police enforcement that benefits the donors. Among the largest contributors to the New York City Police Foundation are Coach, Major League Baseball and the Motion Picture Association of America. Their donations go directly to the police department’s six-person trademark infringement unit, which uses a roughly $200,000 Police Foundation account to fund undercover purchases of counterfeit CDs, DVDs, clothes and other goods. Police Foundation Transparency Rather than accepting that police foundations are vessels of transparency, we use literature on financial obfuscation (Rossman 2014), shell corporations (Jancsics 2016) and dark money to conceptualize how these entities enable financial and public–private relationships that would otherwise contravene laws and policies restricting donations and sponsorship (see also Fridman and Luscombe forthcoming). We contend police foundations as shell corporations broker private, corporate funds to flow to public police without violating laws or rules about direct donations. Far from dissolving the possibility of conflict of interest (Grabosky 2007) or corruption (Punch 2009), foundations may enhance this network characteristic, leading to controversies for police foundations, police services and an ‘erosion of legitimacy’ (Grabosky 2007: 5). Compared to the United States, where there are at least 251 municipal police foundations, the handful of police foundations in Canada have been subjected to less public criticism over their lack of transparency and potential for conflicts of interest. Infrequent, minor criticisms in news media can be found, but nothing like a full-fledged scandal has yet occurred in Canada. When the Calgary Police Foundation went public in 2012, a Calgary Herald newspaper article raised questions about potential special police treatment of donors as ‘insiders,’ but concluded by defending its creation (Corbella 2012). Two years after it had been established in 2010, the foundation had received $6.5 million CDN in donations from ‘big-hearted people and corporations’ (Corbella 2012) like Canadian Natural Resources Ltd, Cenovus Energy, Enbridge Inc., Encana Corporation, MEG Energy, Talisman Energy and Canadian Imperial Bank of Commerce. The article also suggested that concerns about special police treatment for donors were unreasonable given the Foundation’s focus (at the time) on supporting community programs for at-risk youth. The article concluded after discussing potential conflicts of interest the Foundation might create, stating: ‘This Calgary Police Foundation… need not be viewed with any cynicism at all. We should be grateful to all involved. The services that will help at-risk kids will undoubtedly stick with them in a positive way for their entire lives’ (Corbella 2012). In this Canadian city of one million the local police foundation and the fourth estate ride the same train, one greasing the other’s wheels as they move down a seemingly uncontroversial track. The only larger controversy over a police foundation in Canada happened in 1995 with the signing of an agreement between the RCMP Foundation and Walt Disney Co. (Canada) Ltd giving Disney licensed control over the famous ‘Mountie’ image (CBC 1995). The Mounted Police Foundation that owned these rights failed to proceed through public tendering which yielded considerable negative publicity (CBC 1995). A wealth of news articles criticized the Foundation and this deal with Disney. An article in Toronto’s major newspaper, the Globe and Mail, for example, criticized the foundation’s Disney arrangement as well as numerous other deals the Foundation had made with corporations that raised questions of impropriety. This included a sponsorship arrangement that made Canadian Pacific Ltd a ‘partner’ in its Musical Ride: ‘In exchange for undisclosed sponsorship fees, Canadian Pacific—described by an RCMP spokesman as a corporation with a history of values ‘consistent with ours’—will get signs at Musical Ride performances, mention in public-address announcements and guest passes’ (Valpy 1995). The article went as far as to call the Foundation’s board of directors ‘unreconstructed, loose-cannonball capitalists’ (Valpy 1995). As the article concludes: ‘It seems odd that a police force should be in this business’ (Valpy 1995). On the whole, however, critical media coverage of police foundations is rare in Canada. When the Mounted Police Foundation was established in 1994, no Canadian journalist covered the story, though it was reported by CNN in the United States (Valpy 1995). The growth and operations of foundations in Canada and the United States is happening largely under the news media’s radar, with little to no public opposition or probing. Yet, some recent controversies over foundation transparency in the United States are worth illuminating. They serve as exemplars of what can happen when private charitable agencies are secretly misused by police officials and rich corporate ‘philanthropists.’ Below we discuss the recent example of Baltimore. Baltimore Police foundation controversy in Baltimore began in the early 2000s when former commissioner Edward T. Norris was tried and convicted of misusing private donations held in the Department’s charity account. The funds had been donated to the police to ‘provide money for the needy’ (Donovan 2016a). The then Baltimore Police Foundation, although not directly involved with this controversy, was deeply affected by it leading to its dissolution shortly thereafter. Norris had initiated the Baltimore Police Foundation in 2000, an idea acquired from working for the NYPD (Wilber 2000). The Baltimore Police Foundation had ‘for years covered the cost of equipment and initiatives that the city’s tight budget couldn’t cover’ (Donovan 2016a). As with other police foundations, it had operated as a separate 501(c)(3) non-profit fundraising arm of the police with an executive director and board of directors. After the controversy involving Norris, ‘the integrity of the charity crumbled’ (Donovan 2016a). Norris moved to Baltimore from New York City in May 2000, where he had worked for the NYPD, and rose from deputy commissioner to commissioner of the Baltimore Police Department in several months (Kilborn 2003). In August 2002, The Baltimore Sun began reporting on Norris’s use of the charity account for expenditures not beneficial to the department (e.g. paying overtime of the commissioner’s driver) (Wilber 2003; Gibson and Wilber 2004). An independent audit paid for by the City of Baltimore identified $7,663 USD in misspent funds and deducted it from Norris’s pay. Norris then left the Baltimore Police for the Maryland State Police (Wilber 2003). Federal investigators later unraveled the extent of Norris’s spending. It was found Norris had misused upwards of $30,000 USD in charitable donations on personal gifts, private travel and accommodations, visits with girlfriends and excessive overtime hours for his six-member security protection team, among other things (Kilborn 2003; Rich 2004). Norris plead guilty and was sentenced to six months in prison in 2004 (Rich 2004). This was only the first donation-related controversy in the City of Baltimore. Despite closing the Baltimore Police Foundation, private donations continued to flow through two Baltimore Community Foundation accounts created to channel funds to the police department: the ‘Baltimore Police Endowment Fund’ and the ‘Baltimore Police Special Grants Fund’ (Fenton and Donovan 2016). Between 2011 and 2013, Baltimore Police, through the Baltimore Community Foundation, had received roughly $900,000 USD in donations. In 2011, for example, Under Armour donated $300,000 USD for computers, Tasers and other items. Other major corporations known to have donated to the police through this Foundation include Wal-Mart and Target (Fenton and Donovan 2016). Houston billionaire philanthropists, John and Laura Arnold made a more controversial donation in 2015. In true domestic shell corporation fashion, the donation to the Baltimore Police Special Grants Fund was not publicly advertised by the Baltimore Community Foundation (Fenton and Donovan 2016). In November 2015, the Arnolds donated $120,000 USD to this Foundation’s police fund for an aerial surveillance program, conducted by Persistent Surveillance Systems, working with the Baltimore Police Department. John Arnold, after learning about aerial surveillance technologies, contacted Ross McNutt, owner of Persistent Surveillance Systems and expressed interest in developing the company’s services (Dart 2016). McNutt, who had created the surveillance program while in the US Air Force, had been actively approaching police departments in the US since 2012 to secure a contract (Reel 2016). The Arnolds promised to pay for the aerial technology if McNutt could find a police department to partner with (Donovan 2016a, 2016b). McNutt contacted the Baltimore Police Department discovered through a trade-show where he was featuring his company’s services (Reel 2016). During 2016, the plane logged 314 hours of flight time and collected over one million images (Dart 2016). McNutt and his analysts used the aerial footage to help police investigate numerous crimes for six months, though his aid and the program were never publicized (Reel 2016). In April 2016, the Arnolds contacted the Baltimore Community Foundation seeking to donate an additional $240,000 USD to review the program’s effectiveness in reducing crime. After this Foundation declined the funding, claiming it lacked resources to conduct the review, the Arnolds contacted the ‘Police Foundation’ in Washington, DC, a national-level foundation not tied to any one police department, which agreed to accept the donation to review the program (Donovan 2016a). Until Bloomberg Businessweek (Reel 2016) published an article revealing the program in August, neither City Council nor Baltimore’s residents knew about it. There had been no public bidding process, City approval or press statement by police, the Baltimore Community Foundation, Persistent Surveillance Systems or the Arnolds. The use of the aerial surveillance footage was not mentioned by the Baltimore Police either (Reel 2016). When McNutt’s activities with the Baltimore Police Department were exposed in August 2016, controversy broke out over the program (Broadwater and Donovan 2016; Rector and Broadwater 2016). To date, it is unclear whether the Baltimore Police Department will continue the program. Discussion and Conclusion Police foundation staff claim foundations promote transparency and prevent corruption. The NYCP Foundation tells its own history this way: in the early 1970s, when the NYPD was undergoing extensive criticism and reform to deal with systemic, long-standing corruption (the time of the Knapp Commission, which had issued a scathing interim report on July 1, 1971 (New York 1973: 273–276), the foundation emerged as one remedy. A more critical interpretation is that police foundations and the cryptic exchanges they facilitate increase potential risks of corruption and conflict of interest. The work of foundations could even be likened to an organizational form of ‘noble cause corruption’ (Punch 2000: 305) in that they sometimes seemingly encourage ‘illicit means for organizationally and socially approved ends…it is not done for gain but to lubricate the machinery of criminal justice’. Relatedly, Gray (2013: 533) uses the idea of ‘institutional corruption’ to refer to ‘influences that implicitly or purposively serve to distort the independence of a professional in a position of trust’. These efforts are consistent too with the white-collar crime literature that examines the mechanics and opportunity structures that produce white-collar crime (Benson et al. 2009). Shapiro (1990: 346), for example, has called for criminologists of white-collar crime to explore how institutional norms of trust are established and exploited. To help enrich literature on private sponsorship of policing and private influence on public police (Grabosky 2007; Ayling et al. 2009), which has usefully examined the coercive, market and gift-like dimensions of such exchanges, we have used the ideas of shell corporations (Jancsics 2016) and dark money (Mayer 2016) to conceptualize this potential for conflict of interest that police foundations create. We have deployed these notions to illustrate how these organizations mask or buffer disreputable exchanges (Rossman 2014) created by corporate donations to police and that may erode legitimacy or distort the impartial character of police. While undoubtedly these transfers often involve ‘commerce masquerading as gift’ (Ayling et al. 2009: 230) insofar as some donors stand to benefit during later police procurement, the shell corporation and dark money terminology places more emphasis on the surreptitious and corporate nature of these transactions. Police foundations represent a corporate approach to police sponsorship and therefore exemplify criminal justice corporatization (also see Lippert and Walby forthcoming; Luscombe et al. forthcoming; O’Malley and Hutchinson 2007). Police and police foundation officials are aware of the risks of accepting donations from external private sources, even when channeled through an independent foundation. As the IACP’s ethical guidelines on police foundations state: ‘Do not create a perception of entitlement for donors regarding access to department services or the possibility of preferential treatment’ (Wagener 2010). Scott (2006), in her work on creating a Winnipeg Police Foundation, also acknowledged this ‘potential risk’: ‘The perception that affluent donors may gain considerable influence because of their support to the foundation’ (Scott 2006: 61; also see Grabosky 2007). Her solution was for Winnipeg Police Service leadership to ‘mitigate this risk as much as possible’ (Scott 2006: 61–62). For this reason, Walters (2004) argues police foundations should be subject to ethical guidelines and standards. Without validating the notion of transparency given its almost mythical status (Christensen and Cornelissen 2015), and without suggesting other public police issues will disappear if police simply operated more openly, police foundations can minimize the potential for corruption by operating with a higher degree of transparency than presently. IACP best practices and police practitioner rhetoric are quick to encourage transparency in police foundation management. But in practice police foundations are not operating with a high level of transparency. A high degree of openness and transparency are vital given the high stakes and potential for conflict of interest and corruption. Failure of police foundations to garner and secure public trust can result not only in their dissolution but can also create collateral damage to the reputation and trust of a police department too given their close connection. A practical solution to help enact a commitment to transparency for foundations would be to bring them under FOI or sunshine law. Yet reforming FOI law to include police foundation records would be no easy feat and would not necessarily ensure access to relevant records. In Canada, we made numerous appeals to provincial information and privacy commissioners about the transparency problems posed by police foundations but to no avail. There is a precedent in several US states that expose foundations where dark money is exchanged to the sunshine of FOI laws. The Sunshine Law in Florida refers to cases in which private entities such as foundations should be subject to FOI. However, in one case those creating the foundation in question lobbied a City Commission to exempt Sarasota Police Foundation Inc. from the state’s Sunshine Law (Cummings 2014). This decision provides another example of police foundations’ opacity. Decisions such as this and like efforts to bring police foundations under FOI law will have a significant impact on whether the advent of police foundations marks the beginning of a future when private, corporate monies and influence will be transacted under grander shell corporations in the dark and therein be able to reach deeper into public police operations and mandates. Funding This work was supported by a Social Sciences and Humanities Research Council of Canada (SSHRC) Insight Grant, award number 435-2015-0223. References Ayling , J. P. , Grabosky , P. and Shearing , C . ( 2009 ), Lengthening the Arm of the Law: Enhancing Police Resources in the 21st Century . Cambridge University Press . Benson , M. , Madensen , T. and Eck , J . 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Open Source Geospatial Foundation Project. http://www.qgis.org/. 3 One source of emulation was the Washington, DC-based American Police Foundation noted later in this paper (Vancouver 1978). 4 These articles, which since have been removed from the IACP’s website, can be accessed by copying the URLs in the bibliographic entries into the internet database’s ‘Wayback Machine’. https://archive.org/web/. 5 We did not identify foundations in the states of ME, ID, VT, WV, NM, AR or AK. 6 In contrast to revenue, income is prior to subtraction of foundation costs or expenses. We use revenue below in our discussion of Canadian foundations as this was the only statistic available from Canada Revenue Agency’s charity database. 7 https://www.irs.gov/charities-non-profits/exempt-organizations-business-master-file-extract-eo-bmf 8 http://www.cra-arc.gc.ca/ebci/haip/srch/basicsearchresult- eng.action?k=police&s=registered&p=1&b=true. 9 Although federal in orientation, we include the RCMP Foundation in our analysis since the RCMP includes numerous municipal detachments in, e.g. BC, AB, SK, NB and NL. © The Author(s) 2017. Published by Oxford University Press on behalf of the Centre for Crime and Justice Studies (ISTD). All rights reserved. For permissions, please e-mail: [email protected] This article is published and distributed under the terms of the Oxford University Press, Standard Journals Publication Model (https://academic.oup.com/journals/pages/about_us/legal/notices)

Journal

The British Journal of Criminology – Oxford University Press

Published: Sep 15, 2017

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