Intermediate sanctions and excess benefit penalties tied to fundraising compensation and benefits

$5,000–$50,000+ per occurrence (25% initial excise tax on excess benefit amount, escalating to 200% if not corrected within taxable period; e.g., $10,000 excess benefit = $2,500 initial tax, $20,000 if corrected late) • $8,000–$100,000+ per occurrence (25% excise tax on excess benefit for AFM; 10% excise tax per board member who knowingly approved, capped at $10,000/manager; potential IRS audit costs $15,000–$50,000+)

Ad-hoc email approvals from executive director, compensation decisions recorded in meeting minutes but not formally benchmarked, use of personal spreadsheets to track benefits, no written policy linking compensation to role-specific metrics • Compensation approved retroactively or informally; reliance on gut-feel for 'reasonable' salary; no written compensation policy; board approves budget line items but not individual compensation arrangements; grants/foundation contracts passed through without vetting personal benefit to AFM