Who Is Funding the USMI CODEL to Moldova?
A new privately sponsored congressional delegation raises old questions about Sam Alaverdov’s nonprofits
The US Moldova Initiative (USMI), a new US-based nonprofit led by Sam Alaverdov, has requested meetings with Moldovan officials for a privately funded US Congressional delegation scheduled for July 24 - 29, 2026.
USMI has sent meeting requests to various officials in preparation for the visit. The following is a request for a meeting obtained by Moldova Matters that was sent by USMI to the office of Prime Minister Alexandru Munteanu prior to his resignation:
In this letter, USMI states that the CODEL includes Representatives Andy Harris (R-MD), Earl “Buddy” Carter (R-GA), Michael Cloud (R-TX) and Sheri Biggs (R-SC).
Reached for comment and confirmation of their attendance, the offices of Representatives Andy Harris, Michael Cloud, and Sheri Biggs did not respond by the time of publication. Representative Earl “Buddy” Carter’s office responded writing:
“Rep. Buddy Carter is not currently scheduled to attend.”
This response does not indicate whether Representative Carter had previously planned to attend the CODEL as indicated by USMI and since canceled, or never planned to attend.
While the letter is dated May 7, reporting by Moldova Matters has found that it was only sent to the Prime Minister’s office sometime in the last 2 weeks.
The CODEL is privately funded, meaning that travel and accommodations for members of Congress and any accompanying family members, staff, or other guests are paid for by a private organization rather than through ordinary government travel channels. While USMI is organizing the CODEL, the details of who is financing it are not currently public. House Ethics rules require pre-approval for privately sponsored congressional travel, followed by public filings after the trip disclosing the sponsor, itinerary, participants, and costs.
You can read Moldova Matters’ previous investigation into USMI and its founder here:
Sam Alaverdov’s Lobbying Efforts on Behalf of Vasile Tarlev
Before becoming the Executive Director of USMI, Sam Alaverdov1 was the subject of a Moldova Matters investigation into a lobbying effort on behalf of then-presidential candidate Vasile Tarlev. His previous NGO, alternately named the “American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc.” and the “American Charity Fund for Helping Children of Ukraine and Moldova Inc.” - which went by the acronym ACFHCUM - signed a contract with American PR and lobbying firm Qorvis on behalf of Mr. Tarlev.
ACFHCUM and the US Moldova Initiative (USMI) are both registered at the same address - Sam Alaverdov’s house in Valley Stream NY.
ACFHCUM’s tax filings show years of almost zero fundraising and zero expenditures on charitable causes. In September 2024 ACFHCUM signed an $85,000 contract with Qorvis to enhance the reputation of then candidate Tarlev in Washington DC. While Tarlev’s trip to the United States never occurred due to visa issues, $45,000 of this contract was paid on September 30, 2024. While ACFHCUM was designated in the contract as the entity paying, reporting by Moldova Matters found that it was Sam Alaverdov who made the payment to Qorvis personally. Reached for comment on that previous story, and asked why his nonprofit had engaged this contract, Mr. Alaverdov replied simply “I like him.”
Vasile Tarlev has been widely reported as a part of Ilan Shor’s political network in Moldova. This reporting included multiple undercover investigations in Moldova, reporting about how Shor personally chose Tarlev as a candidate and Tarlev’s own party vice president asserting that Tarlev had joined Ilan Shor.
Unlike Ilan Shor, Vasile Tarlev is not subject to US sanctions and so there is nothing illegal about Alaverdov making this payment for him. The same cannot be said of Mr. Tarlev’s failure to report a large political contribution made on his behalf.
You can read Moldova Matters’ previous investigations into this lobbying effort here:
Sam Alaverdov’s 2021 CODEL to Ukraine
In August 2021 a different 501c3 nonprofit called The Humpty Dumpty Institute (HDI) organized a privately funded CODEL to Ukraine and listed ACFHCUM as the funder of the trip on their filings with the House Committee on Ethics. This trip brought Representatives Tony Gonzales (R-TX), Barry Moore (R-AL) and Troy Nehls (R-TX) to Kyiv so that they could “get a better understanding of the complexities of the region through meetings with the Ukrainian government, business, and cultural leaders.”
This was noted at the time as the most expensive CODEL in 2021 and cost over $46,000. Expenses included travel and accommodations for the Representatives, members of their families, congressional staff, HDI staff and Sam Alaverdov.
According to tax filings, ACFHCUM claimed neither income nor expenses in 2021. It remains unclear to this day who actually paid for this trip.
A person familiar with HDI’s handling of the 2021 Ukraine CODEL told Moldova Matters that the controversy surrounding that trip prompted HDI’s board to change its internal policy on future congressional delegations. According to this person, HDI later adopted a policy of partnering only with well-known, established organizations on CODELs. The person also said that Alaverdov later approached HDI about another congressional delegation, but HDI declined to work with him.
A Very Complicated CODEL
The controversy surrounding this 2021 CODEL continues to haunt HDI and the Members of Congress who attended. There was nothing unusual about the trip itself and no credible allegations of impropriety. The problem for this trip was The Humpty Dumpty Institute (HDI) where Mark Epstein - brother of Jeffrey Epstein - had served as a longtime board member.
The conspiracy theorist website “The National File,” founded by Alex Jones, published an article about the CODEL which latched on to the word “children” in American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc and combined it with “Epstein” to create a wild array of conspiracy theories2.
This article, and the many that followed it, had no merit - but it did have impact. Representatives who attended the trip were harried by “journalists” in the halls of Congress with questions about the CODEL. This ecosystem continues to focus on this 2021 trip, HDI and Sam Alaverdov. Moldova Matters received an email this week with a new article published July 10 continuing in this direction3.
While the deep state allegations continue to have neither sense nor merit, these articles do grab onto the most salient question - how did a tiny cash-strapped nonprofit pay more than $46,000 for this trip? and where did the money come from?
Who Funds USMI?
Given both the financing of a lobbying contract for Vasile Tarlev, and ACFHCUM’s claim to have financed the 2021 CODEL while reporting neither income nor expenditure in that year, it is important to ask who is funding USMI’s planned CODEL to Moldova.
Sam Alaverdov and USMI did not respond to questions or requests for comment on this article.
In the 2 years since USMI was granted 501c3 public charity status by the IRS, they have filed Form 990 e-postcard for their tax returns. That is a simplified filing method for small nonprofits with under $50,000 in gross receipts. It does not provide any information about their actual income, expenses or donors.
USMI’s website also lists no donors and does not have any mechanism for people to donate to the organization.
On their website, USMI has a page titled “Our Partners,” which presents an odd list of entities in Moldova including construction companies, a major supermarket chain, some NGOs and the UN Refugee Agency in Moldova (UNHCR). Reached for comment by Moldova Matters, a spokesperson for UNHCR Moldova told Moldova Matters that the organization has no association with USMI.
Why it Matters
As the organizer of this privately funded CODEL, USMI has significant influence over the agenda of the trip. Unlike official government-organized travel, which is coordinated by the State Department, privately sponsored CODELs give the sponsoring organization the key role in shaping which meetings are requested.
In addition to their outreach to the Prime Minister’s office, and likely outreach to other senior officials, USMI will decide which civic groups, journalists, activists, religious figures and opposition politicians the attending Members of Congress will meet with while in Moldova. This gives Sam Alaverdov and the USMI team a lot of control over what messages those members will receive while in country.
This CODEL would only be the first step in USMI’s potential influence. According to their website, the organization aspires to be a bridge in American - Moldovan relations. The organization of a high profile CODEL would cement USMI as a player in the bilateral relationship.
With that as context, it is important to center Sam Alaverdov as the founder and Executive Director of USMI. His personal payment of $45,000 in support of Shor-linked politician Vasile Tarlev calls into question USMI’s presentation of itself as a supporter of Moldova’s European aspirations.
Further, his role in the 2021 Ukraine CODEL continues to raise serious questions. In particular, the fact that HDI chose not to collaborate with Mr. Alaverdov after that event - and the fact that we still do not know who paid for it - in spite of ACFHCUM being listed on Congressional Ethics filings.
If the trip proceeds as planned, House travel disclosures will eventually show the approved sponsor, itinerary, participants, and costs - but those filings will likely become public only after the delegation returns. Moldova Matters will continue following this CODEL closely and will report on these after-the-fact filings when available.
Legal name: Semen George Alaverdov
… involving Soros, the Vatican, Israel, China, Ukrainian Nazis, Zionists, the deep state, the Clintons and many more
Apparently I am also part of the deep state. The new article was posted on July 10, 2026 in the Australian National Review - a fringe / conspiracy theorist website.