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Former HR Executive Agrees to Pay $160,000 to Resolve False Claims Act Allegations

Posted on July 29, 2026 By GBC NEWS No Comments on Former HR Executive Agrees to Pay $160,000 to Resolve False Claims Act Allegations

WASHINGTON – The United States Attorney’s Office for the District of Columbia announced today that it reached a civil settlement agreement with Carleena Graham, whereby the former Vice President of Human Resources for World Learning has agreed to pay $160,000 to resolve allegations that she violated the False Claims Act by submitting false invoices to her employer for reimbursement of expenses that benefitted her personally and organizations with which she was affiliated.  

World Learning is a nonprofit global development and exchange organization that delivers educational and professional training programs around the world. It was also a recipient of United States Agency for International Development (USAID) and U.S. Department of State funds through various grants, contracts, and negotiated indirect cost rate agreements totaling several million dollars. 

The Government asserts that, from approximately 2015 to 2022, Graham orchestrated a scheme to submit false invoices to World Learning for reimbursement of hundreds of thousands of dollars of expenses. As part of that scheme, Graham arranged for goods and services to be delivered to third-party organizations and then arranged for World Learning to pay for these goods and services via electronic transfers of funds from its bank account or use of World Learning’s credit cards. The Government also found that Graham falsified invoices submitted by vendors for payment of the goods and services to make them appear as though World Learning was the recipient of the goods and services. By defrauding World Learning, the Government contends Graham was also misappropriating funds the nonprofit received from USAID and the State Department. 

The settlement concludes a joint investigation conducted by USAID Office of Inspector General and the State Department Office of Inspector General that followed Graham’s guilty plea in the District of Vermont to one count of wire fraud in violation of 18 U.S.C. § 1343 for the above-described conduct. United States v. Carleena Graham, Case No. 23-cr-57.  

The civil settlement resulted from the work of Assistant United States Attorney Sam Escher and Auditor Timothy J. Hurley with the support of Special Agents from USAID and the State Department’s Offices of Inspector General. 

The claims resolved by the civil settlement are allegations only, and there has been no determination of liability. 

carleena_graham_fca_settlement_agrmnt.pdf

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