In January, the Trump administration launched a new international organization, the Board of Peace, with a mandate to carry out peace-building activities in Gaza and potentially in other regions experiencing conflict. In February, at an initial organizing meeting of the Board of Peace, Trump announced that the United States was pledging to contribute $10 billion to the Board’s work.
A U.S. financial contribution to the Board of Peace will require engagement with Congress. The Trump administration’s budget request to Congress for the Department of State for Fiscal Year 2027, which was submitted to Congress on April 3, includes requests for funding that the document says could be used to make contributions to the Board, though does not specify proposed amounts of such contributions (see pages 91 and 96 of the budget request). Separately, a published report indicates that the Trump administration is seeking to reallocate $1.25 billion in funds previously appropriated for other purposes to be used for contribution to the Board.
Congress has historically given close scrutiny to requests for funding for assistance to Gaza and to requests for funding for contributions to international organizations. In addition, considerations specific to the Board of Peace suggest a further need for close scrutiny of the administration’s request. The Board is in its infancy and thus has no track record of designing and implementing effective programs or managing donor funds, which are factors Congress would typically consider when deciding whether to appropriate federal funding for a particular organization or initiative. And the high degree of control that Donald Trump exercises in his personal capacity over the Board’s activities and operations, pursuant to the Board’s Charter, creates the potential for conflicts of interest and other concerns for donors.
Close scrutiny of the administration’s plans for contributions to the Board of Peace is also warranted in light of the large dollar amounts involved. For context, the initial $1.25 billion the administration is reportedly seeking to reallocate from previously appropriated funds for a contribution to the Board of Peace would, by itself, nearly equal the total amount of money Congress appropriated for U.S. assessed contributions to all other international organizations worldwide in 2026, and would make the Board one of the two or three largest institutional recipients of U.S. humanitarian assistance funding in the world.
Against this background, below are some questions Congress should consider in connection with the Trump administration’s requests for funding to be provided to the Board of Peace.
1. How much federal funding is the administration proposing to provide to the Board and what impact will it have on other funding priorities?
While Trump has publicly announced a $10 billion U.S. pledge to the Board of Peace, the administration has not clearly indicated how much money it is currently proposing to provide to the Board.
According to a media report, it is apparently seeking to provide at least $1.25 billion, to be taken from funds previously appropriated for international disaster assistance, peacekeeping operations, and international organizations and programs.
In addition, its budget request to Congress for Fiscal Year 2027 seeks appropriations that could be used for additional contributions to the Board. The budget request identifies two accounts from which it proposes such contributions could be provided: the International Humanitarian Assistance account and the America First Opportunity Fund account. In both cases, the budget request says only that funds from these accounts may be used “for potential contributions to the Board of Peace.”
The total amount requested for these two accounts in Fiscal Year 2027 is $9 billion, but these accounts are also proposed to be used to fund a range of programs aside from the Board of Peace. As noted in the budget request, the International Humanitarian Assistance account funds “life-saving aid to people globally in the case of a natural or human-made disaster or a protracted emergency,” and “support[s] efforts to reduce mass and illegal immigration.” The request also indicates that the America First Opportunity Fund “will target initiatives that strengthen U.S. competitiveness and global leadership, including diversifying critical minerals supply chains to advance the administration’s reindustrialization agenda, expanding opportunities for American companies through infrastructure; addressing illegal and destabilizing migration; and maintaining global and regional balances of power by countering the influence of adversaries in the telecommunications, technology, and energy industries, including through the Countering PRC Influence Fund (CPIF).”
Congress should seek a clearer understanding of the total amount of money the administration intends to contribute to the Board of Peace across its various proposals, and what impact such funding would have on other programs funded by the accounts that would be used for such contributions.
2. How would the Board of Peace spend money contributed by the United States? What programs does it plan for Gaza reconstruction and how will it implement them?
The Board of Peace has said little to date about its plans for carrying out reconstruction activities in Gaza. In part this may reflect the Board’s initial focus on securing agreement to a process for the disarmament of Hamas. But, as a result, there is little clarity about how U.S. funds contributed to the Board of Peace would be spent, and little basis for Congress to assess how effective the Board’s programs are likely to be in promoting stability and reconstruction in Gaza.
It is also unclear how programs funded by the Board of Peace will be implemented. The Board has not indicated whether it intends to establish its own independent capabilities to directly implement programs on the ground in Gaza, or whether it intends to use implementing partners to carry out its programs. In either case, the effectiveness of its programs will depend significantly on the capacity and expertise of its implementers.
Congress has historically scrutinized U.S. assistance programs for Gaza closely. This has included enacting requirements for oversight mechanisms to prevent the diversion of assistance funds to Hamas; requirements for quarterly reporting on implementation of Gaza assistance programs, including identification of the specific entities implementing assistance; and requirements for annual audits of all contractors and grantees under assistance programs for Gaza.
Congress should seek a clearer understanding of the specific programs the Board of Peace intends to undertake in Gaza, how they will be implemented, and by whom. It should also consider whether oversight requirements it has historically established regarding the implementation of Gaza assistance programs should also apply to assistance provided via the Board of Peace (and if not, why this assistance ought to be treated differently).
3. What financial oversight mechanisms will exist to ensure that funds provided to the Board of Peace are used for their intended purposes and not mismanaged or wasted?
The Board of Peace is in its infancy as an international organization, and thus has not had an opportunity to establish a track record regarding the responsible management of funds and accountability to its donors. The Board’s Charter contemplates that the Board will need to put financial management rules in place, including “controls and oversight mechanisms with respect to budgets, financial accounts, and disbursements, as necessary or appropriate to ensure their integrity.”
At the Board’s Feb. 19 meeting, World Bank President Ajay Banga announced the creation of a dedicated Gaza Reconstruction and Development Fund at the World Bank that would receive contributions of funds on behalf of the Board of Peace. He said that such funds would be disbursed for Gaza reconstruction efforts in accordance with decisions of the Board of Peace. He also indicated that the World Bank would second a financial controller to the Board of Peace to help the Board establish financial, legal, and oversight mechanisms for its work. But the Board has not released details of any such mechanisms or rules, and it is not clear whether it has yet adopted any.
In other contexts, both the Trump administration and Congress have expressed a need for careful oversight of U.S. funds contributed to international organizations. Secretary of State Marco Rubio cited “poor financial and ethical governance” by international organizations as among the reasons for President Trump’s decision to withdraw the United States from a number of existing organizations this past January. And Congress has passed legislation directing the Secretary of State to seek to enter into written agreements with each international organization that receives funding from the United States to provide timely access to the State Department’s Inspector General and the U.S. Comptroller General to such organization’s financial data and other information relevant to United States contributions to such organization (see section 7048(i) of the FY26 National Security, Department of State and Related Programs Appropriations Act).
Congress should seek a clearer understanding of the financial management mechanisms the Board of Peace will put in place, including the details of any arrangements the Board has made with the World Bank in this regard, and whether the Board will employ an Inspector General. It should also seek to understand what arrangements will be made for independent audits of the Board’s accounts, and what information about such audits will be available to donors and the public.
4. What conflict of interest rules will the Board of Peace put in place to address potential concerns created by its unique governance structure?
Under the Board’s governance structure established in its Charter, Donald Trump serves as the Board’s Chairman in his personal capacity and, through that role, exercises significant control over the Board’s activities. He has the power to select both the members of the Board and the individuals who will serve on its executive board. No decision of the Board may be made without his approval, and he may adopt, on his own initiative and without approval of other Board members, resolutions or other directives, to implement the Board’s mission. He is also the final authority regarding the meaning, interpretation, and application of the Board’s Charter, giving him the power to resolve any interpretive questions or disputes regarding authorities of the Board’s various bodies, including regarding the extent of his own power as Chairman. Because the Charter designates Trump in his personal capacity as the Board’s Chairman, he would continue to exercise these powers even after his term as U.S. President has concluded. The Charter also gives Trump the power to designate his successor as Chairman.
These aspects of the Board’s governance structure create the potential for conflicts of interest, as situations may arise in which the interests of the Board as an organization and the personal interests of Trump as the Board’s Chairman may not align. In addition, Trump and members of his family have a range of business interests that could potentially intersect with peace-building activities pursued by the Board of Peace, which also create the potential for conflict of interest concerns.
Other international organizations address potential conflict of interest concerns through the establishment of ethics rules and oversight mechanisms, such as those promulgated by the United Nations and by the Global Fund to Fight AIDS, Tuberculosis, and Malaria. These often include rules designed to prevent conflicts of interest in procurement actions and in hiring and contracting decisions, limitations on receipt of gifts by the organization’s officers and employees, and financial disclosure requirements for certain categories of officers and employees to allow the identification of potential conflicts and a process for them to be appropriately addressed.
Congress should seek a clearer understanding of what rules and mechanisms the Board of Peace will put in place to identify and address potential conflicts of interest that may arise in the conduct of its work. This should include an understanding of what financial disclosure rules will apply to officers and employees of the Board; what rules will apply to the use of Board funds to procure goods and services from, or to make other payments to, entities in which a Board officer or employee has a substantial financial interest; and what conflict of interest rules will apply to the Board’s hiring and recruitment processes for employment.
5. What is the legal basis for the Board to enjoy immunities from lawsuits in the United States?
In January, President Trump issued an executive order purporting to extend the Board of Peace privileges and immunities under U.S. law, including immunity from lawsuits in U.S. courts. Such immunities are comparable to those that foreign states enjoy, and have been similarly extended to certain international organizations to facilitate their work in the United States and to insulate them from potential politically motivated interference.
Trump’s executive order indicated that it was relying on a statute, the International Organizations Immunities Act (IOIA), as the legal basis for extending privileges and immunities to the Board of Peace. But, as explained in more detail here, that statute only allows the President to provide privileges and immunities to international organizations in which the United States participates “pursuant to any treaty or under the authority of any Act of Congress authorizing such participation or making an appropriation for such participation.” Since the Senate has not provided advice and consent to ratification of a treaty providing for U.S. participation in the Board of Peace, and Congress has not previously enacted a statute for this purpose, the IOIA does not appear to provide authority for the President to extend privileges and immunities to the Board. If the Board’s privileges and immunities prove not to be legally effective, the Board’s funds in the United States, including any funds contributed from money appropriated by Congress, could be subject to attachment to satisfy any claims against the Board that are successfully pursued in U.S. courts. Uncertainty about the Board’s privileges and immunities may also dissuade implementing partners from being willing to enter into contracts with the Board to assist in its work.
Congress should seek a clearer understanding of the legal basis on which the administration believes it has provided privileges and immunities to the Board, and should assess the extent to which it believes the administration’s action is legally effective. Congress should also consider whether it believes that the Board should receive such privileges and immunities in the United States, including whether the traditional justifications for providing privileges and immunities to international organizations should apply with equal force to the Board given the extent to which its activities and operations are controlled by a private individual. If Congress believes the Board should enjoy privileges and immunities, it could clarify matters by passing legislation clearly providing them to the Board.
6. What will happen if the Board of Peace is dissolved?
Under the terms of the Board of Peace Charter, Donald Trump, as Chairman, may dissolve the Board of Peace at any time, and the Board will dissolve automatically every two years unless the Chairman acts to renew the Board for a further two-year period. In the event of the Board’s dissolution, the Charter says that “the Executive Board shall provide for the rules and procedures with respect to the settling of all assets, liabilities, and obligations upon dissolution.”
Given the large sums of U.S. funds the Trump administration proposes to contribute to the Board, and the uncertainty about the duration of the Board’s operations created by the terms of its Charter, Congress should seek to understand what would happen to U.S. contributions to the Board of Peace in the event of the Board’s dissolution. In particular, Congress should seek to understand what mechanisms would be available to oversee any further use of funds distributed by the Board of Peace upon its dissolution and to ensure that any funds contributed by the United States are used only for the purposes originally intended.
