The biggest share of accountability rests, in my mind, with the board of directors of the foundation. They had a fiduciary responsibility to the foundation. In my view, they failed to ensure that conflicts of interest were well managed and to comply with legal requirements. Most concerning is that this group of members was allowed to dwindle to two individuals instead of 15, and they then appointed five members to the board of directors. That, to me, was a huge gap in governance at the foundation and in compliance with its enabling legislation.
The department plays some role in oversight. However, I think, ultimately, this failure rests with the board of directors of the foundation.