An internal audit commissioned by the Clinton Foundation in 2011 revealed that the Clinton’s family charity may have misled the Internal Revenue Service (IRS) when it claimed, under penalty of perjury, that it was enforcing a policy against conflicts of interest.

The audit — apparently requested by Chelsea Clinton, revealed by Wikileaks, and posted by the Daily Caller — was conducted by the law firm Simpson Thatcher & Bartlett. It addressed deficiencies in the Clinton Foundation’s structure and oversight, including the potential for conflicts of interest due to the Hillary Clinton’s role as Secretary of State.

The auditors noted that “some interviewees reported conflicts of those raising funds or donors, some of whom may have an expectation of quid pro quo benefits in return for gifts.” They also flagged a potential problem in the charity’s IRS filing:

… the IRS Form 990, which is signed under penalties of perjury and is publicly available, asks (a) whether the Foundation has a written conflict-of-interest policy, (ii) whether directors, officers, and key employees are required to annually disclose interests that could give rise to conflicts of interest, and (iii) whether the Foundation regularly and consistently monitors and enforces compliance with its conflict-of- interest policy. The Foundation indicated on its 2010 Form 990 that it has a written conflict-of- interest policy, requires annual disclosure of potential conflicts of interest, and monitors and enforces compliance with the policy. However, we did not find evidence of that enforcement.

The auditors concluded with a recommendation (original emphasis): We recommend that the Foundation establish a gift acceptance policy and procedures to ensure that all donors are properly vetted and that no inappropriate quid pro quos are offered to donors in return for contributions.

However, a report compiled in August 2013 on the internal review, published on the Clinton Foundation’s website, implies that the new gift acceptance policy and procedures had not yet been adopted. Hillary Clinton had already left the State Department earlier that year.

Other problems with the Clinton Foundation at the time included that its board did not have a chair, and was not very involved in running the charity. In a footnote, the audit commented: “We were also told that at CHAI [the Clinton Health Access Initiative], [CEO] Ira Magaziner set his own salary.”

Joel B. Pollak is Senior Editor-at-Large at Breitbart News. His new book, See No Evil: 19 Hard Truths the Left Can’t Handle, is available from Regnery through Amazon. Follow him on Twitter at @joelpollak.