Agency: European Adoption Consultants, Inc. Status: Temporarily Debarred (see 22 CFR 96.85) Date: 12/16/16 Nature of Violations: 22 CFR 96.40. EAC’s contract with clients purported to absolve the agency of oversight and monitoring responsibility for the fees charged by its foreign supervised providers or paid to third parties. The fees EAC disclosed to clients were not the actual fees charged to clients when they were in a foreign country. 22 CFR 96.34(d). The fees charged by EAC’s providers in multiple countries were unreasonably high in relation to the services actually rendered. 22 CFR 96.36(a). EAC offered consideration to birth parents to induce them to release their children for adoption. 22 CFR 96.49(f). EAC failed to use reasonable efforts to obtain accurate information about children in multiple countries. 22 CFR 96.49(j). EAC withheld and/or misrepresented social and other pertinent information about children in multiple instances. 22 CFR 96.41(e). EAC took actions to discourage clients who voiced concerns about EAC’s practices from making complaints, expressing a grievance, or questioning the conduct of or expressing an opinion about the performance of the agency. 22 CFR 96.52(a). EAC failed to inform a foreign Central Authority and the Secretary about the adoption process in a case involving a child immigrating to the U.S. in which the prospective adoptive parents had decided that they no longer wished to adopt the child. 22 CFR 96.39(c). EAC gave preferential treatment to an employee with respect to the placement of a child for adoption when there was a failure of the child’s initial adoption. The placement decision, together with other failures related to that placement, resulted in serious harm to a child. 22 CFR 96.47. EAC failed to ensure that a home study and background check was completed before locating a new adoptive family and placing the child with that family, following the failure of the child’s initial adoption. 22 CFR 96.52(b). EAC failed to transmit a new home study to a Central Authority when a new family was identified for placement of a child who was still habitually resident in their country of origin and who had been adopted in the country of origin by a different family. 22 CFR 96.48. EAC failed to provide preparation and training for the new family of a child following a failed first adoption. 22 CFR 96.44(a) & 96.46(a). EAC failed to adequately supervise its providers in foreign countries to ensure that they complied with the laws of the country in which they operated, and that they did not engage in practices inconsistent with the principles of furthering the best interests of the child and preventing the sale, abduction, exploitation, or trafficking of children. The failure to provide adequate supervision contributed to many of the violations described above. 22 CFR 96.46(a) & (c). EAC failed to ensure, through direct supervision or through verification through review of documentation and other appropriate steps, that consents to termination of parental rights were obtained in accordance with applicable U.S. and foreign law and regulations, and that any background studies and reports on a child were performed in accordance with applicable U.S. and foreign law and regulations. 22 CFR 96.52(e) EAC failed to perform tasks identified by the Secretary of State as required to comply with the Hague Convention on Protection of Children and Co-operation in Respect of Intercountry Adoption (the “Convention”) , the Intercountry Adoption Act of 2000 (the “IAA”), and the Intercountry Adoption Universal Accreditation Act of 2012 (“UAA”), and implementing regulations, including the conduct described above and the following violations: Solicitation of bribes; Fraudulently obtaining birth parent consent, and misrepresentation to birth parents of the effect and significance of their consents; Use of false documents and misrepresentations to influence or affect the decisions and actions of the U.S. and foreign governments with respect to a determination of a child’s eligibility for intercountry adoption, or to affect the decisions of an accrediting entity with respect to accreditation. 22 CFR 96.35 (a) & 96.27(g). In general, based on the conduct described above, EAC consistently failed to provide adoption services ethically and in accordance with the Convention's principles of ensuring that intercountry adoptions take place in the best interests of children, and failed to provide adoption services in intercountry adoption cases consistent with the laws of any state in which it operates, the Convention, the IAA and the UAA.