Are NGOs International Criminal Entrerprses?

In his interesting article, The U.N., Preying on the Weak, in today's Washington Post, Peter Dennis observes that the UN-affiliated NGOs were up to more than hanky-panky: "In fact, abuse at these camps went beyond sexual violations: Injustices of one sort or another were perpetrated by U.N. missions or their affiliated nongovernmental organizations every day in the camps I visited. Corruption was the norm, in particular the embezzlement of food and funds by NGO officials, which often left camp resources dangerously inadequate. Utterly arbitrary judicial systems in the camps subjected refugees to violent physical punishment or months in prison for trivial offenses -- all at the whim of officials and in the absence of any sort of hearing."