Comment by fl0wenol

Not quite, they're an NGO and the CyberTipline which it operates (the database Apple will use) was established by S.1738 [PROTECT our Children Act of 2008], and they get an appropriation from Congress to run that and work with law enforcement.

It's kind of like the PCAOB... private 501.3(c) with congressional oversight and funding.

I think the strategy is that the organization is able to do more for helping children internationally if they're not seen as part of the Justice department and the executive, which after the debacle with CBP and "kids in cages", was probably the right call.