Many of the organizations designated as supporting or engaging in terrorism pursuant to E.O. 13224, E.O. 12947, or the Immigration and Nationality Act are either charities that support terrorist activity or are terrorist organizations potentially engaged in fundraising activities. The purpose of this document is to assist donors and charities in the United States and around the world in identifying charities designated on account of their support for terrorism or entities potentially engaged in fundraising activities on behalf of designated foreign terrorist organizations.
On September 23, 2001, the President issued Executive Order 13224,”Blocking Property and Prohibiting Transactions with Persons who Commit, Threaten to Commit, or Support Terrorism.” On January 23, 1995, the President issued Executive Order 12947, “Prohibiting Transactions with Terrorists Who Threaten to Disrupt the Middle East Peace Process.” As part of the comprehensive and sustained campaign against terrorist financing, all U.S. persons, including U.S.-based charities, are prohibited from dealing with persons (individuals and entities) identified as being associated with terrorism under Executive Orders 13224 and 12947 unless first authorized by the Treasury Department’s Office of Foreign Assets Control (OFAC). Any property of these individuals or entities within the possession or control of a U.S. person is also blocked, must be reported to OFAC, and cannot be dealt in without specific authorization from OFAC. OFAC has published comprehensive regulations implementing E.O. 13224 (31 C.F.R. part 594) and E.O. 12947 (31 C.F.R. part 597).
Section 302 of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) amended the Immigration and Nationality Act to authorize the Secretary of State to designate organizations as “Foreign Terrorist Organizations” (FTOs). The Secretary of State designates FTOs in consultation with the Attorney General and the Secretary of the Treasury. These designations, which are undertaken pursuant to section 219 of the Immigration and Nationality Act, target organizations that are: (i) foreign; (ii) engaging in terrorist activity or terrorism; and (iii) threatening the security of United States nationals or the national security of the United States. It is a criminal offense for U.S. persons to provide material support or assistance to FTOs, and financial institutions are required to block all funds in which FTOs or their agents have an interest. FTOs (including their aka’s) are included on Treasury’s list of Specially Designated Nationals and Blocked Persons, and Treasury’s role in the process is spelled out in regulations published at 31 C.F.R. Part 597. It is important to note that all current FTOs have also been designated pursuant to E.O. 13224. The requirements and prohibitions of E.O. 13224 apply to U.S. persons and are described above.
OFAC also administers economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries. U.S. persons, including U.S.-based charities and donors, are generally prohibited from supporting charities or other organizations working in sanctioned jurisdictions unless the appropriate registration and license is acquired from OFAC. A full description of all country sanctions programs administered by OFAC can be found at http://www.treas.gov/offices/enforcement/ofac/programs/. OFAC has developed guidelines for non-governmental organizations wishing to undertake humanitarian activities in sanctioned countries. These guidelines can be found at http://www.treas.gov/offices/enforcement/ofac/regulations/ngo_reg.pdf.
OFAC publishes, updates, and maintains an integrated and comprehensive list of designated parties with whom U.S. persons are prohibited from providing services or conducting transactions and whose assets are blocked. The names on this list include persons designated under country-based and list-based economic sanctions programs, as well as individuals and entities designated under the various executive orders and statutes aimed at terrorism. Persons designated under E.O. 13224, E.O. 12947, or the AEDPA are included on this integrated and comprehensive list and are called “Specially Designated Global Terrorists” or “SDGTs”, “Specially Designated Terrorists” or “SDTs” , or “Foreign Terrorist Organizations” or “FTOs”, respectively. The comprehensive list is accessible through the OFAC website at http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx.
Upon issuing E.O. 13224, President George W. Bush directed the U.S. Department of the Treasury to work with other elements of the federal government and the international community to lead a comprehensive and sustained campaign against the sources and conduits of terrorist financing. Ensuing investigations revealed terrorist abuse of charitable organizations and donors, both in the United States and worldwide, often through the diversion of donations intended for humanitarian purposes but funneled instead to support terrorist organizations and operations. This abuse threatens to undermine donor confidence and jeopardizes the integrity of the charitable sector, whose services are indispensable to the world community.
A critical element of both the national and global campaign against terrorist financing is to designate those individuals and entities, including corrupted charitable organizations, that support terrorist activity. These designations prevent terrorist financing and advance our collective security in a number of ways, including by:
- ensuring that funds belonging to designated individuals and entities are no longer used to support terrorist activity by obliging all persons to freeze and report funds and other assets belonging to designated individuals and entities;
- preventing open fundraising by individuals and entities designated on account of their support for terrorist activity;
- shutting down pipelines through which terrorists raise and move money;
- informing third parties, who may be unwittingly financing terrorist activity, of their association with supporters of terrorism;
- deterring non-designated parties, who might otherwise be willing to finance terrorist activity; and
- forcing terrorists to use potentially more costly, less efficient and/or less reliable means of financing.
As of July 2005, the United States has designated 41 charities under E.O. 13224 and E.O. 12947 because of their support for terrorist activity. In addition, several FTOs, also designated under E.O. 13224, have operated under names that appear as potential fundraising fronts for terrorist activities. The United Nations and its member states have joined the United States in designating several of these charities, and the United States has received support from several countries in designating many other charities. The United States also has identified potential fundraising fronts for designated FTOs.
The charities and organizations listed below are part of the larger group of individuals and entities designated under E.O. 13224, E.O. 12947, or the AEDPA, and appearing on OFAC’s SDN List. This shortened list is intended to assist donors and charities in the United States and around the world in identifying those charities that have been designated due to their terrorist financing activity and entities potentially engaged in fundraising activities on behalf of designated FTOs. A short description of each designated charity and FTO follows this list. Although these descriptions are non-exhaustive, they are intended to assist in identifying those charities associated with terrorist financing, as well as those potential fundraising front organizations for FTOs.