Charities Designated Under Executive Order 13224 and Executive Order 12947 and Foreign Terrorist Organizations Appearing as Potential Fundraising Front Organizations
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. Executive Orders 13224 and 12947
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).
Foreign Terrorist Organizations
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.
Country Sanction Programs
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/sanctions/.
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’s Specially Designated Nationals List (SDN List)
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.treas.gov/offices/enforcement/ofac/sdn/.
Addressing Terrorist Abuse of Charitable Organizations and Donors
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.
Source: United States Department of the Treasury
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