Protecting Charitable organizations
To view or print
the PDF content on this page, download the free
Adobe® Acrobat® Reader®.
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.treas.gov/offices/enforcement/ofac/sdn/.
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. ____________________________________________
Last Updated:
February 21, 2006
|