Resource Center
Executive Orders
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/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’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.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx.
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.
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.
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