The Department of Treasury has made broad statements charging the U.S. charitable sector with being a significant source of terrorist financing and support. But evidence to support these claims has not been forthcoming. As a result, there has been significant disagreement between Treasury and the nonprofit sector on the extent and nature of the relationship between charities and terrorists. The issue is highlighted by the fact that Treasury’s Annex to the Guidelines only cites examples of alleged crimnal activity by foreign charities.

Using Treasury’s own data, it is clear that charities do not make up a significant portion of Specially Designated Global Terrorists (SDGTs). These figures suggest that U.S. based charities represent less than one percent of organizations with suspected ties to terrorists. Click here to see a list of U.S. charities designated, shut down or both by Treasury.
Table 1: Charities Designated as Specially Designated Global Terrorists (SDGT) by the U.S.
OFAC Category Assets
Total number of charities (foreign and U.S.) designated as SDGT 48
Number of foreign charities 40
Number of U.S. charities 8
Number of U.S. charities not designated, but shut down* 1
Total number of SDGTs** on Treasury’s SDN list 2900
Percentage of SDGTs that are U.S. charities >1%
*This refers to the Ohio-based KindHearts for Charitable Humanitarian Development, which has not be designated as an SDGT but its assets were frozen in February 2006.  Click here for more information about Kindhearts.
** approximate total as of  March 28, 2012, according to Treasury.
For more about the legal authority to designate a charity as a SDGT, see Summary of Economic Sanctions Laws and Regulations Authorizing Treasury to Shut Down Charities
Data from OFAC’s  2011 Terrorist Assets Report  [2] further raises questions about how much of a threat charities pose.
Table 2: Frozen Assets as of 2011
OFAC Category Reported Blocked Assets 2011 Reported Blocked Assets 2010 % of Reported Blocked Assets (2011)
Blocked Funds in the U.S. Relating to SDGT, SDT, and FTO Programs (including charitable organizations)***
$21,109,888 $17,638,123 5%
Blocked Funds Relating to State Sponsors of Terrorism in the U.S. (Cuba, Iran, Sudan & Syria)
$398,600,000 $309,500,000 95%
$419,709,888 $327,138,123 100%
***There is no publicly available information on how much of this amount includes charitable funds, or as a subset, how much includes funds from U.S. charities.  CSN estimates frozen charitable assets to be between $7-19.8 million. Click here for more information about Frozen Funds.