To designate an organization as a proscribed terrorist group, the United States government (USG) only needs to have a “reasonable suspicion” that it is providing “financial, material, or technological support for, or financial or other services to” a designated terrorist organization or “otherwise associate[ing]” with a designated organization. Consequences of designation include the seizing and freezing of all tangible and financial assets and significant civil and criminal penalties. Designated organizations may be Foreign Terrorist Organizations (FTO) listed by the Secretary of State, Specially Designated Terrorist (SDT) listed by the Department of Treasury, or Specially Designated Global Terrorists (SDGT) also listed by Treasury.

In October 2001, the PATRIOTatriot Act expanded the International Emergency Economic Powers Act (IEEPA) by allowing sanctions pending an investigation, so that “all the blocking effects of a designation, including freezing an organization’s assets indefinitely and criminalizing all its transactions, without designating it as a SDGT. Treasury only needs to assert that it is investigating whether the entity should be designated.” It also allows the court to review classified information in the agency record without notice to or knowledge of the blocked organization.

 Penalties for charities suspected of violating U.S. counterterrorism policies can be severe: organizations can be raided and destroyed, and officers sentenced to life imprisonment. If a charity’s assets and funds, including donations, are seized by the government, there is no process to release the charitable funds to programs that respect the intentions of the donors. 

This page contains information on various aspects of the Designation Process, including Due Process, Frozen Funds, and Listing and Delisting. Please see our Background page for details on the Material Support prohibition and how that underpins our work. 

Featured Resources

Summary of Economic Sanctions Laws and Regulations Authorizing Treasury to Shut Down Charities
Mind the Gap: When It Comes To Nonprofits the Tax Code and Sanctions Regime Are In Conflict
Model Policies for Fair Procedures for Listing and Delisting U.S. Charities
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