Introduction ~ EO 13224 background ~ IRRO parties designated Aug. 3, 2006

A Saudi-based entity posing as an Islamic charitable organization has had its Philippine and Indonesian branches, as well as a Saudi-based executive, subjected to U.S. sanctions for supporting terrorist activities.  In the case of the Philippine branch one informant is said to have indicated that a limited amount of the charity’s activities focused on legitimate projects while the bulk supported terrorist operations.  The executive reportedly is known as “the million dollar man” for his support of Islamist extremist groups.

Cracking down on terrorist finance and terrorist fundraising represents a significant, nonmilitary means of combating the asymmetric threat posed by terrorists, by analyzing and attempting to cut off resources necessary to terrorist operations.

Acting under Executive Order 13224, the U.S. Treasury Department on Aug. 3, 2006, sanctioned the Philippine and Indonesian branch offices of Saudi-based International Islamic Relief Organization (IIRO), as well as one of its executives, Abd Al Hamid Sulaiman Al-Mujil, for their connection with fundraising for al-Qaeda and al-Qaeda affiliates.  The action would freeze any assets under U.S. jurisdiction belonging to the designated parties and bar U.S. persons, including corporations, from doing business with the designated parties.

In this case, suspect activities have centered on al-Qaeda, the Abu Sayyaf Group (ASG) and Jemaah Islamiyah (JI).  The latter two entities are al Qaeda-affiliated terrorist groups in Southeast Asia that have already been designated under EO 13224. 

Like al-Qaeda, ASG and JI also are on the UN 1267 Committee list of parties associated with the Taliban, al-Qaeda and/or Osama bin-Laden (a list maintained under the authority of UN Security Council resolution 1267, passed in 1999).

The current EO 13224 list maintained by the Treasury Department may be viewed here; it is now a 104-page PDF, in fairly small print:

http://www.treasury.gov/offices/enforcement/ofac/programs/terror/terror.pdf

EO 13224 background

Parties subject to EO 13224 designation

EO 13224, effective Sept. 24, 2001, centers around the maintenance of a list of suspect entities and individuals set out in an annex of the order itself, supplemented by later designations made by either the secretary of state or the treasury secretary, with either acting only after consulting the other as well as the Attorney General.

Secretary of state designations focus on entities and individuals who have committed, or posing a significant risk of committing, terrorist acts threatening U.S. nationals, U.S. national security, the U.S. economy, or U.S. foreign policy.

Generally speaking, designations by the treasury secretary focus on persons providing financial material or technological support, or “financial or other services” to parties previously designated or otherwise subject to EO 13224, as well as their affiliates.  As such, they probe the tentacles of direct and indirect involvement with terrorist operations and planning, including services in support of basic logistics.

Impact of Designations

EO 13324, with respect to designated persons or entities:

• blocks U.S. assets of designated parties
• prohibits any U.S. person or person within the United States from dealing with a designated party, or conducting a transaction involving blocked assets (note that under the law U.S. “persons” include corporations)
• prohibits any transaction attempting to evade EO 13224
• prohibits conspiracies to violate EO 13224 (note that a conspiracy generally is a joint effort by two or more people to pursue a wrongful act with some overt action taken towards the unlawful goal)

IRRO parties designated on Aug. 3, 2006

The IIRO reportedly was established in 1978 and has branch offices in over 20 countries in Africa, Europe, Asia, and the Middle East.  The designation focuses on its branch offices in Indonesia and the Philippines, as well as Abd Al Hamid Sulaiman Al-Mujil, the executive director of IRRO’s eastern province branch office in Saudi Arabia (IIRO-EP).

Treasury indicates that IIRO’s Indonesian and Philippine branches have received support from IIRO-EP, in turn controlled by Al-Mujil, who is often responsible for authorizing payment transfers for IIRO Philippines (IIRO-Philippines) and IIRO Indonesia (IIRO-Indonesia).

In addition to al-Qaeda, additional terrorist groups relevant to the designation include the Abu Sayyaf Group (ASG) and Jemaah Islamiyah (JI), al-Qaeda-affiliated terrorist groups in Southeast Asia that themselves already have been designated under EO 13224.  ASG and JI are also on the UN 1267 Committee list of parties associated with the Taliban, al-Qaeda and/or Osama bin-Laden (a list maintained under the authority of UN Security Council resolution 1267, passed in 1999).

Al-Mujil

The Treasury Department states Al-Mujil has been called the "million dollar man" for assisting Islamic militant groups.

Treasury announced it has determined that Al-Mujil:

·        has a long history of providing support to terrorist organizations

·        has directly transferred donor funds to al-Qaeda

·        has provided direct financial assistance to ASG leaders, including Abdurajak Janjalani

·        is a major fundraiser for ASG and JI

·        in 2004 invited a Philippines-based JI supporter to Saudi Arabia under the cover of traveling for the hajj Muslim pilgrimage, and made plans to provide him with cash to carry to the Philippines to support organizations that included JI

·        was in Afghanistan in the late 1990s and personally knew Osama bin-Laden and al-Qaeda co-founder Abdallah Azzam

·        in the 1990s established a relationship with senior al-Qaeda operational planner Khalid Sheikh Muhammad

·        traveled continuously to meet with members of Bin Ladin's organization in Arab countries.

IRRO-Philippines

Treasury indicated that a former ASG member in the Philippines familiar with IIRO operations there reported that a limited amount of foreign IIRO funding goes towards legitimate activities and the rest is dedicated to terrorist operations.

Treasury announced it has determined that:

·        IRRO-Philippines is a source of funding for ASG and has served as an ASG liaison with other Islamic extremist groups

·        IRRO-Philippines branches were founded in the late 1980s or early 1990s by Muhammad Jamal Khalifah, Osama bin-Laden’s brother-in-law who also has been identified as a senior al-Qaeda member, of whom the IRRO-Philippines director, Abd al-Hadi Daguit, is a “trusted associate”

·        as IIRO-Philippines director, Khalifah maintained close connections with al-Qaeda and senior al-Qaeda supporters

·        as IIRO-Philippines director, Khalifah employed an ASG intelligence officer as an IIRO-Philippines provincial director

·        in the mid-1990s, Mahmud Abd Al-Jalil Afif, served as IIRO-Philippines director and used the organization to funnel money to terrorist groups including the ASG; Afif has been a major ASG supporter and was implicated in the 1992 assassination of Father Salvatore Carzeda

IRRO-Indonesia

Treasury states it has information that IRRO-Indonesia assists JI with recruitment, transportation, logistics, and safe-havens, and that the IIRO-Indonesia director has channeled money to two JI-affiliated foundations based in Indonesia.  It also indicates that IRRO-Indonesia allegedly financed training facilities for al-Qaeda associates.

Further reading:

“Executive Order 13224,” State Department Fact Sheet, Dec. 20, 2002, http://www.state.gov/s/ct/rls/fs/2002/16181.htm

“Executive Order on Terrorist Financing: Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten to Commit, or Support Terrorism,” text of Executive Order 13224, effective Sept. 24, 2001, http://www.whitehouse.gov/news/releases/2001/09/print/20010924-1.html

“Terrorism: What You Need to Know About U.S. Sanctions,” Treasury Department Office of Foreign Assets Control, http://www.treasury.gov/offices/enforcement/ofac/programs/terror/terror.pdf

“Terrorism and Financial Intelligence: Designation Lists And Financial Advisories,” Treasury Department,

http://treas.gov/offices/enforcement/lists/

“Terrorism and Financial Intelligence: Designations,” Treasury Department, http://treas.gov/offices/enforcement/designations.shtml

“Terrorism and Financial Intelligence: Publications and Legislation,” Treasury Department, http://treas.gov/offices/enforcement/publications/

“Treasury Designates Director, Branches of Charity Bankrolling Al Qaida Network,” Treasury Department news release hp-45, August 3, 2006, http://www.treas.gov/press/releases/hp45.htm

U.S. Department of the Treasury, Terrorism and Financial Intelligence home page,

http://treas.gov/offices/enforcement/

“US Treasury names suspected al Qaeda fund-raisers,” Reuters, Aug. 3, 2006, http://today.reuters.com/news/newsArticle.aspx?type=
topNews&storyID=2006-08-03T174419Z_01_N03440058
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