U.S.DepartmentofJustice

Office oftheInspectorGeneral

A Review of the Federal Bureau of Prisons’

Selection of Muslim Religious Services

Providers

Office of the Inspector General

April 2004
A REVIEW OF THE BUREAU OF PRISONS’ SELECTION OF 

MUSLIM RELIGIOUS SERVICES PROVIDERS

I. INTRODUCTION 

This report describes the Office of the Inspector General’s (OIG) 

review of the Federal Bureau of Prisons’ (BOP) policies and procedures for 

the selection of individuals who provide Islamic religious services to 

federal inmates. On March 10, 2003, Senator Charles Schumer wrote a 

letter to the OIG requesting that we examine the BOP’s process for 

selecting Muslim chaplains based on concerns that the BOP relies solely 

on two Islamic groups to endorse its Muslim chaplains, the Islamic 

Society of North America (ISNA) and the Graduate School of Islamic and 

Social Sciences (GSISS). Schumer noted that the ISNA and the GSISS 

allegedly are connected to terrorism and promote Wahhabism, which 

some consider an exclusionary and extreme form of Islam. In addition to 

Senator Schumer, Senators Jon Kyl and Dianne Feinstein expressed 

similar concerns and asked the OIG to examine these issues as they 

relate to the BOP. 

In response to these requests, we reviewed the recruitment, 

endorsement, selection, and supervision of Muslim chaplains and other 

Muslim religious services providers who work with BOP inmates. We 

also examined the roles the ISNA, the GSISS, and other organizations 

have in the endorsement of chaplain candidates. 

During this review, the OIG interviewed the BOP’s ten Muslim 

chaplains, the BOP detailee to the Federal Bureau of Investigation’s (FBI) 

National Joint Terrorism Task Force (NJTTF), and officials at BOP 

Headquarters who are responsible for religious services providers, 

including the Chief of the Chaplaincy Services Branch and the Senior 

Deputy Assistant Director (SDAD) of the Correctional Programs Division. 

We also interviewed FBI counterterrorism officials and representatives of 

the U.S. Commission on International Religious Freedom at the U.S. 

Department of State (Commission). 

In addition, we visited low, medium, and high security BOP 

institutions, where we interviewed prison officials, examined the 

chaplaincy programs, and observed Muslim religious services. These 

facilities included the Federal Correctional Institution (FCI) in Fort Dix, 

New Jersey; the FCI in Fairton, New Jersey; the United States 

Penitentiary (USP) in Allenwood, Pennsylvania; and the USP in 

Lewisburg, Pennsylvania. We also met with analysts specializing in 

Middle East affairs at the Congressional Research Service, including the 

author of the December 2003 report, The Islamic Traditions of 
Wahhabism and Salafiyya, and representatives of the Department of 

Defense (DOD) OIG regarding its examination of the DOD’s chaplaincy 

selection process. 

This report describes the results of our review. It first provides a 

brief background on Islam, Wahhabism, and the BOP’s provision of 

religious services to inmates. It then describes the BOP’s selection of 

Muslim chaplains and other religious services providers, including their 

recruitment, application process, and security screening. We next 

discuss BOP endorsing organizations, their relationships with the BOP, 

and the steps the BOP and FBI have taken to assess whether these 

organizations are extremist or affiliated with terrorists. The report then 

examines issues related to the supervision of religious services providers 

once they are allowed into BOP correctional institutions. Finally, the 

report provides our analysis and recommendations. 

In sum, our review revealed deficiencies in how the BOP selects 

and supervises Muslim religious services providers. These problems 

include: 

• the BOP typically does not examine the doctrinal beliefs of 

applicants for religious service positions to determine whether 

those beliefs are inconsistent with BOP security policies; 

• the BOP and the FBI have not adequately exchanged information 

regarding the BOP’s Muslim endorsing organizations; 

• because the BOP currently has no national Islamic organizations 

willing or able to provide endorsements for its Muslim chaplain 

candidates, the BOP’s hiring of new Muslim chaplains is effectively 

frozen, resulting in a shortage of Muslim chaplains within the 

BOP;1 

• the BOP does not effectively use the expertise of its current Muslim 

chaplains to screen, recruit, and supervise Muslim religious service 

providers; 

 1 With regard to the ISNA and the GSISS, the BOP currently is not accepting 

endorsements from the ISNA, and the GSISS has never provided endorsements to the 

BOP. Our review did not independently examine these organizations’ sources of funding

or whether they have terrorism-related connections. This type of counterterrorism 

review would be conducted by the FBI. However, the OIG has prepared a classified 

addendum to this report that provides more information about organizations and 

individuals that were determined by the FBI to be “of interest.” This classified

addendum has been given to members of Congress and BOP officials. 

2
• once contractors and certain volunteers gain access to BOP 

facilities, ample opportunity exists for them to deliver inappropriate 

and extremist messages without supervision from BOP staff 

members; 

• BOP inmates often lead Islamic religious services, subject only to 

intermittent supervision from BOP staff members, which enhances 

the likelihood that inappropriate content can be delivered to 

inmates; and 

• within the BOP’s chapels, significant variations exist in the level of 

supervision provided by correctional officers. 

II. BACKGROUND 

A. Islam

Islam is a monotheistic faith that arose in the early 7th century in 

the Arabian city of Mecca. Adherents of the Islamic faith are called 

Muslims and follow the teachings of Muhammad ibn Abdallah. Although 

the origins of Islam were in the Middle East, today the majority of 

Muslims are not Middle Eastern. 

Over time, divergent interpretations of Islam evolved and led to the 

development of differing Islamic sects and doctrines. The current major 

Islamic denominations include Sunni Islam, constituting approximately 

85 percent of all Muslims; Shiite Islam, practiced largely in Iraq and Iran; 

and Sufism, a “mystical” form of Sunni Islam. There is no ecclesiastical 

hierarchy in Islam to resolve disputes between sects or determine whose 

teaching is accurate. 

Wahhabism is a form of Sunni Islam. It is practiced all over the 

world and is the predominant religion in Saudi Arabia. Wahhabism has 

many connotations and means different things to different people. It 

generally refers to a movement that seeks to purify the Islamic religion of 

any innovations or practices that deviate from the 7th century teachings 

of the Prophet Muhammad, as interpreted by Muhammad ibn Abd 

al-Wahhab, who lived in the 18th century in Saudi Arabia, Iraq, and 

Iran.2 

Most Muslims who adhere to Wahhabism refer to themselves as 

“Salafis,” meaning “Unitarians,” because al-Wahhab emphasized the 

transcendental unity of God. The term “Salafi” literally means “one who 

 2 See Febe Armanios, The Islamic Traditions of Wahhabism and Salafiyya, 

Congressional Research Service, Dec. 22, 2003, at 1. 

3
follows the Prophet Muhammad and his companions,” and also can be 

used to describe all Muslims, not just Wahhabis. According to one 

Islamic scholar, “[w]ahhabism, in its present form, is a particular 

orientation within Salafism. . . . It is fair to say that all puritanical groups 

in the Muslim world are Salafi in orientation but not necessarily 

Wahhabi.”3 

Fifteen of the 19 September 11 hijackers were from Saudi Arabia, 

and all of them are believed to have been Wahhabis. In the United 

States, Wahhabism has been equated with radicalism and terrorism in 

some newspaper articles, books, and public discourse. For instance, in 

his 2002 book, The Two Faces of Islam, journalist Stephen Schwartz

wrote that, “Wahhabism exalts and promotes death in every element of 

its existence: the suicide of its adherents, mass murder as a weapon 

against civilization, and above all the suffocation of the mercy embodied 

in Islam.”4 

However, not all experts agree that “Wahhabism” and “Salafism” 

are inherently synonymous with violence, terrorism, or radicalism. For 

example, FBI counterterrorism officials told us that Wahhabism is not 

inherently violent or terroristic, but has been manipulated for violent or 

terroristic ends. In addition, representatives from the Commission noted 

to us that many Wahhabis/Salafis throughout the world are doctrinally 

rigid, but peaceful. 

The BOP’s ten Muslim chaplains, representatives from the 

Commission, and counterterrorism experts at the FBI also stated that 

radical Islam can be found in many different sects of Islam, not just in 

Wahhabism/Salafism. Several of the Muslim chaplains said that 

prominent Wahhabis have publicly condemned terrorism, suicide 

bombers, and Usama Bin Laden. Similarly, representatives from the 

Commission said that Islamic extremism is not so much the result of a 

particular doctrine as it is the result of an individual’s school of learning 

or associations with groups that espouse hate, extremism, and violence. 

In addition, FBI counterterrorism experts and representatives from the 

Commission stated that other Islamic sects, such as extreme Shiite 

Islam, could be just as radical and as much of a terrorism threat as 

extreme Wahhabism/Salafism. 

 3 See Khaled M. Abou El Fadl, And God Knows the Soldiers: The Authoritative 

and Authoritarian in Islamic Discourses 5 n. 5 (2001).

4 See Stephen Schwartz, The Two Faces of Islam 180 (2002).

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B. Islam in Federal Prisons 

1. Number of Muslim Inmates, Chaplains, Contractors 

and Volunteers 

The BOP houses approximately 150,000 inmates in 105 BOP 

facilities nationwide.5 According to the Chief of the BOP’s Chaplaincy 

Services Branch, approximately 9,000 inmates, or about 6 percent of the 

inmate population, seek Islamic religious services. While Muslim 

inmates are not required to report which sect of Islam they identify with, 

inmate self-reporting indicates that Muslim inmates generally can be 

classified into four groups: Sunni, Shiite, Nation of Islam, and Moor 

Science Temple of America. Approximately 85 percent of BOP inmates 

who identify themselves as Muslim are Sunni or Nation of Islam. In 

contrast, less than 1 percent of the Muslim inmates – many of whom are 

from Middle Eastern countries – are Shiite. The Nation of Islam is a 

U.S.-based group that follows the teachings of Elijah Muhammad. The 

Moor Science Temple of America is a very small group and, according to 

the SDAD of the BOP’s Correctional Programs Division, not very active in 

BOP institutions. 

The BOP provides Muslim inmates with religious services through 

BOP chaplains, contractors, and volunteers. Since 2001, 10 BOP 

chaplains, or a little more than 4 percent of the BOP’s total chaplains, 

are Muslim. According to the BOP, it currently is experiencing a “critical 

shortage” of Muslim chaplains. The Chief of the Chaplaincy Services 

Branch said a critical shortage of chaplains exists when there is 1 

chaplain of a certain faith for every 700 inmates of that faith BOP-wide. 

Currently, there is 1 Muslim chaplain for every 900 Muslim inmates. 

When a Muslim chaplain is not available in a prison, Muslim inmates’ 

religious services are provided by Muslim volunteers, contractors, or 

inmates. 

 Muslim contractors are compensated by the BOP to provide 

certain Islamic services to inmates. Volunteers are not compensated by 

the BOP and are classified into two groups: Level 1 and Level 2 

volunteers. Level 1 volunteers are authorized to enter a particular BOP 

institution less than four times a year and must be supervised by a BOP 

staff member at all times. Level 2 volunteers have greater access to 

institutions and, according to the BOP, need only be supervised 

intermittently because they have completed more thorough background 

investigations than Level 1 volunteers. As of September 6, 2003, there 

were 56 Muslim contractors and 108 Muslim Level 2 volunteers 

 5 These numbers do not include contract facilities or halfway houses, which are

responsible for providing religious services to the BOP inmates housed there. 

5
throughout the BOP. BOP officials could not provide us with the 

number of Level 1 volunteers. 

2. Radical Islam in Prisons 

Radicalization of Islamic inmates is not a recent phenomenon.6 

Prison systems throughout the world have been and continue to be 

breeding grounds for radicalism, recruiting grounds for extremist 

movements, and facilities for the planning and training of radical 

activities.7 For example, radicalization has been a serious concern for 

decades in France, where more than half of the penitentiary inmates are 

Muslim. According to some accounts, thousands of French inmates have 

been indoctrinated in the principles of a holy war against “the Western 

powers and the Jews who manipulate them,” in the words of one 

pamphlet circulating in French prisons.8 It also has been reported that 

radicalized inmates have built an extensive and highly organized 

“terrorist university” in French prisons by using smuggled tapes, books, 

and pamphlets to spread anti-Western and anti-Semitic messages.9 

Concerns regarding the radicalization of Muslim inmates in prisons 

were heightened after former inmates Richard Reid and Jose Padilla were 

arrested for allegedly attempting to commit terrorist acts against the 

United States. Reid, convicted for attempting to blow up an American 

Airlines flight from Paris to Miami with explosives in his shoes, had 

converted to Islam in a British prison and left the prison with radical 

leanings. British officials suspect he was radicalized in part by extreme 

Islamic clerics who visited and preached at the prison. Jose Padilla, 

arrested for attempting to detonate a dirty bomb in the United States, 

converted to Islam after serving time in a Broward County, Florida, jail 

where authorities suspect his Islamic radicalization began. 

 6 Radicalization is distinguishable from terrorist recruiting. In this report, we

use “radicalization” to mean the process by which inmates who do not invite or plan 

overt terrorist acts adopt extreme views, including beliefs that violent measures need to

be taken for political or religious purposes. “Terrorist recruitment,” on the other hand, 

is used to mean the solicitation of individuals to commit terrorist acts or engage in 

behavior for a terrorism purpose. These definitions are derived in part from definitions 

provided to us by the BOP detailee to the FBI’s NJTTF. 

7 See Gregory R. Copley, The Intelligence and Management Challenge: Handling 

Radical, Terrorist and Politicized Prisoners, Defense and Foreign Affairs Strategic Policy, 

Jan. 2002, at 10.

8 See, e.g., Frank Viviano, French Prisons: Extremist Training Grounds, 

San Francisco Chron., Nov. 1 2001, at A4. 

9 Id. 

6
According to the FBI, it is likely that terrorist groups such as 

al-Qaeda will attempt to radicalize and recruit inmates in the United 

States.10 FBI counterterrorism officials stated that inmates are logical 

targets for terrorist recruitment because they may be predisposed to 

violence, feel disenfranchised from society, desire power and influence, 

seek revenge against those who incarcerated them, be hostile towards 

authority and the United States, or cling to a radical or extremist Islamic 

“family.” In addition, prisons have large populations of non-Arab Muslim 

inmates who are increasingly valuable for terrorism recruitment, since 

they may not receive the same level of scrutiny as Middle Eastern 

Muslims. Moreover, an FBI counterterrorism analyst told us that the 

immense wealth associated with extreme Wahhabism/Salafism makes 

the religion appealing to inmates who are seeking financial support and 

assistance after they leave prison. 

Inmates can be radicalized in many ways, including through the 

delivery of anti-U.S. sermons, exposure to other radical inmates, or the 

distribution of extremist literature. According to an Ohio state 

correctional official, radicalization has led some inmates in state prisons 

to become members of terrorist groups, including the Islamic-militant 

group Hizballah and the Irish Republican Army.11 While radicalization 

does not necessarily lead inmates to join terrorist organizations, it can, 

upon their release, lead them to attend and serve in radical mosques or 

obtain religious education overseas in locations that provide further 

opportunities for radicalization and terrorist recruitment. 

The SDAD of the BOP’s Correctional Programs Division said that 

he does not believe there is widespread terrorist radicalization or 

recruiting occurring in BOP facilities, but he recognized that many 

inmates are vulnerable to radicalization and terrorist recruitment. FBI 

counterterrorism officials stated that they believe some BOP inmates are 

being radicalized because they are leaving BOP facilities with extreme 

Islamist views. While these officials said they were unsure precisely how 

radicalization is occurring, they believe that some Muslim contractors 

and volunteers are radicalizing inmates in prisons in the United States. 

The ten BOP Muslim chaplains we interviewed said they have not 

witnessed inmates being radicalized by contractors or volunteers. The 

BOP staff and managers we interviewed also asserted that staff 

 10 John S. Pistole, Assistant Director of the FBI Counterterrorism Division, 

Statement for the Record Before the Subcommittee on Terrorism, Technology, and 

Homeland Security of the Senate Judiciary Committee (October 14, 2003). 

11 See statements by Phil Vermillion, the security threat group investigator for 

Ohio’s state prison system, reported by The Associated Press, FBI Agent Warns Prison

Officials of Al Qaeda Recruitment (Sept. 20, 2003). 

7
chaplains, contractors, and volunteers were not the cause of inmate 

radicalization. The BOP staff said they were confident that if a chaplain, 

contractor, or volunteer was delivering inappropriate messages, the 

prison would soon learn about it and the individual would be removed 

from his or her position. 

The BOP Muslim chaplains stated that some inmates are 

radicalized in prison by other inmates. Numerous other BOP staff 

members also told us that the real threat of radicalization comes from 

inmates, not chaplains, contractors, or volunteers. One Muslim chaplain 

stated that at his prison some Islamic extremist inmates told other 

inmates that if they were going to convert to Islam, they had to overthrow 

the government because “Muslims aren’t cowards.” Other chaplains told 

us that convicted terrorists from the 1993 World Trade Center bombing 

were put into their prisons’ general population where they radicalized 

inmates and told them that terrorism was part of Islam. Another 

chaplain said that he has observed some inmates from foreign countries 

politicize Islam and radicalize inmates, who in turn radicalize more 

inmates when they transfer to other prisons. 

In addition to terrorist radicalization and recruitment, the Muslim 

chaplains noted a version of Islam they call “Prison Islam.” They 

explained that Prison Islam, which is unique to the prison environment, 

results when inmates follow Islam without direction or analysis – inmates 

distort Islam to encompass prison values such as gangs and loyalty to 

other inmates. The chaplains said they frequently have to oppose Prison 

Islam in their institutions because it threatens prison security. 

The Muslim chaplains said that Prison Islam especially thrives in 

institutions that do not have a staff chaplain, contractor, or volunteer to 

lead inmates’ Islamic services such as the Juma prayer, which is the 

obligatory, group prayer held midday on Fridays. According to the 

Muslim chaplains, in these institutions Muslim inmates often lead Juma 

services, and inmates who promote Prison Islam or engage in 

radicalization have the opportunity to teach and lead other inmates 

without the countervailing influence of a mainstream Muslim chaplain, 

contractor, or volunteer. In fact, the growth of Islamic radicalism in 

French prisons has been attributed in part to the control that inmates 

exercise over most of the institutions’ religious practices.12

The BOP provides official guidance to institutions’ chaplains 

regarding inmate-led services. The BOP’s Technical Resource Manual 

014.01, issued in June 1995, states that: 

 12 See Frank Viviano, French Prisons: Extremist Training Grounds, San Francisco 

Chron., Nov. 1 2001, at A4. 

8
Normally inmates are not permitted to lead religious 

programs. When an inmate faith group meets which is 

different from the Chaplains’ own, and when there is no 

community representative available to lead the group on a 

volunteer or contractual basis, inmates may conduct or 

lead these programs only under the supervision of the 

Chaplain. This supervision entails eye contact with the 

group and at least periodic presence in the program area 

by the Chaplain.13 

While BOP officials acknowledged to us that religious services led 

by inmates are a security concern, they said that the lack of Muslim 

chaplains, contractors, and volunteers makes inmate-led services a 

necessity in some BOP facilities. The Chief of the Chaplaincy Services 

Branch suggested that the BOP could reduce concerns about inmate-led 

services by having inmates read sermons written by one of the BOP 

Muslim chaplains or by a Muslim outside of the prison and screened by 

the chaplaincy. 

With respect to Wahhabism/Salafism, the BOP chaplains said they 

believed that any chaplain, contractor, or volunteer who identified 

himself as a Wahhabi/Salafi would be too narrow-minded and sectarian 

to be able to teach in a pluralistic, prison environment.14 They also said 

that strict Wahhabism would not survive in prisons because it is too 

exclusionary to appeal to the inmates.15 In addition, they stated that 

pure Wahhabism poses a security threat to the prisons because it does 

not tolerate religious pluralism. 

C. Provision of Religious Services in the BOP 

1. Chaplaincy Services Branch 

The BOP Central Office is composed of eight divisions. One of the 

divisions, the Correctional Programs Division, is responsible for security 

 13 Technical Reference Manuals provide guidelines, optional assistance, best 

practices, and “how-to” information that may be needed or useful to accomplish the

objectives or requirements of Program Statements. They are not “directives” or “policy,” 

but technical and instructional in nature. 

14 The chaplains clarified that because “Wahhabi” means different things to 

different people, a person who is labeled by others as a Wahhabi might not be narrowminded and sectarian. However, they agreed that if a Muslim identifies himself as a

Wahhabi, then he would hold views contrary to the BOP’s position of religious 

pluralism.

15 The chaplains stated that inmates who identify themselves as Wahhabis or 

Salafis generally espouse Prison Islam rather than true Wahhabism or Salafism. 

9
and custody issues, providing services to inmates, and developing policy 

in these areas.16 The Correctional Programs Division coordinates 

inmates’ religious services through the Chaplaincy Services Branch. 

According to the Chief of the Chaplaincy Services Branch, the provision 

of religious services to inmates is required by law to accommodate 

inmates’ free exercise of religion. She stated that religious services are 

essential to the security and orderly running of BOP institutions because 

it provides inmates with direction, guidance, and a sense of purpose, and 

helps them to be productive, disciplined, and compliant. 

The Chaplaincy Services Branch is required to provide 

opportunities for inmates to pursue individual religious beliefs and 

practices in accordance with law, federal regulations, and BOP policy. 

The Chaplaincy Services Branch’s central office is located at BOP 

Headquarters. It provides staffing, training, policy, procedures, and 

technical assistance to regional and field chaplains. However, it does not 

supervise regional or field chaplains and has only advisory authority over 

BOP regional and field decisions, except when governed by BOP policy, 

procedures, or reference manuals. 

The BOP has one Regional Chaplain in each of its six regions. The 

regional chaplains oversee one to five chaplains in each facility in their 

regions. Within each institution, a supervisory chaplain manages the 

institution’s chaplaincy staff. As of March 5, 2004, there were 

approximately 240 chaplains BOP-wide. 

 Under prevailing federal case law, inmates are not entitled to a 

chaplain of their faith group, denomination, or sect.17 As a result, all 

BOP chaplains, regardless of their own faiths, are expected to minister to 

inmates of all faith traditions, including those who have no faith 

tradition. The Chief of the Chaplaincy Services Branch stated that 

chaplains must be willing to accommodate the free exercise of religion for 

all inmates, which means they must respect, appreciate, and understand 

the faith traditions of the inmates, and they must actively provide 

inmates opportunities to mature spiritually within their own faith 

traditions. 

Chaplains are supposed to plan, direct, and supervise all aspects 

of the institutions’ religious programs and have access to all areas of the 

institutions to minister to inmates and staff. They are responsible for 

leading worship services, providing religious education, offering pastoral 

counseling, conducting crisis intervention, supervising religious services 

 16 An organization chart of the BOP is attached to this report as Appendix A. 

17 See Cruz v. Beto, 405 U.S. 319, 322 n. 2 (1972); Weir v. Nix, 114 F.3d 817,

820 (8th Cir. 1997); Blair-Bey v. Nix, 963 F.2d 162, 163-64 (8th Cir. 1992).

10
and meetings, enabling faith groups to observe holy days and other 

religious practices, and accommodating the legitimate religious needs of 

inmates. 

In addition, chaplains oversee religious contractors and volunteers. 

Contractors and volunteers are brought into institutions to perform a 

specific religious service or function, such as a worship service, group 

prayer, scripture study, or religious lecture. 

BOP staff repeatedly emphasized to us that the provision of 

religious services in its institutions is important to the maintenance of 

security in the facility. For example, according to a lieutenant at the FCI 

in Fort Dix, New Jersey, which has the largest inmate population of any 

BOP facility, the religious services department “absolutely plays an 

important role in maintaining security.” A BOP chaplain also stated to 

us that religious services “diffuse a lot of frustrations and anxieties and 

angers; it provides inmates with internal controls that otherwise they 

would not have.” 

2. Duties Performed by Muslim Chaplains, 

Contractors, and Volunteers 

Muslim chaplains are responsible for providing faith-specific 

services for Muslim inmates, including Koranic studies, holy day 

observances, and presiding at Juma prayer. Muslim chaplains also are 

responsible for pastoral counseling and administrative duties. While 

they are not required to perform sacraments, rituals, or worship services 

for other faith groups, they are required to counsel inmates of all faiths 

and supervise the contractors, volunteers, or inmates who lead the 

religious services for other faith groups. See BOP’s “Position Description: 

Chaplain” and BOP Program Statements 3939.07 and 5360.08. 

Muslim contractors also lead Koranic studies, preside at Juma 

prayers, and provide counseling to Muslim inmates. The contractors 

provide services on a “per session” basis. They can offer sessions on a 

weekly basis or as infrequently as once a quarter, depending on the 

needs of the institution. Inmates must register in advance to participate 

in the contractor-led sessions. Contractors do not have general access to 

inmates and cannot leave the area to which they are assigned without 

notifying a staff member. 

Muslim volunteers offer many of the same services as contractors, 

but they are not paid and are not required to come into the institution for 

a certain number of sessions. Volunteers’ services include providing 

occasional seminars, presiding over Juma prayers, leading Koranic 

studies or scholastic discussions, and serving as guest speakers for 

11
Ramadan or other religious observances. As with contractors, inmates 

must register in advance to participate in the sessions offered by 

volunteers. Volunteers do not have general access to inmates and 

cannot leave the area to which they are assigned without being escorted 

or notifying a staff member, depending on whether they are Level 1 or 

Level 2 volunteers.18

According to the Chief of the Chaplaincy Services Branch, Muslim 

chaplains, contractors, and volunteers all are responsible for presenting 

the basic, mainstream principles of Islam and correcting misinformed or 

misled Muslim inmates. They also are responsible for ensuring the 

security of the institution, which includes addressing and countering 

Prison Islam and inmates’ radicalization efforts. One of the BOP Muslim 

chaplains we interviewed asserted that contractors and volunteers have a 

stabilizing effect on Muslim inmates because they bring fresh opinions 

and societal experiences into the institutions, and inmates do not see 

them as part of the “police” like they see the chaplains. He said that 

fewer contractors and volunteers in the prisons make inmates feel more 

isolated and alienated, and leads to the germination of unsophisticated 

Islam, including radicalization and Prison Islam. Other chaplains also 

said that volunteers and contractors help to control radicalization, 

prevent misconceptions about Islam, and keep inmates from delivering 

their own sermons, taking their own interpretations of Islam, and 

controlling religious activities. 

D. BOP Policies Regarding the Provision of Religious 

Services 

The BOP has implemented various policies and procedures 

regarding religious practices, activities, and services in its institutions. 

These policies and procedures apply to all religious chaplains, 

contractors, and volunteers, regardless of faith. According to the Chief of 

the Chaplaincy Services Branch, the policies and procedures are 

intended to guarantee inmates’ free exercise of religion while ensuring 

the security of the institutions. She said that Muslim chaplains are 

supposed to minister to inmates of all faiths and accommodate all 

Islamic denominations, and that all Islamic religious services providers 

are prohibited from endorsing one sect over others, teaching sect-specific 

doctrine, or imposing their own ideas on the inmates. 

 18 As described on page 5, the difference between Level 1 and Level 2 volunteers 

is that Level 1 volunteers are authorized to enter a particular BOP institution less than

four times a year and must be supervised by a BOP staff member at all times, while

Level 2 volunteers have greater access to institutions and, according to BOP personnel, 

need only be supervised intermittently. 

12
The SDAD of the Correctional Programs Division stated that 

inmates are allowed to practice religions with extreme doctrinal views as 

long as their religious teachings do not violate the law or BOP policy. 

According to the SDAD, the main security policy guiding the provision of 

religious services in the BOP is that religious groups and religious 

services providers cannot: 1) advocate violence; 2) make statements 

against the United States, including statements that support or condone 

terrorism; or 3) discriminate against other inmates or exclude them from 

their services, whether based on race, religion, or other discriminatory 

factors. See BOP Program Statements 3420.09, 3730.04, and 5360.08. 

In addition to these restrictions, BOP Program Statement (P.S.) 

5360.08, Religious Beliefs and Practices, explicitly prohibits the following 

religious practices and activities: 

• Proselytizing, 

• Profanity; 

• Consumption of alcohol; 

• Paramilitary exercises; 

• Self-defense training; 

• Animal sacrifice; 

• Casting of spells or curses; 

• Nudity; 

• Sexual acts; 

• Self-Mutilation; 

• Use or display of weapons; 

• Ingestion of illegal substances; and 

• Encryption. 

The SDAD said that if a group’s practices or doctrine violate any of 

these policies or procedures, the group is banned from BOP facilities. 

Similarly, if a religious services provider violates any of these policies or 

procedures, the BOP will consider dismissing the provider from the BOP. 

III. SELECTION OF MUSLIM CHAPLAINS, CONTRACTORS, AND 

VOLUNTEERS 

A. How Personnel Needs Are Identified 

According to the BOP, personnel needs for all religious services 

providers, including Muslim chaplains, contractors, and volunteers, are 

identified based on what institutions need to accommodate inmates’ 

religious beliefs and practices, as allowed under the First Amendment, 

the Religious Freedom Restoration Act (RFRA), the Code of Federal 

Regulations, other Public Laws, and BOP policy. 

13
The need for BOP chaplains also is determined in part by the 

chaplain-inmate ratio BOP-wide. Because BOP chaplains are hired to 

accommodate the religious beliefs and practices of all inmates, the BOP 

considers qualified applicants of all faiths for all chaplain vacancies. 

However, when there is a critical shortage of chaplains of a certain 

religion, the Chief of the Chaplaincy Services Branch said that the BOP is 

more likely to select qualified chaplain candidates of that religion rather 

than candidates of other religions. Moreover, whenever possible, the 

BOP does not place chaplains of the same faith in the same institution. 

See BOP’s “Qualifications and Job Requirements for Chaplaincy.” 

The BOP does not attempt to match chaplains of particular 

denominations or sects to particular institutions. For example, even if a 

particular prison has a large Sufi Muslim inmate population, the BOP 

does not attempt to place a Sufi Muslim chaplain in that prison. 

According to the Chief of the Chaplaincy Services Branch, matching 

chaplains’ denominations or sects to those of the inmates requires the 

BOP to discriminate in hiring based on candidates’ religion and doctrinal 

beliefs. Currently, the BOP does not require chaplain candidates to 

report their denominations or sects because the BOP considers it 

irrelevant to job performance. In addition, according to the Chief of the 

Chaplaincy Services Branch, denomination or sect matching would 

potentially undermine the BOP’s expectation that chaplains minister 

pluralistically, focus on the basic principles of their faiths, and not 

impose their denomination’s or sect’s doctrinal beliefs on inmates. Under 

prevailing case law, the BOP’s refusal to provide a religious leader for 

every sect in a prison does not violate the inmates’ constitutional right to 

the free exercise of religion.19

Chaplain vacancies are determined by each institution, but the 

BOP does not hire chaplains for specific sites. For example, the BOP 

does not announce a chaplain vacancy in the USP in Atlanta, Georgia. 

Instead, it hires chaplains and then places them where needed 

throughout the BOP. 

By contrast, contractors and volunteers are recruited and selected 

by individual institutions to address the particular needs of inmates in 

that institution. The BOP attempts to accommodate inmates’ religious 

needs by providing them sessions with a contractor or volunteer of that 

faith. For example, a prison with a large Shiite Muslim population can 

determine it needs a Shiite contractor or volunteer, rather than a Muslim 

contractor or volunteer from another sect. However, this is not currently 

 19 See Cruz, 405 U.S. at 322 n. 2; Weir, 114 F.3d 817; Blair-Bey, 963 F.2d at

163-64. 

14
being done in the BOP partly because, according to the Chief of the 

Chaplaincy Services Branch, the BOP has difficulty determining the 

denominations or sects of inmates. 

B. How Candidates Are Recruited and Selected 

1. Recruitment 

The BOP does not advertise for chaplaincy positions by specific 

faith groups. Instead, BOP chaplain vacancies are announced 

continuously on the BOP website, the U.S. Office of Personnel 

Management (OPM) website, and websites such as 

http://www.usajobs.com. The BOP also advertises chaplaincy vacancies 

with religious organizations and recruits at job fairs, theology speaking 

engagements, and conferences. Some chaplain candidates have applied 

to work for the BOP after serving as contractors in the institutions. 

Our review determined that each of the current BOP Muslim 

chaplains was recruited or referred by another BOP Muslim chaplain. 

According to the Chief of the Chaplaincy Services Branch, Muslim 

chaplains are the BOP’s most effective and reliable resource for recruiting 

qualified Muslim chaplain candidates. However, the BOP Muslim 

chaplains we interviewed stated that because BOP management had not 

adjusted the chaplains’ schedules to account for recruiting 

responsibilities, they were unable to dedicate time to recruiting new 

chaplain candidates even though they wanted to. 

In addition to recruiting other chaplains, BOP Muslim chaplains 

have recruited Muslim contractors and volunteers. Muslim contractors 

also are recruited through the BOP website, Muslim organizations’ 

websites, the government’s contracting website (www.fedbizopps.gov), 

and newspaper advertisements. Similarly, chaplains and volunteer 

coordinators recruit Muslim volunteers locally. The Chief of the 

Chaplaincy Services Branch said that when an institution determines 

that it needs a Muslim contractor or volunteer, it often will contact a 

local mosque or Islamic center for recommendations. One Muslim 

chaplain said that this was the best way to find qualified, reliable 

contractors and volunteers. The Chief of the Chaplaincy Services Branch 

also said that BOP staff might contact another BOP prison with a strong 

Muslim religious program to seek assistance from chaplains, contractors, 

or volunteers in that program. 

According to the Chief of the Chaplaincy Services Branch, the BOP 

has had difficulty meeting institutions’ demand for Muslim chaplains, in 

part because it is difficult to find candidates who meet all the personal, 

15
academic, and professional requirements to be a chaplain.20 As a result, 

the BOP currently has three Muslim chaplains less than it needs to 

overcome its critical shortage of Muslim chaplains.21 

The Chief of the Chaplaincy Services Branch also stated that the 

BOP does not have enough Muslim contractors and volunteers to provide 

Islamic services for all Muslim inmates. According to BOP officials, there 

are several reasons why the BOP has had difficulty recruiting and 

maintaining Muslim contractors and volunteers. First, the remote 

locations of many BOP institutions makes it difficult for contractors and 

volunteers to get to those institutions. Second, the BOP does not have a 

program or strategy for recruiting Muslim contractors and volunteers. 

The BOP Muslim chaplains suggested that the BOP should make a 

greater effort to reach out to Muslim organizations and communities to 

develop local contacts and encourage Muslims to serve in BOP 

institutions. They said that currently the Chief of the Chaplaincy 

Services Branch is the only person in the BOP who is reaching out to 

Muslims. Third, according to the BOP Muslim chaplains, the BOP does 

not provide its Muslim chaplains adequate time to recruit contractors 

and volunteers, even though they have strong connections to the Muslim 

community. Fourth, one Muslim chaplain noted that the BOP does not 

provide volunteers incentives to work in the prisons, such as 

reimbursement for gasoline when they visit rural facilities. Fifth, 

according to the Muslim chaplains, recruitment of Muslim volunteers has 

slowed after the September 11 terrorist attacks because Muslims fear 

they will be scrutinized or investigated if they become involved with the 

government. Sixth, according to the Chief of the Chaplaincy Services 

Branch, the Islamic community does not have the programs or precedent 

for prison ministry in the United States that other religions have. 

Recruitment difficulties present a special problem because the BOP 

needs many Muslim contractors and volunteers to lead Juma prayers 

and other Islamic services that must occur at the same time on the same 

days (i.e., Juma prayers must be held shortly after 12:30 p.m. on 

Fridays). One chaplain, contractor, or volunteer can only provide these 

services in person to one group of inmates at the appointed time. For 

example, in an institution that has four facilities, a Muslim chaplain, 

contractor, or volunteer is needed in each facility at the same time on 

Fridays to provide Juma prayer. If there is only one chaplain, contractor, 

 20 These requirements are discussed below in section III (B)(2), “Application 

Process.” 

21 The BOP has determined a critical shortage of chaplains exists when there is 1 

chaplain of a certain faith for every 700 inmates of that faith BOP-wide. Using this 

standard, the BOP needs 13 Muslim chaplains to eliminate its critical shortage. 

Currently, it has only ten Muslim chaplains and approximately 9,000 Muslim inmates.

16
or volunteer available, inmates in three of the facilities either will lead 

themselves in the prayer or will not receive the prayer service that day. 

This shortage of Muslim chaplains, contractors, and volunteers means 

inmates are left to lead and direct each other in Islam, which may affect 

prison security because extremist inmates could use these services to 

radicalize and recruit other inmates. 

2. Application Process 

a. Muslim Chaplains 

In order to be considered for a chaplain position in the BOP, 

candidates must meet certain personal and professional requirements.22

First, the applicant must be a citizen or resident of the 

United States or a country that has diplomatic relations or treaties with 

the United States. Second, the applicant ordinarily must be younger 

than 37 to be appointed to a BOP position. However, the Department of 

Justice (DOJ) has waived this age requirement for Muslim chaplain 

applicants because of the critical shortage of Muslim chaplains in the 

BOP. See 5 U.S.C. § 3307. Third, applicants must provide adequate 

documentation of their religious and ministerial role within their religious 

community. This documentation is required in lieu of formal ordination 

or recognition by ecclesiastical institutes, which do not exist in Islam. 

Fourth, applicants must pass a physical examination and Physical 

Abilities Test, which are designed to measure the physical requirements 

necessary to perform essential functions in a correctional setting. Fifth, 

applicants must report the professional, civic, and religious organizations 

in which they hold membership. 

With respect to professional requirements, applicants must have 

earned a bachelor’s degree from an accredited college with at least 120 

hours of instruction. In addition, applicants must have a Master of 

Divinity degree from an accredited residential seminary or theology 

school, or have successfully completed 90 semester hours of graduate 

study that include: 1) 20 semester hours of pastoral ministry; 2) 20 

semester hours of theology, ethics, or philosophy of religion; 3) 20 

semester hours of religious history or world religions (which demonstrate 

 22 The BOP’s table depicting the application and security screening requirements 

for chaplains, contractors, and volunteers is attached as Appendix B. 

17
an understanding of religious pluralism); and 4) 20 semester hours of 

religious writings or language study.23

In addition to these academic requirements, applicants must have 

at least two years of full-time pastoral experience in a ministry setting 

after they have completed their academic preparation. They also must 

sign a “Candidate Certification and Authorization” form certifying that 

they will minister to inmates of other faiths. 

Finally, an applicant must provide three personal references, 

recommendations from previous employers, and an endorsement from a 

national organization that has completed the paperwork required by the 

BOP to endorse chaplain applicants (“endorsing organization”). The 

applicant must have been associated with the endorsing organization for 

at least two years prior to the endorsement. The endorsement must 

attest to the applicant’s suitability for correctional ministry, verify the 

applicant’s ability to minister in a pluralistic environment to inmates of 

all faiths, support the applicant’s candidacy, and provide assurance that 

the applicant has no past or present legal or moral barrier to being a 

religious leader. 

Obtaining an endorsement from a national Islamic organization 

presents special challenges for Muslims because, unlike other religions, 

there is no national Islamic decision-making body to recognize official 

Islamic religious leaders or authorize them to minister to others. The 

BOP Muslim chaplains explained that in Muslim countries the 

government, not organizations, endorses religious leaders. They said 

that Muslims in the United States have created national organizations to 

unify and represent them, such as the Islamic Assembly of North 

America, the Islamic Circle of North America, and the ISNA. However, 

the chaplains noted that these organizations are not as large, organized, 

or established like other religions’ organizations, such as the Catholic 

Church or the Southern Baptists, and several of the organizations have 

received scrutiny for allegedly advocating radical beliefs or supporting 

terrorism. 

At this time, the ISNA is the only Islamic organization that has 

completed the paperwork required by the BOP to endorse chaplain 

applicants. Other organizations can apply to be endorsers for Muslim 

chaplains, but none has submitted the requisite paperwork. However, 

the BOP has not hired a Muslim chaplain since 2001, and in 2003 it 

stopped accepting ISNA-endorsed chaplain candidates until the FBI 

 23 The GSISS offers an academic program that fulfills the BOP’s educational 

requirements for graduate study in Islam. The GSISS is discussed below in section IV, 

“Endorsing Organizations.” 

18
provides the BOP with any information on the ISNA.24 This has resulted 

in a freeze on hiring Muslim chaplains. The GSISS never has endorsed a 

Muslim chaplain, contractor, or volunteer for the BOP.25

Despite the difficulties in obtaining national endorsements from 

Islamic organizations, the BOP requires Muslim chaplain candidates to 

provide a national endorser like all other chaplain candidates. Most of 

the BOP’s Muslim chaplains told us they supported the requirement for a 

national endorser because, they said, it has led to the hiring of highcaliber chaplains and it is an effective way for the government to further 

screen candidates. However, a few of the chaplains believed that the 

BOP should require local endorsers instead of national endorsers 

because some national organizations have been discredited, and national 

organizations do not know chaplain candidates as well as local 

organizations do. This issue is discussed further in section IV(A), “Role of 

Endorsers for Staff, Contractors, and Volunteers.” 

Once the chaplain candidate has completed the application packet, 

obtained all required recommendations, and received a national 

endorsement, the applicant sends the application to the central office of 

the Chaplaincy Services Branch. Only applicants with complete 

application packets are considered for chaplaincy vacancies. 

b. Muslim Contractors 

When a BOP institution determines it needs a religious contractor, 

it completes a Determination of Need form indicating the purpose of the 

contract, description of service required, special qualifications necessary, 

estimated cost of services, and an explanation for why the existing 

chaplains cannot perform the services. Based on the Determination of 

Need, the BOP advertises for contractors and issues a Statement of Work 

(SOW). Contractors apply for advertised positions by submitting 

proposals for services based on the requests in the SOW. 

In order to be eligible for a contractor position, applicants must 

have resided in the United States for three of the past five years and be a 

citizen or resident of the United States or a country that has diplomatic 

relations or treaties with the United States. If a contractor is a foreign 

national, the BOP does not grant the contractor access to BOP 

 24 The ISNA is discussed in more detail in section IV, “Endorsing Organizations.” 

The BOP has stopped accepting endorsements from all Islamic organizations until it 

receives information on those organizations from the FBI and determines whether to

continue using those organizations as endorsers. 

25 The GSISS is discussed in more detail in section IV, “Endorsing 

Organizations.” 

19
computers. Contractors also must demonstrate that they have the 

knowledge of their religion and ministry experience necessary to 

adequately provide the services requested. As with chaplain candidates, 

contractor applicants must provide adequate documentation of their 

religious and ministerial role within their religious community. 

In addition, contractor applicants must have a letter of 

endorsement from a local religious organization or clergy member that 

verifies the applicant is authorized to perform the services requested. 

Generally contractors do not receive endorsements from national 

organizations like the ISNA, but approximately five Muslim BOP 

contractors or volunteers have been endorsed by the ISNA. The GSISS 

never has endorsed a Muslim BOP contractor. 

Unlike chaplain candidates, contractor applicants are not asked to 

report the professional, civic, and religious organizations in which they 

hold membership. They also are not required to have particular 

academic credentials or pastoral experience. However, local BOP 

institutions often impose these requirements on their own. For example, 

a February 2003 SOW issued by the FCI in Victorville, California, 

required applicants to have a minimum of three years of documented, 

continuous, full-time experience as an Islamic minister and a 

Baccalaureate Degree from an accredited college or university, with a 

major in some form of religious studies. 

Contractors submit their proposals directly to the institutions 

requesting contractor assistance. The facility’s Human Resource 

Management and Business Office staff determine which proposal is 

selected. 

c. Muslim Volunteers 

Muslims interested in volunteering in the BOP apply directly to 

specific institutions, generally through a volunteer coordinator. Muslim 

volunteers must provide a letter of endorsement from a local Islamic 

organization or clergy member that verifies the volunteer is authorized to 

perform the services requested. According to the Chief of the Chaplaincy 

Services Branch, volunteers must also have verifiable religious 

credentials, but no specific academic training is required. The ISNA has 

endorsed approximately five of the BOP’s Muslim volunteers or 

contractors, but the GSISS has not endorsed any. 

20
3. Security Screening 

a. Muslim Chaplains 

In order to be selected as a BOP chaplain, candidates must pass a 

criminal history check, which includes a fingerprint check, local law 

enforcement checks for the past five years, and a record check through 

the FBI’s National Crime Information Center (NCIC). Candidates also 

must pass a drug screening urinalysis and provide the contact 

information for their employers for the past five years. In addition, the 

OPM contracts with the U.S. Investigations Services (USIS) to conduct 

full investigative background checks on chaplain candidates. These 

investigations are supposed to be completed within 120 days from the 

date scheduled. Subsequent reinvestigations of chaplains are supposed 

to be conducted by the OPM every five years. These security screening 

requirements are standard for most federal government employees. 

The OPM/USIS’s background investigation examines, among other 

things, the chaplain candidate’s loyalty to the United States, contacts 

with foreign countries, and any previous criminal activity. According to 

the Chief of the Chaplaincy Services Branch, the investigations do not 

specifically examine the candidates’ past sermons or performance in 

religious settings to determine whether they have given radical messages 

or made radical statements. 

The BOP has experienced problems obtaining timely closure of 

investigations from the OPM/USIS for all of its employees. In June 2002, 

the BOP’s Security and Background Investigation Section wrote a formal 

letter to the OPM regarding delinquent cases, and the OPM responded by 

implementing a plan to address the backlog of cases. The BOP informed 

us that since it took these steps, the OPM investigations are being closed 

quicker. However, the BOP said that the OPM still has some cases open 

until after new employees’ one-year probationary period has expired, 

making it more difficult for the BOP to dismiss personnel whose 

background investigations develop derogatory information. 

 Despite the OPM’s delays in conducting background investigations, 

the BOP’s SDAD of the Correctional Programs Division said he is not 

aware of any concerns or problems with the results or quality of the OPM 

investigations. In addition, while OPM delays might affect the 

background investigations of future Muslim chaplains, the current 

Muslim chaplains’ background investigations already have been 

completed. 

In addition to background investigations, chaplain candidates also 

receive a pre-employment screening interview and a panel interview. The 

21
pre-employment screening interview is conducted by a Human Resources 

specialist and covers the candidate’s employment history, financial 

history, criminal history, driving record, and any dishonest conduct or 

excessive use of force. A representative from Human Resources, a 

Regional Chaplain, and at least one other manager conduct the panel 

interview. While the panel interview is more in-depth than the 

pre-employment screening interview, the questions are standard (the 

Civil Service Questionnaire) and do not typically explore candidates’ 

doctrinal beliefs. 

Although some of the BOP Muslim chaplains said they were asked 

doctrine-related questions in their interviews, most said they were not. 

However, many of the chaplains said that they were recruited by people 

in the BOP who already knew their doctrinal beliefs. The Muslim 

chaplains told us they believed there should be some process to discern a 

candidate’s doctrinal beliefs, whether formally (through the interview) or 

informally (by checking with staff familiar with the candidate), for 

security purposes. For example, they stated that the BOP should know if 

a Muslim candidate identifies himself as a Wahhabi/Salafi or identifies 

himself with a particular school of thought rather than with Islam in 

general because, in their view, these individuals would not be willing or 

able to minister effectively to inmates of all faiths or of other Islamic 

sects. 

Currently, the BOP’s policy is not to ask chaplain candidates what 

they believe or require them to provide a statement of faith. Rather, the 

BOP relies on the certification of national endorsers that the candidates 

are mainstream Muslims and capable of teaching in BOP institutions. 

The Chief of the Chaplaincy Services Branch expressed concern to us 

that asking such questions or requiring a statement of faith would place 

the government in the position of approving or disapproving of a person’s 

religion. She also said there would be no way to ensure the candidate 

answered questions truthfully. Furthermore, she stated that, in her 

view, candidates’ doctrinal beliefs are secondary to what they will commit 

to do in the job.26 

In addition to not asking Muslim chaplain candidates about their 

religious beliefs, the BOP does not require a Muslim or other persons 

knowledgeable of Islam to participate in chaplain candidates’ interviews. 

However, eight of the ten Muslim chaplains said they were interviewed by 

a Muslim. Some were interviewed by a BOP regional official who was 

Muslim, and one chaplain said he was interviewed by another BOP 

 26 The OIG’s analysis of whether the BOP legally can screen chaplains’ doctrinal 

beliefs is contained in section VI, “OIG Analysis.” 

22
Muslim chaplain. The Muslim chaplains believed that the interview 

process is not effective if candidates are not interviewed by a Muslim. 

In response to questions about Muslim chaplain candidates being 

interviewed by a person knowledgeable of Islam, the Chief of the 

Chaplaincy Services Branch suggested that the BOP could create an 

interfaith advisory board composed of chaplains of many faiths, including 

Islam, to interview all of the BOP’s chaplain candidates, regardless of 

faith. 

The only method the BOP currently uses to screen chaplain 

candidates’ doctrinal beliefs is the “Candidate Certification and 

Authorization,” which the candidates sign pledging that they will minister 

to inmates of all faiths. The Chief of the Chaplaincy Services Branch said 

that Muslims with extreme Islamic views, like extreme Wahhabis/Salafis, 

would not be willing to sign this statement, unless they were attempting 

to infiltrate the prisons by misrepresenting their beliefs. 

The BOP also does not ask candidates whether they have received 

funds from foreign governments. The Chief of the Chaplaincy Services 

Branch noted that chaplains are not currently asked this, even though 

candidates for other, higher-ranking federal positions are. She believed 

chaplains and chaplain candidates should be asked questions such as, 

“Have you accepted gifts or funds from any foreign government?” by the 

BOP or the OPM. 

Finally, as discussed previously, the BOP requires chaplain 

candidates to report their foreign travel. The SDAD of the Correctional 

Programs Division said the BOP is interested in verifying chaplains’ 

foreign travel and soon will be able to use the State Department’s 

databases for this purpose. The Chief of the Chaplaincy Services Branch 

said that the BOP would not hire chaplain applicants who lie about their 

foreign travel. In addition, she said that the BOP will not hire a chaplain 

candidate who has spent a significant amount of time in a country that 

does not have diplomatic relations or treaties with the United States, but 

she did not define how much time was significant enough to preclude 

hiring.27 She said that because Saudi Arabia has diplomatic relations 

with the United States, she did not believe Muslim chaplain candidates 

who have studied in Saudi Arabia should be excluded from BOP 

positions. She also noted that Saudi Arabia is the religious center of 

Islam and offers many professional schools that can prepare Muslims for 

ministry. 

 27 As noted earlier, chaplain and contractor candidates must have resided in the

United States for three of the past five years. 

23
b. Muslim Contractors 

In order to be selected as a BOP contractor, candidates must pass 

a criminal history check, which includes a fingerprint check, inquiries 

with local law enforcement, and a records check through the FBI’s NCIC. 

Candidates also must pass a drug screening urinalysis and provide 

contact information for their employers for the past five years. According 

to the Chief of the Chaplaincy Services Branch, the BOP began in 

October 2003 to inquire about contractor applicants’ educational 

background, countries visited, and naturalization numbers (if 

applicable). As with chaplains, the Chief of the Chaplaincy Services 

Branch said that the BOP would not hire applicants who have spent a 

significant amount of time in a country that does not have diplomatic 

relations or treaties with the United States. 

According to BOP officials, contractor candidates are interviewed 

by the program manager at the institution in which they will work. 

These interviews are not standardized, and they also are not as in-depth 

as the interviews of chaplain candidates. 

As with chaplains, the BOP does not screen contractors’ doctrinal 

beliefs or require that they provide a statement of faith. For example, the 

BOP does not use contractors’ interviews to determine what candidates 

believe or whether their beliefs could compromise security or violate BOP 

policies. 

In addition to not screening contractors’ doctrinal beliefs, the BOP 

does not ask contractors to report the professional, civic, and religious 

organizations in which they hold membership or whether they have 

received funds from foreign governments. The BOP also does not require 

contractors to submit lesson plans to the chaplains or an outline of what 

they intend to cover during their services. The Chief of the Chaplaincy 

Services Branch said that the contractors’ SOW and proposal describe 

the number of sessions needed and what service the contractor would 

provide. 

The BOP Muslim chaplains we interviewed said that the BOP does 

not consult them regarding the hiring of Muslim contractors or ask them 

to interview contractor applicants. The chaplains said they have 

witnessed some Muslim contractors bring distorted Islam into the 

prisons, which causes problems for the BOP. They said that the BOP 

does not select contractors based on doctrinal beliefs or lesson plans, but 

mostly on who offers the services for the cheapest cost. As a result, they 

said, the BOP has hired contractors who have taught things that pose a 

security threat to the institutions. 

24
In addition, the BOP does not require chaplains at prisons hiring 

Muslim contractors to gather information from the local community on 

contractor applicants. The Chief of the Chaplaincy Services Branch told 

the OIG that if chaplains had time, she thought it would be beneficial for 

them to examine applicants’ activities and reputations in their 

communities and religious congregations before hiring them. 

c. Muslim Volunteers 

In order to be selected as a BOP Muslim volunteer (Level 1 or 

Level 2), applicants must pass a criminal history check, which includes a 

fingerprint check, inquiries with local law enforcement, and a record 

check through the FBI’s NCIC. Applicants also must disclose their 

country of citizenship. In addition, according to the Chief of the 

Chaplaincy Services Branch, the BOP began in October 2003 to inquire 

about volunteer applicants’ educational background, countries visited, 

and naturalization number (if applicable). She said this information is 

used to further screen out potentially radical individuals. For example, 

the BOP will not accept volunteers who have spent a significant amount 

of time in a country that does not have diplomatic relations or treaties 

with the United States. 

Unlike chaplains and contractors, volunteers are not required to 

pass a drug screening urinalysis or provide contact information for their 

employers for the past five years. They also are not asked to report the 

professional, civic, and religious organizations in which they hold 

membership or whether they have received funds from foreign 

governments. 

Ex-offenders are eligible to serve as volunteers, but are subject to 

more stringent security requirements. In addition to the standard 

volunteer security requirements, ex-offenders must have no arrests for 

three or more years after their release, must submit to a background 

check in which they provide and verify their current employment or 

academic status, and cannot be placed in a prison that houses inmates 

who have separation orders against them. In addition, ex-offenders are 

prohibited from entering protective custody units and must be escorted 

at all times. 

Level 2 volunteers must be interviewed prior to working with 

inmates, but Level 1 volunteers are not interviewed. The prison’s 

program manager conducts brief interviews for Level 2 volunteers at the 

local prison. 

The BOP does not screen volunteers’ doctrinal beliefs or require 

they provide a statement of faith. The BOP also does not consult the 

25
BOP Muslim chaplains regarding the screening of Muslim volunteers or 

ask chaplains to gather information from the local community on 

volunteer applicants. The Chief of the Chaplaincy Services Branch told 

the OIG that she believed it would be beneficial for chaplains to examine 

volunteers’ activities and reputations in their communities and religious 

congregations. 

d. Security Screening Through the FBI 

The FBI recently began providing additional information to the BOP 

on contractors and volunteers that may not be available during an NCIC 

check. This could include open investigations, terrorism-related 

connections, or other information that did not result in an arrest or 

conviction. 

1. National Joint Terrorism Task Force 

All communications between the FBI and the BOP about the 

radicalization of inmates are now channeled through the National Joint 

Terrorism Task Force (NJTTF) in FBI Headquarters.28 The BOP detailee 

to the NJTTF is the project manager for the NJTTF’s Correctional 

Intelligence Initiative (CII), described below, and serves as the conduit for 

the flow of information between the FBI and the BOP on counterterrorism 

issues. For example, he said he exchanges information with FBI 

intelligence analysts, searches FBI databases for information relevant to 

BOP security, and assists in implementing initiatives for the purpose of 

detecting and deterring inmate radicalization in the BOP. Almost all 

information between the FBI and the BOP regarding the radicalization of 

inmates is channeled through this BOP detailee to the NJTTF. However, 

the SDAD of the Correctional Programs Division informed us that he 

occasionally has spoken with unit chiefs at the FBI and the 

Counterterrorism Division’s Deputy Assistant Director for Operational 

Support about the radicalization of inmates.

During our review, we found that the exchange of information 

between the FBI and the BOP on issues concerning the BOP’s selection of 

Muslim religious services providers has not been entirely effective. We 

 28 The NJTTF was formed in July 2002 to allow for the direct exchange of 

information among approximately 30 participating federal agencies. These agencies

include, among others, the Central Intelligence Agency, the DOD, the Internal Revenue

Service, the Department of Homeland Security, and the BOP. According to the FBI,

NJTTF members receive all intelligence and other information that their FBI

counterparts receive. The primary purpose of the NJTTF is to collect terrorism

information and intelligence and disseminate it to the FBI’s 56 local Joint Terrorism

Task Forces (JTTF), various terrorism units within the FBI, and partner agencies. 

NJTTF members support the FBI’s counterterrorism mission by sharing their respective

agencies’ information and resources with the FBI and other NJTTF participants. 

26
learned that the FBI had information about certain Islamic endorsing 

organizations’ potential terrorism connections, but when we interviewed 

senior BOP officials and the BOP detailee to the NJTTF in July and 

August 2003, they did not know about the FBI information or the extent 

of the FBI’s concerns about these organizations. This indicated that 

despite the BOP detailee’s queries in FBI databases and discussions with 

various FBI counterterrorism analysts, he was not obtaining information 

critical to the BOP’s assessment of these endorsing organizations. 

Moreover, the detailee’s work was not part of a larger coordinated effort 

with the FBI to respond to the issues concerning the BOP’s selection of 

Muslim religious services providers.29 The BOP detailee explained in 

August 2003 that he had not contacted the Counterterrorism Division at 

the FBI “in an organized way” and instead simply had conversations “on 

a spot-individual basis” with FBI analysts.30 

In addition, we learned that BOP and FBI officials did not meet to 

discuss concerns about the BOP’s selection of Muslim chaplains, 

contractors, and volunteers until December 16, 2003, after significant 

congressional and media attention arose about these issues. On that 

day, we conducted a follow-up interview of the SDAD of the Correctional 

Programs Division. He said that shortly before our interview, he had met 

for the first time with the Unit Chief of the NJTTF to discuss the BOP’s 

selection process for religious services providers. Until that meeting, 

which the Unit Chief of the NJTTF described as an annual meeting at 

which BOP and NJTTF representatives discussed issues of mutual 

interest, essentially all of the FBI’s and BOP’s communications about 

issues pertaining to the selection of religious services providers were 

exchanged solely through the BOP detailee to the NJTTF. 

2. The Correctional Intelligence Initiative

The CII is led by the BOP detailee to the NJTTF. The purpose of 

the CII is to prevent potential acts of terrorism by inmates in the 

United States. The CII has four subprojects: 1) general intelligence, 

 29 The scope of this review is limited to the selection of Muslim religious services 

providers, and does not include an examination of the entire CII program and its

“recruiting in custody subproject.” 

30 Shortly after congressional inquiries regarding concerns about Islamic 

endorsing organizations, the BOP detailee began to gather information from the FBI on

a few of the endorsing organizations he knew were of concern to Congress. He 

conducted several test searches of these groups for the purpose of determining what 

information the FBI had on them and whether this information indicated the BOP 

should not use them to endorse chaplain candidates. He also had informal 

conversations with analysts in the FBI’s Counterterrorism Division regarding their 

knowledge about Wahhabism, Salafism, the ISNA, and the GSISS. According to the

detailee, his research was “non-directed” and executed “just on my own.” 

27
2) recruiting in custody, 3) development of inmate sources on terrorism 

matters, and 4) inmates calling persons of concern. 

The CII’s recruiting in custody subproject focuses specifically on 

detecting and deterring the radicalization or recruitment of inmates by 

extremist organizations or individuals who come into the prisons to 

provide services directly to the inmates. This includes all services, 

religious or otherwise, and all people, including staff, contractors, and 

volunteers. 

According to the SDAD of the BOP’s Correctional Programs 

Division, all contractors and volunteers were managed and screened by 

local prisons until April 2003. Until that time, their security screening 

did not include any checks with the FBI beyond fingerprint and NCIC 

checks. However, in April 2003, BOP Headquarters began working with 

the NJTTF to conduct further security checks on BOP contractors and 

volunteers. The BOP created a database of the names of all its 

contractors and volunteers and submitted the names to the FBI’s Name 

Check Unit for a security threat assessment. 

Through this and other projects under the recruiting in custody 

subproject, the FBI has identified some BOP contractors or volunteers “of 

interest” who it suspects could be recruiting or radicalizing inmates.31 

According to the BOP detailee to the NJTTF, “of interest” means that 

there is an indication that the person is connected, directly or indirectly, 

to individuals or a group of concern to the FBI’s Counterterrorism 

Division. He said that while the FBI may suspect these individuals to be 

a security threat, the information is not always conclusive and may 

require further investigation or research. 

The SDAD of the Correctional Programs Division said that the BOP 

analyzes the information obtained by the FBI on the contractors and 

volunteers identified as “of interest” to determine whether to recommend 

that they be dismissed. He said that a contractor or volunteer will be 

dismissed based on any credible evidence that the person has potential 

ties to any terrorist-affiliated organizations or individuals; advocates 

racism or violence; or has made anti-U.S. statements or supports such 

statements. He also said that the BOP maintains a database of its 

decisions on these cases to assist in making decisions on future cases. 

He further stated that the BOP plans to screen new contractors’ and 

Level 2 volunteers’ names through the FBI before hiring them. 

 31 According to the FBI, none of the BOP’s chaplains, Muslim or otherwise, is “of 

interest.” In addition, the BOP never has dismissed a Muslim chaplain for 

inappropriate work-related conduct or teachings.

28
Ultimately, the BOP’s success in identifying and dismissing staff, 

contractors, and volunteers who are radicalizing and recruiting inmates 

for terrorist acts depends in part on the FBI developing and documenting 

sufficient, accurate, and credible information to support a decision to 

dismiss an individual. This further underscores the importance for 

improving the FBI-BOP information flow process. 

3. The Joint Intelligence Coordinating 

Council (JICC) 

On February 24, 2004, the Attorney General announced the 

initiation of the Joint Intelligence Coordinating Council (JICC). The JICC 

will include personnel from key DOJ agencies, including the FBI, Drug 

Enforcement Administration, and the BOP. According to a press release 

from the Attorney General’s office, the purpose of the JICC is to improve 

counterterrorism intelligence collection, analysis, and information 

sharing within the DOJ. While the creation of the JICC may improve 

information sharing between the FBI and the BOP on issues of inmate 

radicalization, the JICC is not yet operational and the actual effect of the 

JICC on the FBI-BOP information flow is not clear. 

IV. ENDORSING ORGANIZATIONS 

A. Role of Endorsers for Staff, Contractors, and Volunteers 

The BOP uses local and national endorsements to help determine 

that chaplain, contractor, and volunteer applicants are qualified and able 

to provide appropriate religious services in a prison setting. The roles for 

local and national endorsers differ in many respects. 

Contractors and volunteers require only local endorsements that 

are supposed to attest to a person’s good standing in the organization. 

These endorsements authorize the person to work in the local BOP 

facility on behalf of the organization. According to the Chief of the 

Chaplaincy Services Branch, the endorsement serves to verify the 

legitimacy and qualifications of the contractor or volunteer. However, the 

BOP does not contact the endorser to discuss the candidate or the basis 

for the endorsement, or maintain any kind of relationship with local 

endorsing organizations. 

National endorsements are required for chaplain candidates. 

National endorsements are supposed to signify that the chaplain 

candidates are mature in their religion; can provide religious services in a 

pluralistic environment; represent the national organization in the 

provision of religious services; and have no legal, moral, or ecclesiastical 

barrier to serving as chaplains. According to the Chief of the Chaplaincy 

29
Services Branch, the national endorsement also is supposed to attest 

that the candidate has mainstream religious beliefs and is qualified and 

capable to teach in BOP institutions. 

The BOP requires chaplain candidates to obtain a national 

endorsement from an organization like the ISNA rather than a local 

endorsement because they provide services for many different kinds of 

inmates at facilities across the nation. In contrast, the BOP requires 

contractors and volunteers to obtain only a local endorsement because 

they work at a single, local facility with inmates of their faith group. 

The Chief of the Chaplaincy Services Branch stated that before 

1995 the BOP required Muslim chaplains to provide only a local 

endorsement, just like volunteers and contractors. However, because it 

was difficult for chaplains to maintain relationships with local 

organizations when they were assigned to prisons in other states, the 

BOP decided to move to a national endorsement requirement for chaplain 

candidates. To maintain the relationships between the endorsing 

organizations and the chaplains, the BOP encourages national endorsers 

to visit chaplains in their facilities and authorizes chaplains to take 

administrative leave to attend endorsers’ annual conferences or spiritual 

retreats. 

The Chief of the Chaplaincy Services Branch said that the national 

endorsement is intended to hold chaplains accountable, keep them 

rooted in their faith, and help them maintain contacts with their faith 

communities. The endorsement is an affirmation that the candidate will 

be performing a valid ministry consistent with the faith group’s beliefs 

and has presented evidence of having the education, experience, and 

skills necessary to perform that ministry in a correctional setting. 

The Chief of the Chaplaincy Services Branch acknowledged, 

however, that national endorsing organizations likely would not know 

candidates as well as a local endorsing organization would. But she said 

that it is safer and more effective to require national endorsements for 

chaplain candidates than local endorsements. She asserted that radical 

local organizations could go undetected much easier than national 

organizations. She also said that national endorsers have more 

experience working with chaplains and have more resources to assist 

them in their work. Furthermore, she said the BOP builds relationships 

with the national endorsers because it can more easily work with a 

consistent group of people over time. Through these relationships, she 

said, the BOP is able to obtain greater support for its chaplains and 

further ensure that the organizations are mainstream, understand the 

BOP’s mission, and share the BOP’s values. For example, the BOP has 

asked endorsers to report any language or conduct that indicates a staff 

30
member, contractor, or volunteer is promoting a message that is contrary 

to the BOP’s policies. 

B. Qualification to be an Endorser 

The Chief of the Chaplaincy Services Branch said that the religious 

legitimacy of the endorsement provided by a particular organization or 

mosque is based on its reputation. She said if the BOP had any 

suspicion that an organization or mosque was radical, the BOP would 

not rely on its endorsements. Before October 2003, the BOP relied on 

information known to the general public or reported in newspapers to 

know whether a mosque or organization was radical. She said that the 

BOP evaluated the integrity of a mosque or organization based on the 

conduct of the staff members, contractors, and volunteers it had 

previously endorsed. 

Prior to this review, if the BOP had no reason to be concerned 

about a local organization, the organization’s endorsement of a 

contractor or volunteer applicant was accepted without any further 

qualification requirements or security screening procedures. Security 

screening steps taken since initiation of our review are discussed below 

in section IV (E), “The FBI’s Assessment of Endorsing Organizations.” 

Before a national group is allowed to endorse chaplain applicants, 

it must complete the paperwork required by the BOP to verify the 

organization’s religious legitimacy. Such organizations must provide the 

BOP a statement of their beliefs and practices, proof of their tax-exempt 

status (501(c)(3)), an endorsement for their candidate, and a completed 

application form.32 The form asks endorsers how they select candidates, 

what criteria they use to determine whether candidates are qualified as 

professional ministers, and how the candidates receive the official 

endorsement of the organization. Since December 2003, the BOP also 

has started requiring national endorsing organizations to submit an 

additional form certifying that their organization does not promote 

separatism, terrorism, or violence. 

Currently, the ISNA is the only national organization that has 

submitted all paperwork required by the BOP to be a national endorser 

for Muslim chaplains. However, the BOP recently stopped accepting 

ISNA-endorsed Muslim candidates, effectively ceasing the hiring of 

 32 The Chief of the Chaplaincy Services Branch told the OIG that the BOP does 

not use 501(c)(3) information for purposes other than to establish that the endorsing 

group is recognized by the Internal Revenue Service as a religious organization. 

31
Muslim chaplains.33 The BOP’s decision to stop accepting ISNA-endorsed 

chaplains is discussed further below under IV (D), “ISNA and GSISS 

Endorsements of BOP Religious Services Providers.” 

The BOP has encouraged other Islamic organizations to apply to be 

endorsers for Muslim chaplains, including the Islamic Supreme Council 

of America (a moderate Sufi organization). However, the BOP normally 

does not seek endorsers for chaplains. Instead, chaplain candidates 

identify which organization will provide their endorsement and if the 

organization has not completed the paperwork required by the BOP to be 

a national endorser, the BOP will send it an endorser application packet. 

We found no evidence indicating that the BOP excludes non-Wahhabist 

organizations from endorsing Muslim chaplain candidates. According to 

the Chief of the Chaplaincy Services Branch, Muslim chaplain candidates 

recently identified two moderate Muslim organizations as endorsers, but 

neither of them has completed the requisite paperwork. 

The Chief of the Chaplaincy Services Branch asserted that there 

are special problems posed by requiring Muslim chaplain candidates to 

obtain a national endorsement: 1) the non-hierarchical structure of 

Islam does not lend itself naturally to the existence of national Islamic 

organizations; 2) very few Islamic national organizations have been 

established in the United States; 3) many of these organizations have 

fallen into disrepute; and 4) the BOP is not presently accepting 

endorsements from the ISNA and other Muslim endorsing organizations. 

She added that despite her reluctance to rely on local endorsements for 

chaplains, she would consider permitting local endorsements for Muslim 

chaplains if the candidate cannot identify a national organization that 

will complete the paperwork required by the BOP to be an official BOP 

endorser. 

C. Background of the ISNA and the GSISS 

Founded in 1981 and located in Plainfield, Indiana, the ISNA is the 

oldest national Islamic organization in the United States. According to 

the ISNA’s website, the ISNA is an association of Muslim organizations 

and individuals that provides a common platform for uniting Islamic 

communities nationwide; presenting Islam; developing educational, 

social, and outreach programs; and fostering good relations with other 

religious communities and civic organizations. The ISNA’s stated mission 

is to be an exemplary and unifying Islamic organization in North America 

 33 The BOP has stopped accepting endorsements from all Islamic organizations 

until it receives information on those organizations from the FBI and determines 

whether to continue using those organizations as endorsers.

32
that contributes to the betterment of the Muslim community and society 

at large. 

The ISNA is operated by an executive council of nine officers, 

including the president, two vice presidents, a former president, and five 

regional representatives. The president, two vice presidents, and former 

president also serve on the ISNA’s Board of Directors. The ISNA’s Board 

of Directors is composed of 22 individuals, including leaders of various 

Islamic organizations, ISNA chapter presidents, and members at large. 

The Chief of the Chaplaincy Services Branch said that she has 

worked with the ISNA since the 1980s when the BOP hired its first 

Muslim chaplains. She stated that originally the federal government 

sought the ISNA’s assistance with locating qualified, trustworthy Muslim 

chaplains; the ISNA did not approach the federal government to perform 

this role. 

The Chief of the Chaplaincy Services Branch asserted that the 

ISNA is a moderate, mainstream, non-Wahhabist, Islamic organization 

that encompasses Muslims from several Islamic sects. She said that the 

ISNA’s president participated in inter-faith prayer services following the 

September 11 terrorist attacks. She said that the ISNA is funded by its 

member mosques and does not receive Saudi funding. She recounted a 

time when the BOP approached the ISNA with concerns about a 

particular Muslim contractor, and the ISNA informed the BOP that the 

individual was not teaching Islam appropriately and that he did not 

represent the organization’s views. 

The GSISS was founded in 1985 by a group of Islamic scholars. 

Due to the death of a significant contributor to the program, the GSISS 

did not begin enrolling students until 1996. The GSISS, located in 

Leesburg, Virginia, was the first Muslim-governed, campus-based 

institution of Islamic graduate studies in the United States. As of March 

2004, 11 students were enrolled at the GSISS and 13 professors made up 

the GSISS’s faculty. The president of the GSISS is Taha Jabir Alalwani. 

The GSISS offers two degrees, the Masters of Arts in Islamic Studies and 

the Masters of Religious Practice, which is a 90-credit hour professional 

degree that trains Muslim chaplains. One of the GSISS’s stated 

objectives is to serve as a bridge between cultures by offering a classical 

Islamic education framed within the North American experience. 

The GSISS is one of the few Islamic graduate programs in the 

United States available to BOP Muslim chaplain applicants to obtain 

their requisite academic credentials. However, only one of the ten 

current BOP Muslim chaplains has attended the GSISS. 

33
The Chief of the Chaplaincy Services Branch said she has 

maintained a relationship with the GSISS since 1996. In her opinion, 

the GSISS is a mainstream, Islamic organization that has not 

demonstrated any tendency toward extremism. Following the 

September 11 attacks, the president of the GSISS issued a fatwa, or 

official Islamic legal opinion, supporting American Muslims who serve in 

the United States military, combat terrorism, and bring terrorists to 

justice. 

The BOP has an ongoing relationship with both the ISNA and the 

GSISS. For example, in June 2002 the Chief of the Chaplaincy Services 

Branch delivered a commencement address at the GSISS’s graduation 

ceremony. She also attended the ISNA national conference in the 

summer of 2003 and spoke on one of its panels. In October 2003, the 

ISNA Director came to Washington, D.C., and met with the Chief of the 

Chaplaincy Services Branch and the SDAD of the Correctional Programs 

Division to discuss the goals and mission of the ISNA. 

Following the September 11 terrorist attacks, both the ISNA and 

the GSISS were scrutinized for their possible connections to terrorist 

groups. For example, according to an affidavit in support of an 

application for a search warrant that was publicly released by the 

U.S. Attorney’s Office for the Eastern District of Virginia, the GSISS and 

some of its affiliated entities have been under federal investigation by the 

Department since December 2001 for providing material support to 

terrorists, laundering money, and evading taxes. As of March 15, 2004, 

the GSISS was still under investigation for supporting terrorism. 

In addition, several ISNA board members have been accused of 

supporting or having ties to terrorism. One member, Siraj Wahhaj, was 

named by U.S. Attorney Mary Jo White as one of the “unindicted persons 

who may be alleged as co-conspirators” in the 1993 World Trade Center 

bombing. Wahhaj also has been accused of urging his followers to 

overturn the U.S. system of government and set up an Islamic 

dictatorship. Another ISNA board member, Bassam Osman, is Chairman 

of the North American Islamic Trust (NAIT), which allegedly owns the 

Islamic Academy of Florida (IAF) and many other Islamic organizations. 

In a federal indictment handed down in February 2003, the IAF was 

accused of raising funds and providing support for the terrorist 

organization Palestinian Islamic Jihad. 

The ten BOP Muslim chaplains said that Muslims established the 

ISNA to accommodate the American custom of having large, unified, 

religious organizations to represent a faith group. They said that their 

experience indicates that the ISNA is a moderate group and it was 

surprising that the ISNA was suspected of being radical and having ties 

34
to terrorist organizations. They expressed concern that if the ISNA has 

fallen into disrepute, then Muslims have to start all over and build 

another national Islamic organization. However, they were concerned 

that other Islamic organizations would suffer the same fate that the ISNA 

has, mostly because, they said, the hospitable, familial nature of Islam 

means that radical Muslims can easily become part of such 

organizations, unbeknownst to the organizations, and mainstream 

Muslims can innocently become affiliated with the wrong people or 

groups. The ten chaplains also said they believed the GSISS was a 

mainstream organization and that the GSISS trained Muslims from 

various Islamic sects. 

D. ISNA and GSISS Endorsements of BOP Religious Services 

Providers 

The ISNA’s and the GSISS’s relationship to the BOP came under 

scrutiny after a February 2003 Wall Street Journal article reported that a 

BOP Muslim contractor defended the September 11 terrorist attacks and 

supported terrorism in statements he made at an event outside a prison. 

The contractor, Warith Deen Umar, attended the GSISS but was not 

endorsed by the GSISS or the ISNA. He is the founder and president of 

the National Association of Muslim Chaplains and served as the chief 

Muslim chaplain of the New York State prison system, where he was 

employed for about 25 years. After he retired from the New York State 

prison system in 2000, he became a Muslim contractor at the FCI in 

Otisville, New York. 

In February 2003, the Wall Street Journal quoted Umar as stating 

at a public event, “Even Muslims who say they are against terrorism 

secretly admired and applaud [the September 11 hijackers].” The article 

also reported that Umar believed black inmates who converted to Islam 

in prison were logical recruits for committing future terrorist attacks 

against the United States. Around the same time, Umar’s contract was 

terminated “for the convenience of the government,” according to a letter 

the BOP sent Umar. One of the BOP Muslim chaplains told us that he 

knew Umar in a professional setting several years before Umar joined the 

BOP, and if asked he would have informed the BOP that Umar did not 

hold mainstream Islam values had he known at the time of Umar’s 

application that the BOP was considering hiring him as a contractor. 

This incident drew attention to the BOP’s process for selecting 

Muslim religious services providers. Shortly after the Wall Street Journal 

article was published, Senator Schumer wrote a letter to the OIG 

expressing concern that the BOP was relying solely on the ISNA and the 

GSISS to endorse its Muslim chaplains. His letter precipitated this 

review. 

35
The ISNA has provided endorsements for the BOP from 1987 to 

2001, but the GSISS never has. Three of the BOP’s ten Muslim 

chaplains were endorsed by the ISNA. The remaining seven were 

endorsed by other organizations. Before 1995, the BOP required Muslim 

chaplains to provide only a local endorsement, just like volunteers and 

contractors. As a result, six of the chaplains were endorsed by local 

organizations such as the Fox Valley Islamic Society, the Islamic Society 

of New Jersey, and the Islamic Society of Greater Charlotte. The seventh 

chaplain, hired in 1998, was endorsed by a national organization, the 

American Muslim Council (AMC). Because the AMC has not complied 

with the BOP’s more recent requirements for official recognition as a 

national endorser, it is not currently allowed to endorse Muslim 

chaplains. In addition, approximately five Muslim volunteers and 

contractors have been endorsed by the ISNA. However, volunteers and 

contractors generally receive endorsements from local organizations, not 

a national group such as the ISNA. 

The BOP has not hired a Muslim chaplain since 2001. The Chief of 

the Chaplaincy Services Branch stated that around the summer of 2003 

the BOP stopped accepting ISNA-endorsed chaplain candidates. She said 

that the BOP would not accept ISNA-endorsed candidates until the FBI 

determined that the organization was not radical and does not have ties 

to terrorism.34 Since the ISNA currently is the only Islamic national 

organization that has submitted all paperwork required by the BOP to 

endorse chaplains, and chaplain candidates must receive an 

endorsement from a national organization that has submitted the 

requisite paperwork, the BOP’s non-acceptance of ISNA-endorsed 

candidates effectively has resulted in a freeze on hiring Muslim 

chaplains. According to the Chief of the Chaplaincy Services Branch, for 

example, one qualified Muslim chaplain has submitted his application to 

the BOP, but because he was endorsed by the ISNA the BOP will not hire 

him at this time. 

This freeze on hiring Muslim chaplains implicates prison security 

and presents counterterrorism concerns. Without a sufficient number of 

Muslim chaplains on staff, inmates are, according to the Chief of the 

Chaplaincy Services Branch and the ten BOP Muslim chaplains, much 

more likely to lead their own religious services, distort Islam, advocate 

Prison Islam, and espouse extremist beliefs. 

 34 By contrast, the FBI told us that it would not provide the BOP an assessment 

of whether an endorsing organization is radical. Instead, it said it would share the

information it has on the organization so that the BOP can draw its own conclusions 

about whether to use the organization as an endorser. 

36
E. The FBI’s Assessment of Endorsing Organizations 

The FBI potentially could provide the BOP with information that 

would help the BOP determine whether there is a reason to be suspicious 

about an endorsing organization. However, the BOP did not screen 

Islamic organizations through the FBI prior to the time this review began. 

In addition, as described above, our review found that FBI information 

about organizations’ radicalism or connections to terrorism has not been 

shared effectively with the BOP. As a result, the BOP did not have 

information from the FBI on the ISNA or the GSISS when public concerns 

surfaced about those organizations’ alleged terrorism connections. For 

example, when we interviewed the SDAD of the Correctional Programs 

Division in July 2003, four months after the BOP received Senator 

Schumer’s letter expressing concern about the ISNA and the GSISS, he 

informed us that the BOP never had requested or seen any intelligence 

from the FBI on the ISNA or the GSISS. 

In October 2003, after the OIG began conducting this review, the 

BOP formally requested information and a threat assessment from the 

FBI on all 82 Muslim national and local endorsing organizations used by 

the BOP, including the ISNA.35 The GSISS was not included in this 

request because it has not endorsed any chaplains, contractors, or 

volunteers for the BOP. According to the SDAD of the Correctional 

Programs Division and the BOP detailee to the NJTTF, the purpose of the 

request was to assist the NJTTF and the BOP in determining if 

derogatory information indicated an Islamic organization should not be 

used as an endorsing organization for Muslim chaplains, contractors, or 

volunteers. Prior to this request, the BOP had not asked for information 

from the FBI on whether the ISNA or other endorsing organizations posed 

a security threat to the BOP. 

In mid-December 2003, the FBI finished screening the 82 Muslim 

endorsing organizations. The FBI determined that some of the 

organizations were “of interest,” although most of them were not.36 

According to the BOP detailee to the NJTTF, “of interest” means that 

there is an indication that the organization is connected, directly or 

indirectly, to individuals or a group of concern to the FBI’s 

Counterterrorism Division. He said that while the FBI may suspect these 

organizations to be a security threat, the information is not always 

conclusive and may require further investigation or research. 

 35 The endorsing organizations of other faith groups have not been examined.

36 The classified addendum to this report provides more information about 

organizations and individuals that were determined to be “of interest.” 

37
The FBI indicated that several of the other organizations of interest 

required further research by the FBI because there was not enough 

information to determine whether they have ties to terrorist groups, are 

radical, or should continue to be used by the BOP. According to the BOP 

detailee to the NJTTF, if the FBI’s information about an organization is 

derogatory, the FBI will further examine all Muslim chaplains, 

contractors, and volunteers who have connections with that group. 

According to the Unit Chief of the FBI’s Counterterrorism Division 

Domestic Sunni Analytical Unit, as of April 13, 2004, detailed 

information from the FBI’s review still had not been provided to the BOP. 

He said that the Counterterrorism Division was awaiting legal clearance 

to release the information contained in the review. According to the 

initial request issued to the FBI field divisions, when this information 

was provided to the BOP, it would be only advisory in nature and would 

not constitute a formal recommendation from the FBI. Rather, once the 

BOP receives the information, it would use the information to make its 

own judgments about the organizations after consulting with the FBI. 

The BOP also said it will determine whether it should discontinue 

receiving endorsements from any of the organizations. According to 

senior BOP officials, if the FBI does not have any concerns or significant 

derogatory information about an organization, the BOP will consider the 

organization’s application to be an endorsing organization. If the FBI has 

an investigation of or compelling derogatory information about an 

organization, the BOP will not continue to accept applicants who are 

endorsed by that organization until it is cleared by the FBI. 

The SDAD of the BOP’s Correctional Programs Division was unable 

to define what the BOP would consider to be “significant” or “compelling” 

derogatory information. He said the BOP has to make this determination 

on a case-by-case basis, and it cannot begin making such determinations 

until it received information from the FBI. He also said that if the FBI’s 

information is inconclusive or ambiguous, the BOP would examine each 

organization on a case-by-case basis to determine whether to continue 

accepting endorsements from that organization. If the BOP decided to 

continue accepting endorsements from such an organization, it would 

subject the organization and its endorsed applicants to increased levels 

of security monitoring until the FBI reaches a conclusion about it. 

According to the SDAD of the Correctional Programs Division, if a 

future Muslim chaplain, contractor, or volunteer applicant is endorsed by 

an organization that has not yet been vetted through the FBI, the BOP 

plans to have the FBI process the organization’s name through FBI 

databases before it allows the chaplain, contractor, or volunteer 

applicant to have access to inmates. 

38
V. SUPERVISION OF RELIGIOUS SERVICES ACTIVITIES AND 

PROVIDERS 

Supervision within BOP facilities is a further check to ensure that 

chaplains, contractors, or volunteers espousing radical beliefs are not 

permitted to influence the inmate population. An effective supervision 

program also can indicate whether the BOP’s personnel selection process 

is successfully screening out individuals who pose a security risk in the 

prison environment. In addition, rigorous inmate supervision also can 

detect, deter, and prevent terrorist recruitment and radicalization. 

A. Overview 

Religious activities in BOP facilities are supposed to occur under 

the supervision of chaplaincy staff and typically occur in dedicated space 

referred to as “the chapel.” The chapels we observed during this review 

typically included one or two areas for worship services, offices for 

chaplaincy staff, a library, and several classrooms. These spaces were 

enclosed and generally were not amenable to supervision (visual and 

auditory) by one person of more than two rooms at a time. In some 

facilities, the Psychological Services Department shared space with the 

chaplaincy. 

The chapel is one of the few areas in BOP facilities where large 

numbers of inmates are permitted to meet as a group and to converse. 

Services typically occur on Friday through Sunday. Classes are common 

in the evenings during the week and last one to two hours each. At the 

facilities we visited, from two to six religious activities were scheduled 

concurrently each weekday evening. To accommodate the demand for 

evening activities, BOP chaplains must work evening hours twice a week. 

As with other religious groups, Muslim groups usually gather in 

the chapel two times each week: once for a worship service and once for 

a study lesson. The BOP staff members we interviewed all believed that 

the presence of an Islamic radical in this environment would pose a 

threat to institutional security and that supervision practices needed to 

be adequate to detect such persons. 

The BOP does not have specific policies that address oversight of 

religious activities. The BOP P.S. concerning “Religious Beliefs and 

Practices” provides simply that “[a]ll institution chaplains are employed 

to . . . supervise institution religious activities.” See BOP P.S. 5360.08. 

Although responsibilities of some BOP employees who interact with 

chaplaincy staff members are described in the P.S. (e.g., food service 

staff, employees who make work assignments), the obligations of 

correctional officers in support of chaplains are not identified. As 

39
described below, the lack of policy guidance allows for significant 

variations in the way that religious activities are supervised at BOP 

facilities. 

B. BOP Supervision and Intelligence Gathering Methods 

The BOP employs a number of methods to oversee religious 

activities, including staff observation, electronic monitoring, and physical 

inspections. As described to us during our fieldwork, the primary 

responsibility for observing and supervising worship services and 

religious classes in the chapel rests with the staff chaplains. 

According to BOP officials at Headquarters and in the field, the 

supervision of contractors, volunteers, and inmates who lead services 

and classes in the chapel is intermittent.37 BOP staff members are not 

required to be in the same room continuously with religious service 

providers and, instead, observe them only periodically. The frequency of 

staff observations varied at the facilities we visited. At one institution, 

the supervisory chaplain stated that his staff must perform a “walk 

around” every hour, while another chaplain stated that this task must be 

performed every 30 minutes to an hour. At another facility, the 

supervisory chaplain said that chaplains must check on religious 

services providers every 15 minutes but was unsure if this requirement 

was embodied in a written policy. 

During our fieldwork, we observed significant differences in the 

level of supervision that correctional officers provided to religious services 

and meetings – differences that could not be explained by institution 

security level. At one prison, the captain of the correctional officers 

explained that the chaplains are responsible for monitoring activities in 

the chapel and that the only time he would send an officer to assist with 

supervision is when one of the chaplains is absent. A captain at a 

different institution explained that the correctional officers visit the 

chapel “sometimes,” but most often they rely on the chaplains to provide 

supervision. A lieutenant at a third facility explained that “any good 

lieutenant working any shift will not rely on chaplains to watch all the 

inmates” and that it is important for the custodial staff to make a 

presence in the chapel because it acts as a deterrent to misconduct. One 

Muslim chaplain also told us that, based on his experiences, the level of 

supervision over chapel activities varies by institution. 

Moreover, it was apparent to us that at certain facilities the 

supervising correctional officers and the associate warden who oversees 

chaplaincy services were not familiar with chapel activities. For example, 

 37 This does not include Level 1 volunteers who must be escorted at all times. 

40
at one institution the captain of the correctional officers told us that 

Islamic services are conducted entirely in English and both the captain 

and associate warden stated categorically that inmates were not allowed 

to lead services. When we observed the chapel, however, an inmate was 

leading a service in one of the classrooms and Arabic was spoken 

periodically throughout the Muslim worship service. 

Several BOP staff members stated that the effectiveness of 

supervision by correctional officers could be enhanced with additional 

training. One associate warden said that he was not confident that 

correctional officers could detect radical religious messages (“not a whole 

lot of folks are in tune with that kind of stuff”), and a captain explained 

that if his staff had more training on Islam they would be better able to 

detect inappropriate messages. 

In addition to direct staff observation, the BOP relies upon cameras 

to monitor activities in some chapel service areas and classrooms. At the 

four facilities we visited, a camera was present in the worship areas at 

two facilities, and in two classrooms at another facility. One associate 

warden told us that the use of cameras had significantly reduced inmate 

fighting and strongly deterred inmates from inappropriate conduct. One 

Muslim chaplain told us that there should be more cameras in the 

chapel, and a supervisory chaplain stated that cameras should be placed 

in the classrooms. 

 

While the BOP has video cameras in some worship areas and 

chapel classrooms, however, it does not rely upon audio monitoring for 

routine supervision of religious services in its facilities. Audio monitoring 

is not currently employed in any BOP chapels to evaluate the messages 

that religious services providers deliver to inmates. Some correctional 

officers said that the ability to listen in on worship services and 

classroom instruction would benefit security and would be a deterrent to 

the expression of radical messages. 

Physical inspections also are a component of security procedures 

in the chapel. One lieutenant explained that the chapel is routinely 

checked for contraband, and inmates are pat-searched as they enter and 

exit the chapel for services and classes. Reading materials that are 

delivered to the chapel library also are screened by the chaplaincy staff. 

Several of the institutions we visited, however, did not have an inventory 

of the books currently available to the inmates, and none of the library 

collections had been re-screened since the September 11 terrorist 

attacks. We were told by one Muslim chaplain that not all religious 

materials that come into BOP institutions are being screened by the 

BOP’s chaplains. We found that inmates are allowed to order books, 

which are delivered to them directly from the institution mailroom unless 

41
the mailroom screener first routes the material to the chaplains for 

review. 

The BOP collects intelligence and security information from a 

variety of sources, including staff, inmate informants, and other law 

enforcement agencies. Nearly every BOP staff member we interviewed 

believed that if a Muslim radical infiltrated a BOP facility and began 

expressing his views, an inmate would report the conduct. According to 

one lieutenant, “inmates are knocking down our doors to tell us things.” 

Another lieutenant told us that he had inmate informants in virtually 

every known group of inmates in the institution. Intelligence on inmates 

also is generated by the BOP’s Sacramento Intelligence Unit, which 

distributes a weekly bulletin to BOP facilities. Captains at several of the 

BOP institutions we visited further said that their emergency 

preparedness coordinators had contacts with the local JTTF. A captain 

at one facility stated that he believed that a member of his intelligence 

staff should be a member of the JTTF because information sharing is a 

paramount concern. 

C. Inmate-Led Services 

Some staff members we interviewed stated that they were troubled 

by the practice of allowing inmates to lead religious services. According 

to one chaplain, “inmates look for things to control and the chapel is a 

good place to do that.” One associate warden told us that allowing an 

inmate to lead a service would “put the inmate on a pedestal,” elevating 

the inmate’s stature, which could lead to security problems. At one 

facility where inmates were leading the Muslim services, the chaplain 

could not describe how the inmates were selected for their position, 

whether by vote of the inmates, self-appointment, or otherwise. 

VI. OIG ANALYSIS 

Based on our review, we concluded that the BOP’s selection 

process needs improvement to further protect the BOP from hiring 

religious services providers who could pose security threats. We found 

that the BOP made some improvements after we initiated this review, but 

we believe additional changes are necessary to address deficiencies in the 

BOP’s selection and supervision of religious service providers. 

With regard to chaplains, the BOP requires Muslim chaplain 

candidates to obtain graduate school accreditation in Islam, have two 

years of full-time pastoral experience, provide three personal references, 

supply recommendations from previous employers, receive an 

endorsement from an Islamic national organization, have a 

pre-employment screening interview and a panel interview, and undergo 

42
a criminal history check, drug screening urinalysis, and background 

investigation. These requirements appear to have identified appropriate 

chaplain candidates. According to the Chief of the Chaplaincy Services 

Branch, none of the BOP’s Muslim chaplains has been of concern to the 

FBI or caused problems for the BOP. 

With regard to contractors, the BOP requires applicants to provide 

documentation of their religious and ministerial role within the Islamic 

community, obtain an endorsement from a local Islamic organization, 

provide contact information for their employers for the past five years, be 

interviewed by the institution’s program manager, and undergo a 

criminal history check and drug screening urinalysis. Volunteers are 

required to obtain an endorsement from a local Islamic organization, 

provide verifiable religious credentials, undergo a criminal history check, 

and be interviewed by the institution’s program manager if they are 

Level 2 volunteers. Unlike the Muslim chaplains, a few of the BOP’s 

Muslim contractors or volunteers, such as Warith Deen Umar, have been 

of concern to the FBI or been dismissed from the BOP for inappropriate 

behavior such as making extremist statements and appearing to give 

preferential treatment to inmates. 

 

With regard to endorsing organizations, before the OIG initiated 

this review, the BOP required national endorsers to provide a statement 

of their beliefs and practices, proof of their tax-exempt status, an 

endorsement for their candidate, and a completed application form that 

asked endorsers how they select candidates, what criteria they use to 

determine which candidates are qualified as professional ministers, and 

how the candidate will receive the official endorsement of the 

organization. However, the BOP did not check with the FBI for 

information on these organizations. 

After the OIG initiated this review in March 2003, the BOP began 

requiring national endorsing organizations to submit an additional form 

certifying that their organizations do not promote separatism, terrorism, 

or violence. In addition, in April 2003 the BOP began to seek assistance 

from the FBI with screening out potentially extremist contractors and 

volunteers. In October 2003, the BOP began to seek assistance from the 

FBI with screening out endorsing organizations that may be attempting 

to infiltrate the BOP to radicalize or recruit inmates for terrorist acts. 

According to the SDAD of the Correctional Programs Division, the BOP 

intends to continue screening new national and local Muslim endorsing 

organizations through the FBI, as well as the names of all new 

contractors and Level 2 volunteers, regardless of faith. The BOP also 

plans to wait until it receives the FBI’s results from these screenings 

before it grants applicants access to BOP institutions. 

43
In addition, the BOP and FBI have taken steps to improve their 

information sharing. For example, the BOP has made formal requests to 

the FBI for information and assessments on contractors, volunteers, and 

endorsing organizations, and a senior official from the BOP met in 

December 2003 with a senior official from the FBI to discuss concerns 

about the BOP’s selection of Muslim chaplains, contractors, and 

volunteers. 

While the BOP has taken several steps towards improving its 

selection process, we believe additional changes are necessary to address 

deficiencies in the BOP’s selection and supervision of religious service 

providers. 

For example, the BOP still does not screen doctrinal beliefs of 

chaplains, contractors, or volunteers. BOP officials expressed some 

concern to the OIG that such screening would not be legally permissible. 

According to the BOP’s General Counsel, the BOP Office of General 

Counsel (OGC) has not thoroughly analyzed this legal issue, but it 

believes screening chaplain, contractor, or volunteer applicants on the 

basis of their beliefs rather than their actions or statements may violate 

Title VII of the Civil Rights Act of 1964 or the First Amendment. 

We believe, based on our review of the case law, that the BOP 

legally may screen all chaplain candidates by asking them questions 

about their beliefs. The responses to these questions can provide 

important information for the BOP to determine whether the candidates 

pose a security threat. Pursuant to the Religious Freedom Restoration 

Act (RFRA), the BOP may “substantially burden” a person’s exercise of 

religion if the BOP’s actions are the “least restrictive means” of furthering 

a “compelling state interest.”38 Many courts have determined that a 

correctional institution’s maintenance of security, safety, and orderliness 

qualifies as a “compelling interest.”39 Moreover, prison officials are 

entitled to take action based on potential threats to institution security or 

 38 Religious Freedom Restoration Act, 42 U.S.C. § 2000bb (2000). The RFRA 

standard for burdening an individual’s free exercise of religion in a prison context is 

more stringent than the constitutional standard. Under the U.S. Constitution, the BOP 

may impinge on a person’s exercise of religion if the BOP’s actions are “reasonably

related to legitimate penological interests.” See O’Lone v. Estate of Shabazz, 482 U.S.

342, 349 (1987). Therefore, if the BOP’s screening of applicants’ religious beliefs meets 

the RFRA standard, it would likely meet the constitutional standard as well. 

39 See Hines v. South Carolina Dep’t of Corrections, 148 F.3d 353, 358 (4th Cir.

1998); Mack v. O’Leary, 80 F.3d 1175, 1180 (7th Cir.), cert. granted, judgment vacated 

on other grounds, 522 U.S. 801 (1997); Winburn v. Bologna, 979 F. Supp. 531, 535

(W.D. Mich. 1997); Woods v. Evatt, 876 F. Supp. 756, 769 (D.S.C. 1995). Cf. Bell v. 

Wolfish, 441 U.S. 520, 546-547 (1979); Kikumura v. Hurley, 242 F.3d 950, 962 (10th

Cir. 2001).

44
the anticipation of security problems,40 and are accorded deference in 

creating regulations and policies directed at the maintenance of prison 

safety and security.41 Therefore, we believe that the law allows the BOP, 

for security purposes, to ascertain from chaplain, contractor, and 

volunteer applicants information to determine whether their religious 

beliefs include: 1) endorsement of violence, 2) support of terrorism or 

other anti-U.S. activities, or 3) discrimination against other inmates or 

exclusion of other inmates from their services, whether based on race, 

religion, or other discriminatory factors. 

Thus, we believe, based upon our initial review, that screening 

religious services applicants’ beliefs is legally permissible. We encourage 

the BOP’s OGC, in conjunction with DOJ attorneys, to carefully evaluate 

this legal issue. It is critical for the security of federal prisons that the 

BOP determine whether religious services providers support violence; 

terrorism; anti-U.S. activities; or discrimination or exclusion of other 

inmates, whether based on race, religion, or other discriminatory factors, 

before they are allowed access to inmates. 

In addition to not screening religious services providers’ doctrinal 

beliefs, the BOP does not request assistance from the BOP Muslim 

chaplains in recruiting or screening chaplains, contractors, and 

volunteers. However, we believe that the Muslim chaplains are a 

valuable resource within the BOP for preventing inmate radicalization 

and can assist with the recruitment and selection of Muslims who have 

mainstream Islamic beliefs. No other group of BOP employees has as 

much expertise and experience with Islam as the chaplains. The Muslim 

chaplains stated that they would be able to discern whether a Muslim 

chaplain, contractor, or volunteer candidate was an Islamic extremist in 

part by knowing who his teachers were and what mosques he has 

attended. However, the BOP currently does not request this kind of 

information from applicants or discuss it with the chaplains to determine 

whether there is a problem with the candidates’ views. The chaplains 

suggested that the BOP could have them review Muslim candidates’ 

application forms, references, and endorsement letters. They said that 

based on this information, they could flag any concerns with the 

applicants and suggest questions that BOP interviewers could ask them. 

 40 Whitley v. Albers, 475 U.S. 312, 323 (1986); Hewitt v. Helms, 459 U.S. 460,

474 (1983); Jones v. North Carolina Prisoners’ Labor Union, Inc., 433 U.S. 119, 132-

133 n.9 (1977); Procunier v. Martinez, 416 U.S. 396, 405 (1974); Butler-Bey v. Frey, 

811 F.2d 449, 451 (8th Cir. 1987).

41 O’Lone, 482 U.S. at 353; Bell, 441 U.S. at 547; Hamilton v. Schriro, 74 F.3d 

1545, 1556 (8th Cir. 1996).

45
Moreover, the BOP does not encourage its chaplains to seek 

information from their local communities on individuals who have 

applied to be religious contractors and volunteers in their institutions. 

To the extent chaplains are able to obtain this type of information on 

religious contractor and volunteer applicants, regardless of faith, it would 

assist the BOP in identifying and screening out individuals with 

extremist views. 

The BOP also has not developed a recruitment strategy specifically 

focused on identifying and hiring qualified Muslim chaplains and 

contractors, and recruiting Muslim volunteers. While there are many 

factors affecting the BOP’s ability to successfully recruit Muslim religious 

services providers, one of the main reasons the BOP is experiencing a 

critical shortage of Muslim chaplains and a deficiency of Muslim 

contractors and volunteers is that it does not have an official program or 

strategy specifically focused on recruiting Muslim religious services 

providers. The BOP needs to develop such a strategy and increase the 

number of Muslim religious services providers in its institutions in order 

to accommodate sufficiently the religious needs of Muslim inmates and 

further protect institutions from Prison Islam and inmates’ radicalization 

efforts. The lack of Muslim religious services providers in the BOP gives 

inmates more opportunities to radicalize other inmates by leading 

religious services. 

Moreover, the BOP has not developed alternative endorsement 

policies for Muslim chaplains now that it is not accepting ISNA-endorsed 

candidates. This has resulted in a hiring freeze on Muslim chaplains, 

which contributes to the BOP’s critical shortage of Muslim chaplains. 

While the Chief of the Chaplaincy Services Branch said she would 

consider accepting endorsements from local organizations for Muslim 

chaplains, the BOP has not developed a policy prescribing when local 

endorsements will be accepted in lieu of national endorsements. Hiring 

more Muslim chaplains to meet the religious needs of Muslim inmates is 

essential to deterring radicalization and Prison Islam. 

The BOP also does not require Muslim chaplains, contractors, or 

Level 2 volunteers to be interviewed by anyone knowledgeable about 

Islam. Interviewers who are unfamiliar with Islam and radical beliefs 

within Islam are unlikely to be able to discern whether a Muslim 

candidate poses a security threat. 

In addition, the BOP does not require an in-depth panel interview 

for contractors and volunteers. The Chief of the Chaplaincy Services 

Branch asserted that because of the extensive contact contractors and 

volunteers have with inmates, she supports requiring contractor and 

Level 2 volunteer applicants to be interviewed more thoroughly by a 

46
panel consisting of a chaplain, a security officer, and a human resources 

official from the BOP institution where the applicants will work.42 

Moreover, the BOP’s Muslim chaplains suggested that Muslim contractor 

applicants be asked questions that would explore how they would handle 

hypothetical correctional scenarios and discuss their motivation for 

working in the prisons. We believe the BOP will be able to screen 

contractors and volunteers more adequately if they are given more 

thorough interviews such as the panel interviews given to chaplain 

candidates. 

The BOP does not ask whether chaplains, contractors, or 

volunteers have received funds from foreign governments. In addition, it 

does not verify chaplains’ foreign travel or ask contractors or volunteers 

to report the professional, civic, and religious organizations in which they 

hold membership. This information could help the BOP better determine 

whether applicants have extremist beliefs or pose a security threat to 

institutions. 

As of April 13, 2004, the FBI still had not shared with the BOP the 

information it has on Muslim endorsing organizations. We were told that 

the FBI is awaiting legal clearance to release to the BOP the classified 

and sensitive information it has gathered on the organizations. As a 

result, the BOP has not yet been able to make assessments of its 

endorsing organizations or decide whether to continue using them. 

The BOP and the FBI continue to exchange almost all information 

regarding the radicalization of inmates through the BOP detailee to the 

NJTTF. We found that this process is flawed because the BOP has not 

received critical information from the FBI about endorsing organizations’ 

possible connections to terrorism. The BOP detailee has many NJTTF 

responsibilities and may not be able to serve effectively as the sole 

conduit for the FBI-BOP information-flow.43 Other agencies such as the 

Secret Service and the Immigration and Customs Enforcement assign 

permanent liaisons to the FBI, in addition to their detailees on the 

NJTTF, to assist in exchanging information. 

With regard to BOP supervision practices, our examination 

revealed that the BOP relies on various methods to oversee its religious 

 42 In comments to a draft of this report, the Chief of the Chaplaincy Services 

Branch clarified that she does not believe it is necessary to conduct panel interviews of 

religious services contractors and volunteers who average four to eight hours in a BOP 

institution per month and have very limited contact with inmates. 

43 The OIG is conducting a separate evaluation that is examining the NJTTF and 

expects to issue a report later this year that addresses various aspects of the NJTTF’s 

operations, including information sharing and training for NJTTF detailees. 

47
services providers and inmates, including direct staff supervision and 

electronic monitoring, but significant gaps remain. Once an individual is 

allowed entry to a BOP institution and therefore has a platform to 

instruct inmates or to lead them in worship, ample opportunity exists for 

them to deliver inappropriate messages without the direct oversight of 

BOP personnel. With few exceptions, contractors, unescorted volunteers, 

and inmates who lead services are subject only to intermittent 

supervision. Service areas and chapel classrooms frequently lack 

cameras, and audio monitoring currently is not employed. Our fieldwork 

also identified significant differences in the level of supervision or 

observation of them by chaplains or correctional officers, and that BOP 

staff did not always understand the frequency with which they were 

supposed to observe religious services providers. Supervisory 

correctional officers and BOP managers further advised us that many 

correctional officers are not familiar with Islam, and that this lack of 

knowledge may limit their ability to recognize radical Islamist messages 

that are inappropriate in BOP facilities. 

BOP staff members were consistent in their views that the most 

significant radicalization threat comes from the inmates and not from 

chaplains, contractors, and volunteers. Many of the BOP staff we 

interviewed also emphasized that allowing inmates to lead services posed 

security risks, and in one institution we were told the practice was 

prohibited for security reasons.44 Although BOP staff acknowledged the 

importance of a rigorous selection process for religious services 

providers, they repeatedly told us that they had not encountered 

significant problems with chaplains, volunteers, and contractors, and 

that if such persons were Islamic radicals they would be identified 

quickly because of inmate reporting and other detection methods.45 

We believe that the BOP should evaluate the feasibility of having 

correctional officers provide intermittent supervision of all religious 

activities to supplement the supervision provided by chaplaincy staff. As 

a further means to enhance supervision of religious services, the BOP 

should evaluate the cost, legality, and feasibility of expanding video or 

audio monitoring of all worship areas and chapel classrooms. To better 

 44 As explained above, however, we observed an inmate leading a service at this 

institution. 

45 We note that in the case of former BOP contractor Warith Deen Umar, 

described above, BOP staff observed Umar repeatedly give sermons that violated BOP 

security policies but failed to terminate his contract. Several of his Contractor Progress 

Reports explain that he “disparages Judaism and Christianity” and that his “sermons

are sometimes not appropriate; has been spoken to.” Despite this conduct, the same 

Reports provide him with “Good” or “Excellent” marks for the “Quality of

Goods/Services” rendered. 

48
ensure that correctional officers are familiar with Islam and can 

recognize radical Islamist messages that are inappropriate in BOP 

facilities, the BOP also should provide training on Islam and 

radicalization to its correctional officers. 

Another significant problem identified by BOP staff was the 

practice of allowing inmates to lead religious services. Many BOP 

officials and employees said they do not believe that it is appropriate for 

inmates to assume leadership positions in BOP facilities, including the 

position of surrogate chaplain. We agree. Too many opportunities for 

abuse of this practice exist. We think that the BOP should restrict the 

use of inmates to lead religious services. For example, in facilities where 

inmates presently are leading services, the BOP should evaluate the 

feasibility of providing Internet video feeds to chapel areas for Juma 

prayer by a BOP Muslim chaplain. 

In addition, the BOP does not require inmate-led religious services 

to be monitored constantly by a staff member. Rather, staff must 

supervise inmate-led services only intermittently, like services led by 

contractors or Level 2 volunteers. As a result, inmates have the 

opportunity to deliver radical messages during religious services 

undetected by BOP staff. Staff supervision at inmate-led services is 

essential to deterring and preventing inmate radicalism. 

The BOP does not require contractors to submit to the chaplains 

lesson plans or an outline of what they intend to cover during services. 

The Chief of the Chaplaincy Services Branch expressed concern that 

making contractors submit their lesson plans for approval would deter 

people from working for the BOP. However, she said that the SOW for 

religious contractors could include the themes and topics on which 

contractors are to focus and list the specific things contractors are not 

allowed to say as part of their messages (i.e., advocate violence, make 

statements against the United States, or make exclusionary statements). 

Our discussions with the BOP’s Muslim chaplains revealed that 

they are discouraged from assisting non-Muslim chaplains in other 

facilities with supervision issues related to the practice of Islam, 

including problems concerning radicalization. We believe this is a 

serious error and that the BOP could better use the expertise of its 

Muslim chaplains. Few other BOP employees have the degree of 

knowledge and experience with Islam to advise BOP staff members 

adequately on matters related to Islamic radicalization. For example, to 

improve supervision practices in facilities that do not have a Muslim 

chaplain, the BOP could encourage staff members from those facilities to 

consult with the Muslim chaplains at other facilities to address potential 

or actual radicalization problems. 

49
Our fieldwork also revealed that supervision of chapel libraries is 

not as thorough as it should be. None of the chaplains at the facilities 

that we visited was able to produce an inventory of the books and videos 

available to the inmates, and it did not appear that these materials had 

been evaluated after the terrorist attacks of September 11. We 

recommend that the BOP undertake an inventory of chapel books and 

videos to confirm that they are permissible under BOP security policies. 

The BOP also should consider maintaining a central registry of 

acceptable material to prevent duplication of effort when reviewing these 

materials. 

Lastly, we found that not all of the BOP facilities we visited were 

working closely with the local JTTF. BOP facilities should be fully 

integrated into local counterterrorism initiatives. We recommend that all 

BOP facilities maintain at least a liaison with their local JTTF. 

VII. OIG RECOMMENDATIONS 

We believe the BOP can and should improve its process for 

selecting, screening, and supervising Muslim religious services providers. 

We therefore offer a series of recommendations to address the issues we 

examined in our review. 

A. Screening of Religious Services Providers 

1. The BOP should screen all religious services providers’ 

doctrinal beliefs. Currently the BOP does not screen 

religious services providers’ religious and doctrinal beliefs. 

Instead, it relies on the candidates’ endorsements to certify 

that they will minister to inmates of all faiths and provide 

appropriate religious services in a prison setting. However, it 

is essential to the security of the BOP that candidates who 

have extreme views and who pose a security threat not be 

allowed into the prisons. 

We recommend the BOP take steps to examine all chaplains’, 

religious contractors’, and religious volunteers’ doctrinal 

beliefs to screen out anyone who poses a threat to security. 

For example, the BOP could ask chaplains, contractors, and 

Level 2 volunteers doctrinal questions in their interviews and 

require them to submit a statement of faith with their 

applications. We recommend that the BOP OGC examine 

this issue to determine what screening procedures are legally 

permissible. The BOP’s screening of candidates’ religious 

and doctrinal beliefs should be for security purposes only, 

50
not to assess the purity of candidates’ views or serve as an 

approval or endorsement of their religious beliefs. The BOP 

also should develop a list of criteria to use when screening 

individuals. At the least, this list should include: 

1) endorsement of violence, 2) support of terrorism or other 

anti-U.S. activities, and 3) discrimination against other 

inmates or exclusion of other inmates from religious services, 

whether based on race, religion, or other discriminatory 

factors. In addition, the BOP should consider requesting 

that OPM’s background investigations examine chaplains’ 

past statements and conduct in religious communities. 

2. The BOP should require all chaplain, religious contractor, 

and religious Level 2 volunteer applicants to be 

interviewed by at least one individual knowledgeable of 

the applicant’s religion. This individual could be a BOP 

chaplain, BOP official, or member of an interfaith chaplain 

advisory board created by the BOP for the purpose of 

interviewing chaplain candidates. However, if the BOP 

creates an interfaith chaplain advisory board, members of 

the board must be screened sufficiently to ensure they do 

not hold views contrary to BOP policy, including advocating 

violence, supporting terrorism, or discriminating against 

people of certain races or religions. 

3. The BOP should require panel interviews for all religious 

contractors and Level 2 volunteers. Because of the 

extensive contact contractors and volunteers have with 

inmates, we recommend the BOP require contractor and 

Level 2 volunteer applicants to be interviewed thoroughly by 

a panel consisting of a chaplain, a security officer, and a 

human resources official from the BOP institution where the 

applicants will work. The BOP likely will be able to screen 

contractors and volunteers more adequately if they are given 

more thorough interviews such as the panel interviews given 

to chaplain candidates. 

4. The BOP should implement further security screening 

requirements for religious services providers. The BOP 

should ask chaplains and religious contractors whether they 

have ever received funds from foreign governments. The BOP 

should ask contractors and Level 2 volunteers to report the 

professional, civic, and religious organizations in which they 

hold membership. In addition, the BOP should verify 

chaplains’ foreign travel to determine whether they have 

51
spent a significant amount of time in a country that does not 

have diplomatic relations or treaties with the United States. 

5. The BOP should encourage chaplains to seek information 

about contractor and volunteer applicants from their 

local communities. We recommend that the BOP 

encourage chaplains at institutions hiring contractors and 

volunteers to seek information from their local communities 

about individuals applying to be religious services 

contractors or volunteers. 

B. FBI-BOP Information Flow 

 

6. The BOP should take steps to improve and increase the 

information flow between the BOP and the FBI. Our 

review indicated that the information flow between the FBI 

and the BOP regarding the radicalization and recruitment of 

inmates needs improvement. While the recent creation of 

the Joint Intelligence Coordinating Council (JICC) might help 

improve FBI-BOP information sharing on inmate 

radicalization issues, we believe that additional steps need to 

be taken to further improve information flow. We 

recommend that the BOP not rely exclusively on the BOP 

detailee to the NJTTF or the creation of the JICC for this 

information flow, but consider assigning a liaison to the FBI, 

like other agencies do, to improve the exchange of 

information about the radicalization and recruitment of 

inmates. In addition, we recommend that BOP officials meet 

periodically with FBI officials regarding joint efforts to 

prevent the radicalization of inmates. 

C. Reliance on Staff Muslim Chaplains 

7. The BOP should more effectively use the expertise of its 

current Muslim chaplains to screen, recruit, and 

supervise Muslim religious services providers. The BOP 

should utilize its Muslim chaplains more effectively by 

having them review the applications, references, and 

endorsements of potential Muslim chaplains, contractors, 

and volunteers. We also recommend the BOP consider 

having at least one Muslim chaplain serve on the interview 

panel for Muslim chaplain candidates. 

52
D. Recruiting Muslim Religious Services Providers 

8. The BOP should develop a strategy specifically targeted 

towards recruiting Muslim religious services providers. 

Currently the BOP does not have enough Muslim chaplains, 

contractors, and volunteers compared to the size of its 

Muslim inmate population. As a result, inmates are leading 

religious services, which presents prison security and 

national security concerns. Recruiting qualified Muslim 

religious services providers could reduce inmate-led services, 

Prison Islam, and radicalization. We recommend that the 

BOP develop a strategy specifically for recruiting Muslim 

chaplains, contractors, and volunteers. For this strategy, the 

BOP should consider having BOP personnel reach out more 

to Muslim communities or enabling Muslim chaplains to 

spend part of their work hours recruiting. 

E. Endorsements 

9. The BOP should consider implementing alternative 

endorsement requirements for Muslim chaplains. 

Presently the BOP is experiencing a hiring freeze on Muslim 

chaplains because it will not accept endorsements from any 

Islamic organizations until it receives information on those 

organizations from the FBI. In addition, no other national 

organization besides the ISNA is authorized to endorse 

Muslim chaplains. Moreover, the BOP will not hire 

chaplains who have endorsements from national 

organizations about which the FBI has derogatory 

information. We recommend the BOP consider developing 

alternative endorsing requirements for Muslim chaplains, 

such as permitting endorsements from local or regional 

organizations in specific situations. 

F. Supervision 

10. The BOP should evaluate the feasibility of having 

correctional officers provide intermittent supervision to 

all chapels to supplement the supervision provided by 

chaplaincy staff. As a further means to enhance 

supervision of religious services, the BOP should 

evaluate the cost, legality, and feasibility of audio and 

video monitoring to include all worship areas and chapel 

classrooms. With few exceptions, individuals who lead 

religious services in BOP facilities are subject to only limited 

supervision. As a result, once contractors and volunteers 

53
gain access to BOP facilities, ample opportunity exists for 

them to deliver inappropriate messages without direct 

supervision from BOP staff members. Our fieldwork 

identified significant differences in the level of support 

provided to chaplains by correctional officers. We also 

observed that video coverage of BOP chapels varies by 

institution, and that audio monitoring is not employed. We 

believe that the BOP should evaluate options to make chapel 

supervision more thorough and consistent Bureau-wide. 

11. The BOP should limit and more closely supervise inmateled religious services. Inmates are radicalized primarily by 

other inmates. We do not believe that it is appropriate for 

inmates to assume leadership positions in BOP facilities, 

including the position of surrogate chaplain. We recommend 

that the BOP take steps to reduce inmate-led religious 

services. For example, in facilities where inmates presently 

are leading Juma services, the BOP should evaluate the 

alternative of providing Internet video feeds to chapel areas 

for Juma prayer by a BOP Muslim chaplain. The BOP also 

should consider requiring inmate-led services to be 

monitored by staff constantly rather than intermittently.

12. The BOP should provide its staff with training on Islam. 

Supervisory correctional officers and BOP managers advised 

us that many correctional officers are not familiar with 

Islam, and that this lack of knowledge may limit their ability 

to recognize radical Islamist messages that are inappropriate 

in BOP facilities. At a minimum, we believe that the BOP 

should provide basic training to its staff members who 

supervise Muslim religious services so that they will be 

familiar with accepted prayer and service rituals, understand 

Islamic terminology, and recognize messages that violate 

BOP security policy.

13. To improve supervision practices in facilities that do not 

have a Muslim chaplain, the BOP should encourage staff 

members from those facilities to consult with the BOP 

Muslim chaplains to address potential or actual 

radicalization problems. Our review found that the BOP is 

not fully using the expertise of its staff Muslim chaplains. 

These individuals have knowledge and abilities that can and 

should be used to assist the BOP to address radical 

influences. 

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14. The BOP should include in contractors’ SOWs the 

themes and topics on which they should focus. The BOP 

should provide contractors guidance on what they are to 

teach during religious services by including topics and 

themes to be discussed with inmates in contractors’ SOWs. 

The SOWs also should include specific things contractors 

are not allowed to say as part of their messages, such as 

statements that support violence, denigrate the United 

States, or disparage other inmates or other faith groups. 

15. The BOP should conduct an inventory of chapel books 

and videos and re-screen them to confirm that they are 

permissible under BOP security policies. The BOP 

should consider maintaining a central registry of 

acceptable material to prevent duplication of effort 

when reviewing these materials. Of the institutions we 

visited, several did not have an inventory of the books 

currently available to the inmates, and none of the 

collections had been re-screened since the September 11 

terrorist attacks. 

16. BOP facilities should maintain a liaison with their local 

JTTF. BOP facilities should be fully integrated into local 

counterterrorism initiatives. Our review revealed that not all 

BOP facilities are working closely with their local JTTF. 

VIII. CONCLUSION 

Religious services providers are in a unique position to influence 

the beliefs and conduct of inmates. The presence of extremist chaplains, 

contractors, or volunteers in the BOP’s correctional facilities can pose a 

threat to institutional security and could implicate national security if 

inmates are encouraged to commit terrorist acts against the 

United States. For this reason, it is imperative that the BOP has in place 

sound screening and supervision practices that will identify persons who 

seek to disrupt the order of its institutions or to inflict harm on the 

United States through terrorism. 

We recognize that the BOP has made significant improvements 

since our review was initiated in March 2003 to better screen extremist 

religious services providers. However, our review found that while the 

BOP has not identified widespread problems with inmate radicalization 

and terrorist recruiting, chaplaincy services in the BOP remain 

vulnerable to infiltration by religious extremists, and supervision 

practices in BOP chapels need strengthening. For example, the BOP 

currently does not screen religious services providers’ doctrinal beliefs to 

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determine whether the providers pose a security threat. Moreover, once 

granted access to an institution, the providers typically have ample 

opportunity to deliver messages without supervision from BOP staff. The 

BOP also does not effectively use the expertise of its current Muslim 

chaplains to screen, recruit, and supervise Muslim religious services 

providers. In addition, the BOP has not developed a recruiting strategy 

or alternative endorsement requirements to end its shortage of Muslim 

chaplains. Furthermore, the FBI and the BOP have not effectively 

exchanged information about endorsing organizations’ possible 

connections to terrorism. In our view, these and other practices 

identified in this report create unnecessary risks to prison and national 

security. 

This report includes a series of recommendations that address the 

deficiencies we identified during our review. We believe that the BOP 

needs to carefully evaluate and implement these recommendations to 

improve its selection and supervision of religious services providers.

 

 

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