Combating Terrorism: Foreign Terrorist Organization Designation Process and U.S. Agency Enforcement Actions
Published: 2015-06-25T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Secretary of State, in consultation with the Secretary of the Treasury and the Attorney General, has the authority to designate a foreign organization as an FTO. Designation allows the United States to impose legal consequences on the FTO or on individuals who support the FTO. As of June 1, 2015, 59 organizations were designated as FTOs.
GAO was asked to review the FTO designation process. This report provides information on the process by which the Secretary of State designates FTOs. Specifically, this report addresses (1) the process for designating FTOs, (2) the extent to which the Department of State considers input from other agencies during the FTO designation process, and (3) the consequences that U.S. agencies impose as a result of an FTO designation.
To address these objectives, GAO reviewed and analyzed agency documents and data, and interviewed officials from Departments of Defense, Homeland Security, Justice, State, and the Treasury, as well as the intelligence community.
Separately, GAO also reviewed the duration of the designation process for FTOs designated between 2012 and 2014. That information was published in April 2015 in a report for official use only.
GAO is not making recommendations in this report.
section_title: What GAO Found
paragraphs: The Department of State (State) has developed a six-step process for designating foreign terrorist organizations (FTO) that involves other State bureaus and agency partners in the various steps. State's Bureau of Counterterrorism (CT) leads the designation process for State. CT monitors terrorist activity to identify potential targets for designation and also considers recommendations for potential targets from other State bureaus, federal agencies, and foreign partners. After selecting a target, State follows a six-step process to designate a group as an FTO, including steps to consult with partners and draft supporting documents. During this process, federal agencies and State bureaus, citing law enforcement, diplomatic, or intelligence concerns, can place a “hold” on a potential designation, which, until resolved, prevents the designation of the organization. The number of FTO designations has varied annually since 1997, when 20 FTOs were designated. As of December 31, 2014, 59 organizations were designated as FTOs, with 13 FTO designations occurring between 2012 and 2014.
State considered input provided by other State bureaus and federal agencies for all 13 of the FTO designations made between 2012 and 2014, according to officials from the Departments of Defense, Homeland Security, Justice, State, and the Treasury, and the Office of the Director of National Intelligence, and GAO review of agency documents. For example, State used intelligence agencies' information on terrorist organizations and activities to support the designations.
U.S. agencies reported enforcing FTO designations through three key legal consequences—blocking assets, prosecuting individuals, and imposing immigration restrictions—that target FTOs, their members, and individuals that provide support to those organizations. The restrictions and penalties that agencies reported imposing vary widely. For example, as of 2013, Treasury has blocked about $22 million in assets relating to 7 of 59 designated FTOs.

section_title: Letter
paragraphs: U.S. agencies, including components of the Departments of Defense,  Homeland Security, Justice, State, and the Treasury, and the intelligence  community, have implemented procedures to collect and share  information about and take action on terrorists posing a threat to the  national security of the United States. The Secretary of State, in  consultation with the Secretary of the Treasury and the Attorney General,  may identify and designate certain groups as foreign terrorist  organizations (FTO), a designation that can result in criminal and civil  penalties, as well as other financial and immigration consequences for  designated FTOs or those who provide support to FTOs. Congress has  recently expressed concerns about the designation process.
You asked us to provide information on the designation of FTOs. In this  report, we provide information on (1) the process for designating FTOs,  (2) the extent to which the Department of State (State) considers input  from other agencies during the FTO designation process, and (3) the  consequences that U.S. agencies impose as a result of an FTO  designation.
To identify the FTO designation process, we identified the steps in the  FTO designation process by reviewing the legal requirements for  designation and the legal authorities granted to State and other U.S.  agencies to designate FTOs. In addition, we reviewed State documents  that identified and outlined State’s process to designate an FTO. To  assess the extent to which State considered input from other agencies  during the FTO designation process, we interviewed officials from the  Departments of Defense (Defense), Homeland Security (DHS), Justice  (Justice), State, and the Treasury (Treasury), as well as officials from the  intelligence community, to determine for the 13 FTOs designated  between 2012 and 2014 when information on organizations considered  for FTO designation is provided to State by its consulting partners, as well  as the nature of that information. We defined consideration as any action  of State to request, obtain, and use information from other federal  agencies, as well as letters of concurrence from those agencies. To  identify the consequences U.S. agencies impose as a result of FTO  designation, we (1) reviewed Treasury reports on blocked funds for FTOs  from 2008 through 2013, (2) reviewed data on the public/unsealed  terrorism and terrorism-related convictions to identify individuals who  provided material support or resources to an FTO or received military- type training from an FTO between 2009 and 2013, and (3) analyzed data  from State’s Bureau of Consular Affairs reports on visa denials between  fiscal years 2009 and 2013. We also reviewed the U.S. Customs and  Border Protection enforcement system database on arrival inadmissibility  determinations between fiscal years 2009 and 2014, and information from  DHS’s Immigration and Customs Enforcement on deportations between  fiscal years 2013 and 2014. In each instance, we analyzed the data  provided by the agencies, performed basic checks to determine the  reasonableness of the data, and discussed the data with relevant agency  officials to confirm the totals presented. We determined that these data  were sufficiently reliable for the purposes of our report. See appendix I for  more details on our scope and methodology.
We conducted this performance audit from April 2015 to June 2015 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
This report is a public version of a sensitive but unclassified (SBU) report  that was issued on April 21, 2015. State regarded some of the material in  that report as SBU information, which must be protected from public  disclosure and is available for official use only. This public version of the  original report does not contain certain information regarding the duration  of FTO designations between 2012 and 2014 that State deemed to be  SBU.
subsections: section_title: Background
subsections: section_title: FTO Designation Authority
paragraphs: Under section 219 of the Immigration and Nationality Act, as amended,  the Secretary of State, in consultation with the Secretary of the Treasury  and the Attorney General, is authorized to designate an organization as  an FTO. For State to designate an organization as an FTO, the  Secretary of State must find that the organization meets three criteria:  1.  It is a foreign organization.  2.  The organization engages in terrorist activity or terrorism, or retains  the capability and intent to engage in terrorist activity or terrorism.  3.  The organization’s terrorist activity or terrorism threatens the security  of U.S. nationals or the national security of the United States.
Designation of a terrorist group as an FTO allows the United States to  impose certain legal consequences on the FTO, as well as on individuals  that associate with or knowingly provide support to the designated  organization. It is unlawful for a person in the United States or subject to  the jurisdiction of the United States to knowingly provide “material support  or resources” to a designated FTO, and offenders can be fined or  imprisoned for violating this law. In addition, representatives and  members of a designated FTO, if they are not U.S. citizens, are  inadmissible to and, in certain circumstances, removable from the United  States. Additionally, any U.S. financial institution that becomes aware  that it has possession of or control over funds in which a designated FTO  or its agent has an interest must retain possession of or control over the  funds and report the funds to Treasury’s Office of Foreign Assets  Control.
section_title: Other Terrorist Designation Authorities
paragraphs: In addition to making FTO designations, the Secretary of State can  address terrorist organizations and terrorists through other authorities,  including listing an individual or entity that engages in terrorist activity  under Executive Order 13,224 (E.O. 13,224). E.O. 13,224 requires the  blocking of property and interests in property of foreign persons the  Secretary of State has determined, in consultation with the Attorney  General and the Secretaries of the Departments of Homeland Security  and the Treasury, to have committed or to pose a significant risk of  committing acts of terrorism that threaten the security of U.S. nationals or  the national security, foreign policy, or economy of the United States.  E.O. 13,224 blocks the assets of organizations and individuals designated  under the executive order. It also authorizes the blocking of assets of  persons determined by the Secretary of the Treasury, in consultation with  the Attorney General and the Secretaries of State and Homeland  Security, to assist in; sponsor; or provide financial, material, or  technological support for, or financial or other services to or in support of,  designated persons, or to be otherwise associated with those persons. In  practice, when State designates an organization as an FTO, it also  concurrently designates the organization under E.O. 13,224. Once State  designates an organization under E.O. 13,224, Treasury is able to make  its own designations under E.O. 13,224 of other organizations and  individuals associated with or providing support to the organization  designated by State under E.O. 13,224. These designations allow the  U.S. government to target organizations and individuals that provide  material support and assistance to FTOs.
section_title: State Uses a Six-Step Process for Designating Foreign Terrorist Organizations
paragraphs: State has developed a six-step process for designating foreign terrorist  organizations. State’s Bureau of Counterterrorism (CT) leads the  designation process for State, and other State bureaus and agency  partners are involved in the various steps. While the number of FTO  designations has varied annually since the first 20 FTOs were designated  in 1997, as of December 31, 2014, 59 organizations were designated as  FTOs.
FTO designation activities are led by CT, which monitors the activities of  terrorist groups around the world to identify potential targets for  designation. When reviewing potential targets, CT considers not only  terrorist attacks that a group has carried out but also whether the group  has engaged in planning and preparations for possible future acts of  terrorism or retains the capability and intent to carry out such acts. CT  also considers recommendations from other State bureaus, federal  agencies, and foreign partners, among others, and selects potential target  organizations for designation. For an overview of agencies and their roles  in the designation process, see appendix II. After selecting a target  organization for possible designation, State uses a six-step process it has  developed to designate a group as an FTO (see fig. 1).
Step 1: Equity check—The first step in CT’s process is to consult with  other State bureaus, federal agencies, and the intelligence  community, among others, to determine whether any law  enforcement, diplomatic, or intelligence concerns should prevent the  designation of the target organization. If any of these agencies or  other bureaus has a concern regarding the designation of the target  organization, it can elect to place a “hold” on the proposed  designation, which prevents the designation from being made until the  hold is lifted by the entity that requested it. The equity check is the first  step where an objection to a designation can be raised; however, in  practice, a hold can be placed at any step in the FTO designation  process prior to the Secretary’s decision to designate.
Step 2: Administrative record—As required by law, in support of the  proposed designation, CT is to prepare an administrative record,  which is a compilation of information, typically including both classified  and open source information, demonstrating that the target  organization identified meets the statutory criteria for FTO  designation.
Step 3: Clearance process—The third step in CT’s process is to send  the draft administrative record and associated documents to State’s  Office of the Legal Adviser and then to Justice and Treasury for  review and approval of a final version to submit to the Secretary of  State. For clearance, Justice and Treasury are to review the draft  administrative record prepared by State and may suggest that State  make changes to the document. The interagency clearance process is  complete once Justice and Treasury provide State with signed letters  of concurrence indicating that the administrative record is legally  sufficient. CT is then to send the administrative record to other  bureaus in the State Department for final clearance.
Step 4: Secretary of State’s decision—Materials supporting the  proposed FTO designation are to be sent to the Secretary of State for  review and decision on whether or not to designate. The Secretary of  State is authorized, but not required, to designate an organization as  an FTO if he or she finds that the legal elements for designation are  met.
Step 5: Congressional notification—In accordance with the law, State  is required to notify Congress 7 days before an organization is  formally designated.
Step 6: Federal Register notice—State is required to publish the  designation announcement in the Federal Register and, upon  publication, the designation is effective for purposes of penalties that  would apply to persons who provide material support or resources to  designated FTOs.
subsections: section_title: Fifty-nine Organizations Are Currently Designated as FTOs
paragraphs: As of December 31, 2014, there were 59 organizations designated as  FTOs, including al Qaeda and its affiliates, Islamic State of Iraq and the  Levant (ISIL), and Boko Haram. See appendix III for the complete list of  FTOs designated, as of December 31, 2014. The number of FTO  designations has varied annually since the first FTOs were designated, in  1997. State designated 13 groups between 2012 and 2014. Figure 2  shows the number of organizations designated by year of designation, as  of December 31, 2014.
section_title: State Considered Input from Other Agencies in All FTO Designations between 2012 and 2014
paragraphs: According to State officials and our review of agency documents, State  considered information and input provided by other State bureaus and  federal agencies for all 13 designations made between 2012 and 2014.  State considered this input during the first three steps in its designation  process: conducting the equity check, compiling the administrative record,  and obtaining approval in the clearance process.
During our review of the 13 FTO designations between 2012 and 2014,  officials from the Departments of Defense, Homeland Security, Justice,  and the Treasury, and the Office of the Director of National Intelligence  (ODNI) reported that State considered their input when making  designations. Specifically, we found that State considered information  during the first three steps in the FTO designation process, including the  following:
Step 1: Equity check—According to State officials, regional bureaus at  State and other agencies provided input to CT during the equity check  step by identifying, when warranted, any law enforcement, diplomatic,  or intelligence equities that would be jeopardized by the designation of  the target organization. Officials from Defense, DHS, Justice,  Treasury, and the intelligence community also confirmed that they  provided input during the equity check. According to State officials,  other bureaus and agencies participating in the equity check included  the Central Intelligence Agency, the National Counterterrorism Center,  the National Security Agency, and the National Security Council  Counterterrorism staff.
Step 2: Administrative record—Agencies provided classified and  unclassified materials to State to support the draft administrative  record. For example, officials from ODNI told us they provide an  assessment and intelligence review, at the request of State, for any  terrorist organization that is nominated for FTO designation. U.S.  intelligence agencies may also provide information to State during the  equity check and during the compilation of the administrative record to  support the designation. Otherwise, State has direct access to the  disseminated intelligence of other agencies and does not need to  separately request such information, according to CT officials.
Step 3: Clearance—In accordance with the law, Justice and Treasury  review the draft administrative record for legal sufficiency and provide  their input to State before the administrative record is finalized.  Officials from Treasury and Justice told us that State considered their  input during the clearance process for the administrative record for the  13 FTO designations we examined. This consultation culminates in  and is documented through letters of concurrence in support of each  FTO designation signed by Treasury and Justice. In all 13 FTO  designations that we reviewed, Treasury and Justice issued signed  letters of concurrence.
section_title: U.S. Agencies Impose a Variety of Consequences on Designated FTOs and Associated Individuals
paragraphs: The U.S. government penalizes designated FTOs through three key  consequences. First, the designation of an FTO triggers a freeze on any  assets the organization holds in a financial institution within the United  States. Second, the U.S. government can criminally prosecute individuals  that provide material support to an FTO, as well as impose civil penalties.  Third, FTO designation imposes immigration restrictions upon members  of the organization and individuals that knowingly provide material  support or resources to the designated organization. Over the period of  our review, we found that U.S. agencies imposed all three consequences.
subsections: section_title: Blocking of FTO Funds Held in U.S. Financial Institutions
paragraphs: U.S. persons are prohibited from conducting unauthorized transactions or  having other dealings with or providing services to designated FTOs. U.S.  financial institutions that are aware that they are in possession of or  control funds in which an FTO or its agent has an interest must retain  possession of or maintain control over the funds and report the existence  of such funds to Treasury.
As of December 31, 2013, which is the date for the most recently  published Terrorist Assets Report, the U.S. government blocked funds  related to 7 of the 59 currently designated foreign terrorist organizations,  totaling more than $22 million (see table 1). As of December 2013, there  were no blocked funds reported to Treasury related to the remaining 52  designated FTOs. According to Treasury, the reported amounts blocked  by the U.S. government change over the years because of several  factors, including forfeiture actions, reallocation of assets to another  sanctions program, or the release of blocked funds consistent with  sanctions policy.
Funds shown in the table above are blocked by the U.S. government  pursuant to terrorism sanctions administered by Treasury, including FTO  sanctions regulations and global terrorism sanctions regulations. The  FTO-related funds blocked by the United States are only funds held within  the United States and do not include any assets and funds that terrorist  groups may hold outside U.S. financial institutions. However, according to  Treasury officials, while designation of FTOs exposes and isolates  individuals and organizations, and denies access to U.S. financial  institutions, in some cases, FTOs may also be sanctioned by the United  Nations or other international partners, an action that may block access to  the global financial system.
section_title: Prosecution of Individuals for Providing Support to FTOs
paragraphs: Designation as an FTO triggers criminal liability for persons within the  United States or subject to U.S. jurisdiction who knowingly provide, or  attempt or conspire to provide, “material support or resources” to a  designated FTO. Violations are punishable by a fine and up to 15 years  in prison, or life if the death of a person results. Furthermore, it is also a  crime to knowingly receive military-type training from or on behalf of an  organization designated as an FTO at the time of the training.
Between January 1, 2009, and December 31, 2013, which is the most  recent date for which data are available, over 80 individuals were  convicted of terrorism or terrorism-related crimes, that included providing  material support or resources to an FTO or receiving military-type training  from or on behalf of an FTO. The penalties for these convictions varied,  and included some combination of imprisonment, fines, and asset  forfeiture. For example, individuals convicted of terrorism or terrorism- related crimes, which included providing material support to an FTO,  received sentences that included imprisonment lengths that varied  between time served and life in prison, plus 95 years. In addition,  sentencing for convicted individuals included fines up to $125,000, asset  forfeiture up to $15 million, and supervised release for up to life.
In addition, Justice may also bring civil forfeiture actions against assets  connected to terrorism offenses, including the provision of material  support to FTOs. U.S. law authorizes, among other things, the forfeiture  of property involved in money laundering, property derived from or used  to commit certain foreign crimes, and the proceeds of certain unlawful  activities. Once the government establishes that an individual or entity is  engaged in terrorism, it may bring forfeiture actions by proceeding directly  against the assets (1) of an individual, entity, or organization engaged in  planning or perpetrating crimes of terrorism against the United States or  U.S. citizens; (2) acquired or maintained by any person intending to  support, plan, conduct, or conceal crimes of terrorism against the United  States or U.S. citizens; (3) derived from, involved in, or used or intended  to be used to commit terrorism against the United States or U.S. citizens  or their property; or (4) of any individual, entity, or organization engaged  in planning or perpetrating any act of international terrorism. According to  Justice officials, there have not been any civil forfeiture actions related to  FTOs. However, Justice officials said their department routinely  investigates and takes actions against financial institutions operating in  the United States that willfully violate the International Emergency  Economic Powers Act. They added that Justice has, for example,  imposed fines and forfeitures and installed compliance monitors in cases  where banks have violated terrorism-related sanctions programs.  Furthermore, according to Justice officials, there are numerous other  investigative and prosecutorial tools available to the United States to  confront terrorism and terrorism-related conduct, disrupt terrorist plots,  and dismantle foreign terrorist organizations.
section_title: Enforcement of Immigration Actions for FTO Support
paragraphs: FTO representatives and members, as well as individuals who knowingly  provide material support or resources to a designated organization who  are not U.S. citizens are inadmissible to, and in some cases removable  from, the United States under the Immigration and Nationality Act.  However, exemptions or waivers can be granted for certain  circumstances, according to State and DHS officials. For example, DHS  may grant eligible individuals exemptions in cases where material support  was provided under duress. Individuals found inadmissible or deportable  without an appropriate waiver or exemption under these provisions are  also barred from receiving most immigration benefits or relief from  removal. State and DHS are responsible for enforcing different aspects of  the immigration restrictions and ensuring that inadmissible individuals  without an appropriate waiver or exemption do not enter the United  States.
State consular officers at U.S. embassies and consulates are responsible  for determining whether an applicant is eligible for a visa to travel to the  United States. In instances where a consular officer determines that an  applicant has engaged or engages in terrorism-related activity, the visa  will be denied. According to State Bureau of Consular Affairs data,  between fiscal years 2009 and 2013, which was the most recent period  for which data are available, 1,069 individuals were denied nonimmigrant  visas and 187 individuals were denied immigrant visas on the basis of  involvement in terrorist activities and associations with terrorist  organizations.
DHS develops and deploys resources to detect; assess; and, if  necessary, mitigate the risk posed by travelers during the international air  travel process, including when an individual applies for U.S. travel  documents; reserves, books, or purchases an airline ticket; checks in at  an airport; travels en route on an airplane; and arrives at a U.S. port of  entry. For example, upon arrival in the United States, all travelers are  subjected to an inspection by U.S. Customs and Border Protection to  determine if the individual is eligible for admission under U.S. immigration  law. According to U.S. Customs and Border Protection data, between  fiscal years 2009 and 2014, which was the most recent period for which  data were available, more than 1,000 individuals were denied admission  to the United States for various reasons, and were identified for potential  connections to terrorism or terrorist groups, including being a member of  or supporting an FTO. In addition, U.S. Immigration and Customs  Enforcement is responsible for deporting individuals determined to be  engaged in terrorism or terrorism-related activities. Between fiscal years  2013 and 2104, which was the most recent period for which data are  available, Immigration and Customs Enforcement officials indicated that 3  individuals determined to be associated with or to have provided material  support to designated FTOs were removed from the United States.
Further, U.S. Citizenship and Immigration Services is responsible for the  adjudication of immigration benefits. An individual who is a member of a  terrorist organization or who has engaged or engages in terrorist-related  activity, as defined by the Immigration and Nationality Act, is deemed  inadmissible to the United States and is ineligible for most immigration  benefits. The law grants both the Secretary of State and the Secretary  of Homeland Security unreviewable discretion to waive the inadmissibility  of certain individuals who would be otherwise inadmissible under this  provision, after consulting with each other and the Attorney General.
Additionally, according to DHS officials, an exemption may be applied to  certain terrorist-related inadmissibility grounds if the activity was carried  out under duress, or under certain circumstances, such as the provision  of material support in the form of medical care. Such exemptions, if  applied favorably, may allow an immigration benefit to be granted. DHS  officials stated that these exemptions are extremely limited.
section_title: Concluding Observations
paragraphs: Terrorist groups, such as al Qaeda and its affiliates, Boko Haram, and  ISIL, continue to be a threat to the United States and its foreign partners.  The designation of FTOs, which can result in civil and criminal penalties,  is an integral component of the U.S. government’s counterterrorism  efforts. State’s process for designating FTOs considers input and  information from several key U.S. agency stakeholders, and allows U.S.  agencies to impose consequences on the organizations and individuals  that associate with or provide material support to FTOs. Such  consequences help U.S. counterterrorism efforts isolate terrorist  organizations internationally and limit support and contributions to those  organizations.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided draft copies of this report to the Departments of Defense,  Homeland Security, Justice, State, and the Treasury, as well as the Office  of the Director of National Intelligence, for review and comment. The  Department of Homeland Security provided technical comments, which  we incorporated as appropriate. The Departments of Defense, Justice,  State, and the Treasury, as well as the Office of the Director of National  Intelligence, had no comments.
If you or your staff have any questions about this report, please contact  me at (202) 512-7331 or johnsoncm@gao.gov. GAO staff who made key  contributions to this report are listed in appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines the Department of State’s (State) process for  designating foreign terrorist organizations (FTO) and the consequences  resulting from designation. We report on (1) the process for designating  FTOs, (2) the extent to which the State considers input from other  agencies during the FTO designation process, and (3) the consequences  that U.S. agencies impose as a result of an FTO designation.
To identify the steps in the FTO designation process, we reviewed the  legal requirements for designation and the legal authorities granted to  State and other U.S. agencies to designate FTOs. In addition, we  reviewed State documents that identified and outlined State’s process to  designate an FTO, from the equity check through publishing the  designation in the Federal Register. We interviewed State officials in the  Bureau of Counterterrorism to confirm and clarify the steps in the FTO  designation process and to identify which agencies are involved in the  process and at what steps they are involved. We also interviewed officials  from the Departments of Defense, Homeland Security, Justice (Justice),  and the Treasury (Treasury), as well as officials from the intelligence  community, to determine each agency’s level of participation in the  process.
To assess the extent to which State considered information from other  agencies in the designation process, we interviewed officials from the  Departments of Defense, Homeland Security, Justice, State, and the  Treasury, as well as officials from the intelligence community, to  determine when information is provided to State on organizations  considered for FTO designation, as well as the nature of that information.  We defined consideration as any action of State to request, obtain, and  use information from other agencies, as well as letters of concurrence  from those agencies. We reviewed both Justice’s and Treasury’s letters of  concurrence for all 13 designations made between 2012 and 2014. We  also interviewed State officials to determine how information provided by  other agencies is considered during the FTO designation process.
To identify the consequences U.S. agencies impose as a result of FTO  designation, we reviewed the legal consequences agencies can impose  under U.S. law, including the Immigration and Nationality Act, as  amended. Specifically, we reviewed the FTO funds and assets related to  FTOs that are blocked by U.S. financial institutions, as reported by the  Office of Foreign Assets Control (OFAC) of the Department of the  Treasury. We reviewed the publicly available Terrorist Assets Reports  published by Treasury for calendar years 2008 through 2013, which  identify the blocked assets identified and reported to Treasury related to  FTOs, as well as organizations designated under additional Treasury  authorities. U.S. persons are prohibited from conducting unauthorized  transactions or having other dealings with or providing services to the  designated individuals or entities. Any property or property interest of a  designated person that comes within the United States or into the  possession or control of a U.S. person is blocked and must be reported to  OFAC. The Terrorist Assets Reports identify these reported blocked  assets held within U.S. financial institutions that are targeted with  sanctions under any of the three OFAC-administered sanctions programs  related to terrorist organizations designated as FTOs, specially  designated global terrorists, and specially designated terrorists under  various U.S. authorities. We verified the totals reported in each of the  reports and identified the funds blocked for organizations designated as  FTOs. We also interviewed Treasury officials to discuss the reports of  blocked assets and the changes in the assets across years. We did not  analyze blocked funds for organizations that were designated under other  authorities or by the United Nations or international partners. To assess  the reliability of Treasury data on blocked funds, we performed checks of  the year-to-year data published in the Terrorist Assets Reports for  inconsistencies and errors. When we found minor inconsistencies, we  discussed them with relevant agency officials and clarified the reporting  data before finalizing our analysis. We determined that these data were  sufficiently reliable for the purposes of our report.
We also reviewed the Department of Justice National Security Division  Chart of Public/Unsealed Terrorism and Terrorism Related Convictions to  identify the individuals convicted of and sentenced for providing material  support or resources to an FTO or receiving military-type training from or  on behalf of an FTO between January 1, 2009, and December 31, 2013,  which was the period for which the most recent data were available.  Designation as an FTO introduces the possibility of a range of civil  penalties for the FTO or its members, as well as criminal liability for  individuals engaged in certain prohibited activities, such as individuals  who knowingly provide, or attempt or conspire to provide, “material  support or resources” to a designated FTO. We reviewed Justice data of  only public/unsealed convictions from January 1, 2009, to December 31,  2013. For the purposes of our report, we analyzed the Justice data on the  convictions and sentencing associated with individuals who were  convicted of knowingly providing, or attempting or conspiring to provide,  “material support or resources” to a designated FTO. We also reviewed  the data to identify the individuals who were convicted of knowingly  receiving military-type training from or on behalf of an organization  designated as an FTO at the time of the training. The data did not include  defendants who were charged with terrorism or terrorism-related offenses  but had not been convicted either at trial or by guilty plea, as of December  31, 2013. The data included defendants who were determined by  prosecutors in Justice’s National Security Division Counterterrorism  Section to have a connection to international terrorism, even if they were  not charged with a terrorism offense. To assess the reliability of the  convictions data, we performed basic reasonableness checks on the data  and interviewed relevant agency officials to discuss the convictions and  sentencing data. We determined that these data were sufficiently reliable  for the purposes of our report.
To identify the immigration restrictions and penalties imposed on  individuals associated with or who provided material support to a  designated foreign terrorist organization, we analyzed available data from  State Bureau of Consular Affairs reports on visa denials between fiscal  years 2009 and 2013, the U.S. Customs and Border Protection  enforcement system database on arrival inadmissibility determinations  between fiscal years 2009 and 2014, and information from the U.S.  Immigration and Customs Enforcement on deportations between fiscal  years 2013 and 2014. The Immigration and Nationality Act, as amended,  establishes the types of visas available for travel to the United States and  what conditions must be met before an applicant can be issued a  particular type of visa and granted admission to the United States. For the  purposes of this report, we primarily included the applicants deemed  inadmissible under section 212(a)(3) of the Immigration and Nationality  Act, which includes ineligibility based on terrorism grounds. We did not  include the national security inadmissibility codes that were not relevant  to terrorism. In each instance, we analyzed the data provided by the  agencies and performed basic checks to determine the reasonableness  of the data. We also spoke with relevant agency officials to discuss the  data to confirm the reasonableness of the totals presented for individuals  denied visas, denied entry into the United States, or deported from the  United States for association with a designated foreign terrorist  organization. We determined that these data were sufficiently reliable for  the purposes of our report.
We conducted this performance audit from April 2015 to June 2015 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Agencies and Their Roles in the Foreign Terrorist Organization (FTO) Designation Process
section_title: Appendix III: Designated Foreign Terrorist Organizations, as of December 31, 2014
paragraphs: Appendix III: Designated Foreign Terrorist  Organizations, as of December 31, 2014 1.
Organization  Abu Nidal Organization (ANO)
2.
Abu Sayyaf Group (ASG)
3.
Aum Shinrikyo (AUM)
4.
Basque Fatherland and Liberty (ETA)  5.  Gama’a al-Islamiyya (Islamic Group) (IG)  6.  7.
Harakat ul-Mujahidin (HUM)
8.  9.
Kahane Chai (Kach)  10.  Kurdistan Workers Party (PKK) (Kongra-Gel)  11.  Liberation Tigers of Tamil Eelam (LTTE)  12.  National Liberation Army (ELN)  13.  Palestine Liberation Front (PLF)  14.  Palestinian Islamic Jihad (PIJ)  15.  PFLP-General Command (PFLP-GC)  16.  Popular Front for the Liberation of Palestine (PFLF)  17.  Revolutionary Armed Forces of Colombia (FARC)  18.  Revolutionary Organization 17 November (17N)  19.  Revolutionary People’s Liberation Party/Front (DHKP/C)  20.  Shining Path (SL)  21.  al Qaeda (AQ)  22.
Islamic Movement of Uzbekistan (IMU)  23.  Real Irish Republican Army (RIRA)  24.  Jaish-e-Mohammed (JEM)  25.  Lashkar-e Tayyiba (LeT)  26.  Al-Aqsa Martyrs Brigade (AAMB)  27.  al Qaeda in the Islamic Maghreb (AQIM)  28.  Asbat al-Ansar (AAA)  29.  Communist Party of the Philippines/New People’s Army  (CPP/NPA)  30.  Jemaah Islamiya (JI)  31.  Lashkar i Jhangvi (LJ)  32.  Ansar al-Islam (AAI)  33.  Continuity Irish Republican Army (CIRA)  34.
Islamic State of Iraq and the Levant (formerly al Qaeda in Iraq)  12/17/2004  35.  Libyan Islamic Fighting Group (LIFG)
12/17/2004  36.
Organization  Islamic Jihad Union (IJU)  37.  Harakat ul-Jihad-i-Islami/Bangladesh (HUJI-B)  39.  Revolutionary Struggle (RS)  40.  Kata’ib Hizballah (KH)  41.  al Qaeda in the Arabian Peninsula (AQAP)  42.  Harakat ul-Jihad-i-Islami (HUJI)  43.  Tehrik-e Taliban Pakistan (TTP)  45.  Army of Islam (AOI)  46.
Indian Mujahedeen (IM)  47.  Jemaah Anshorut Tauhid (JAT)  48.  Abdallah Azzam Brigades (AAB)  49.  Haqqani Network (HQN)  50.  Ansar al-Dine (AAD)  54.  Ansar al-Shari’a in Benghazi  55.  Ansar al-Shari’a in Darnah  56.   Ansar al-Shari’a in Tunisia  57.  Ansar Bayt al-Maqdis  59.  Mujahidin Shura Council in the Environs of Jerusalem (MSC)
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact listed above, Elizabeth Repko (Assistant  Director), Claude Adrien, John F. Miller, and Laurani Singh made key  contributions to this report. Ashley Alley, Martin de Alteriis, Tina Cheng,  and Lynn Cothern provided technical assistance.