Army of Islam Designated on the OFAC SDN List

The Secretary of State has designated the Army of Islam (AOI) as a Foreign Terrorist Organization (FTO) under Section 219 of the Immigration and Nationality Act, as well as, designated that organization pursuant to Executive Order 13224. The designation under Executive Order 13224, places the name of Army of Islam on the list of Specially Designated Nationals (SDNs) administered by the United States Department of the Treasury Office of Foreign Assets Control (OFAC).

According to the press release from the Department of State, Army of Islam is a Gaza Strip-based terrorist organization responsible for numerous terrorist acts against the Governments of Israel and Egypt and citizens of the U.S., the U.K., and New Zealand. Amongst, these acts were numerous rocket attacks on Israel, the 2006 kidnapping of two Fox News journalists in Gaza and the 2007 kidnapping of a British journalist in Gaza. The Department of State also states that the group was responsible for the 2009 attacks on Egyptian civilians in Cairo and Heliopolis.

The Army of Islam is thought to be led by Mumtaz Dughmush and operates primarily in the Gaza Strip and Palestinian territories. The organization adheres to a Salafist ideology of global jihad together and has previously worked with Hamas. Currently, Army of Islam and is thought to be developing closer al-Qa’ida contacts by amongst, other things releasing a eulogy for Osama bin Laden via its Al Nur Media Foundation.

The placing of Army of Islam on the OFAC SDN List effectively prohibits U.S. persons from engaging in transactions with the organization, and also freezes the property and interests in property of the organization that are under or come under U.S. jurisdiction.

When persons have been placed on the SDN list, they are often confused as how to challenge the designation. This is because there is much confusion about what sanctions are, who issues them, and who enforces them. For this reason, designated persons spend many years trying to challenge a designation by going through the wrong channels. For example, when challenging an OFAC designation we have seen individuals try to challenge it through the State Department, through the Department of Justice, through the United Nations, and through the European Commission. Many times designated persons try to challenge their designation everywhere except the most logical choice: OFAC. OFAC is responsible for administering the SDN List, and OFAC is where one needs to challenge their designation.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or

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