OFAC Says Union of Good - Not So Good

OFAC updated its website today to add Union of Good to the list of Specially Designated Global Terrorists (SDGT). Union of Good was originally established to collect charitable contributions for only a hundred and one days, but had its activities extended following the initial impressive collection of receipts. Along with Union of Good, OFAC designated several entity aliases as follows:

• 101 Days Campaign
• Charity Coalition
• Coalition of Good
• Etelaf Al-Khair
• Etilafu El-Khair
• I'tilaf Al-Khair
• I'tilaf Al-Khayr

Executive Order 13224 lays out OFAC's authority to make such designations, and the effect of the OFAC designation prohibits any and all transactions with SDGTs, and blocks SDGT property. OFAC's November 12, 2008 designation follows on the heels of a similar designation made by Israel's Defense Minister in 2002, outlawing Union of Good for "its massive support of Hamas." This February, 2005 study posted by the Intelligence and Terrorism Information Center at the Center for Special Studies linked Union of Good to the dispersement of payments associated with three suicide bombers, including a suicide bombing in Netanya and a suicide bombing in Ariel.

Some might wonder why there is a six year lag between Israel's recognition of a terror supporter and the US's official recognition of the same. I do not have an answer. All I've found is that the lag appears to be a two-way street.

On July 7, 2008, Israel's Defense Minister was reported to have signed an order declaring thirty-six (36) entities to be banned associations in Israel. The entities were found to be part of Hamas's worldwide fundraising network, and connected to Union of Good. Among the entities was the Holy Land Foundation. OFAC designated the Holy Land Foundation an SDGT in December, 2001. Additionally, the US Government has brought the Holy Land Foundation and its key personnel to trial for charges related to the financing of terrorism - twice. The first trial ended in jury deadlock on most counts and a mistrial on those deadlocked counts in October, 2007. Today, the jury began deliberation in the retrial of the Holy Land Foundation.

Perhaps this lag is representative of a government's slow expansion of the effects of its regulations to entities further and further from home. Union of Good operates from the doorstep of Israel. Holy Land Foundation operates from within the US. Each are half a world away from the other. The problem is that SDGTs half a world apart can quickly coordinate cooperative activities. If it always takes six years or more for the likes of Israel and the US to get on the same page, the goal of the Global War on Terror had better be a tortoise and hare race.