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Militant Islam Monitor > Articles > FROM TEHERAN TO TAMPA: Iranian Proxy Networks Operating Through Florida's 501(c) (3) Sector FROM TEHERAN TO TAMPA: Iranian Proxy Networks Operating Through Florida's 501(c) (3) SectorThe Network Contagion Research Institute's 2026 Report On The Decades Long Islamization Of Tampa FL - From Al- Arian's PIJ To CAIR PDF: 'NETWORK CONTAGION' 'From Tehran To Tampa -Iranian Proxies in FL as 501c3 About The Network Contagion Research Institute (NCRI) https://networkcontagion.us/about/ Designated Terror Organization U.S-Based Advocacy Hub Terror Financier 0 4 - 1 4 - 2 6 From Tehran to Tampa: Iranian Proxy Networks Operating Through Florida's 501(c)(3) Sector C o n ta g i o n a n d I d e o lo g y R e p o r t C o n ta g i o n a n d I d e o lo g y R e p o r t tFrom Tehran to Tampa: Iranian Proxy Networks Operating Through Florida's 501(c)(3) Sector Executive Summary As the United States confronts Iran's expanding proxy architecture across the Middle East, this report documents a dimension of that challenge that has received insufficient regulatory attention: the degree to which U.S. -based civil-society infrastructure has been used to platform, sustain, and confer legitimacy upon individuals tied to Iranian-backed proxy organizations operating domestically. This report examines a network of nonprofit, religious, and advocacy organizations operating in and connected to Florida that show repeated documented overlap with individuals convicted of terrorism-related offenses, designated under U.S. sanctions authorities, or publicly associated with Hamas, Palestinian Islamic Jihad, and broader Iran-aligned influence ecosystems. The available record does not establish that the organizations themselves engage in terrorism or terrorist financing. It does, however, document recurring patterns in which convicted or sanctioned individuals receive public platforms, institutional association, financial support, or reputational amplification through U.S.-based nonprofit and allied institutions. Collectively, these patterns raise material compliance and oversight questions under federal sanctions law, IRS nonprofit regulations, and Florida charitable-solicitation statutes. Hamas and Palestinian Islamic Jihad are not peripheral actors. Both organizations are core components of Iran's regional proxy system and have received substantial material and financial support from Tehran, including through the Islamic Revolutionary Guard Corps (IRGC). The Iran connection in this report is therefore not incidental – it is structurally central. Florida-based institutions have not merely interacted with PIJ- or Hamas-linked individuals; the record indicates overlapping engagement with figures operating across the full breadth of Iran's "Axis of Resistance" ecosystem, including Iranian state media figures and advisors to the Iranian government. That breadth is analytically significant and distinguishes this network from one organized solely around the Palestinian cause. Florida is significant within this ecosystem for several reasons. Multiple relevant entities are incorporated, registered, or operationally active in Florida; fundraising events, donor solicitations, and public programming have occurred in the state; and Florida-based institutions have repeatedly served as venues, sponsors, or support structures for individuals tied to PIJ, Hamas, and adjacent Iran-aligned messaging networks. The evidence supports viewing Florida as a permissive domestic jurisdiction in which overlapping organizations have provided 1continuity, legitimacy, fundraising access, and audience reach to actors linked to the broader "resistance" milieu. The report also indicates that public transparency and institutional separation are often limited at the points where oversight matters most. In some instances, recipient identities are not fully disclosed; in others, religious-institution exemptions reduce financial visibility; and in still others, overlapping leadership roles or repeated co-sponsorships blur the distinction between formally separate organizations. These features do not by themselves establish unlawful conduct. They do, however, make independent verification of sanctions compliance, governance safeguards, and state registration requirements more difficult. Taken together, the evidence supports coordinated regulatory review by relevant state and federal authorities. Potential areas for review include nonprofit governance and conflicts controls, sanctions-screening practices, charitable-solicitation compliance, and campaign-intervention restrictions applicable to 501(c)(3) entities. The broader policy question is no longer limited to whether Florida nonprofits have interacted with Hamas- or PIJ-linked individuals; the more significant concern is whether U.S. -based civil-society infrastructure is being used to platform, normalize, or sustain actors operating within, or adjacent to, Iran's proxy and influence architecture – and whether that infrastructure poses a domestic risk vector at a moment of heightened U.S.-Iran tension. BLUF • Florida courts removed a state restriction as Iran-linked influence risks persist. Recent rulings struck down Florida laws that had been used against CAIR-related organizations, removing one state-level enforcement tool even as the record reflects continued overlap among Florida nonprofits, convicted terror offenders, Hamas officials, and Iranian regime-linked figures. • A convicted PIJ facilitator built a Florida network that overlaps with Iran's proxy ecosystem. Sami Al-Arian, a former University of South Florida professor convicted for providing material support to PIJ, founded multiple organizations in Florida and remains connected to several through partnerships, shared personnel, fundraising relationships, and repeated public programming. That network extends beyond PIJ alone and repeatedly intersects with Hamas figures and Iranian regime-linked actors. Al-Arian has participated in pro-Iran webinars hosted at U.S. universities and through CIGA, and has co-appeared on state-linked Iranian media platforms alongside Iranian government advisors. • A sanctioned PIJ leader held a leadership role in a Tampa mosque. Ramadan Abdullah Shallah, who became Secretary General of Palestinian Islamic Jihad,2continued to appear as a director and imam of a Tampa mosque founded byAl-Arian during the same period in which he was sanctioned by OFAC. • Network actors platform Hamas officials and Iranian regime-linked figures. Individuals tied to this network have hosted events featuring Hamas officials, sanctioned operatives, and Iranian regime-linked figures such as Mohammad Marandi – a University of Tehran professor, Iranian nuclear committee advisor, and prolific Press TV commentator – indicating that the relevant Florida-based ecosystem overlaps with the broader Iran-aligned "resistance" sphere rather than stopping at Palestinian militancy alone. • A nonprofit board overlap connects the Al-Arian and Iranian state media ecosystems. Sara Flounders, a member of the Coalition for Civil Freedom (CCF) Board of Directors, has extensive documented contact with Iranian state media outlet Press TV, appeared alongside Al-Arian at public events dating to 2002, and was a prominent campaigner for Al-Arian's release from federal custody. Al-Arian has publicly praised her published work in highly favorable terms. Her presence on CCF's board places an individual with sustained Iranian state media ties at the governance level of a registered 501(c)(3). • Florida nonprofits provide support, legitimacy, and continuity across the network. Florida nonprofits with foundational ties to Sami Al-Arian – including the CCF, CAIR-FL, and the Islamic Community of Tampa (ICT) – each appear in documented relationships involving fundraising, sponsorship, public collaboration, platforming, or shared leadership overlap. The nature and degree of those relationships differ across the organizations, but together they create a domestic support environment in which actors tied to PIJ, Hamas, and adjacent Iran-aligned networks can gain visibility and institutional association. • Assessment: Florida's nonprofit sector presents a permissive environment for Iran-aligned proxy influence. Tax-exempt and allied institutions have provided platforms, sponsorship relationships, financial support, or reputational cover to actors tied to PIJ, Hamas, and overlapping Iranian regime-linked influence ecosystems, creating a domestic risk environment for the amplification of extremist narratives and for downstream compliance exposure. Overview and Key Figures A network of nonprofit organizations operating in Florida's charitable, religious, and advocacy sectors shows repeated overlap with individuals convicted of terrorism-related offenses or designated under U.S. sanctions authorities. The most 3useful analytical frame is not to treat these connections1 as confined to Palestinian Islamic Jihad (PIJ) or Hamas in isolation. PIJ and Hamas are not independent actors; both have received sustained material, financial, and strategic support from the Islamic Republic of Iran, principally through the IRGC's Quds Force, and are considered proxy nodes within the larger terror network facilitated by the Islamic Regime. 2 The schematic and event record indicate that the same domestic ecosystem also overlaps with Iranian regime-linked actors, advisors, and state-run media – which is consistent with, rather than separate from, the PIJ and Hamas connections. Central figures include Sami Al-Arian and Hatem Naji Fariz, both of whom were convicted in PIJ-related cases and both of whom appear across multiple Florida-linked entities. Around them are four principal institutional nodes with links to the Tampa Bay Muslim community: 1) Sami Al-Arian and the Center for Islam and Global Affairs (CIGA), 2) the Coalition for Civil Freedoms (CCF), 3) the Islamic Community of Tampa (ICT), and 4) CAIR-Florida. These nodes are not identical in conduct, risk, or evidentiary weight; however, they show repeated relationships through leadership overlap, sponsorship, event collaboration, donor activity, and shared public narratives. The significance of this structure is that it documents a domestic ecosystem in which actors tied to PIJ, Hamas, and Iranian regime-linked influence networks can access institutional platforms, donor audiences, and reputational reinforcement through Florida-based organizations. That combination of overlap, continuity, and legitimacy is what makes the Iran angle analytically central rather than incidental. This report does not assert that any of the four nodes operates under Iranian direction or control. It does assert that the documented pattern of co-platforming, co-funding, and shared personnel creates a domestic risk environment that warrants coordinated regulatory attention – particularly in a period of escalating U.S.-Iran tensions. 1 For purposes of this report, the term 'terror-linked' refers to documented organizational relationships with individuals convicted of terrorism-related offenses or designated under U.S. sanctions authorities. This report does not provide dispositive evidence that the organizations themselves engage in terrorism or terrorist financing. 2 Maddocks, J. (2025). Iran and its proxies: Attribution and state responsibility. International Law Studies, 104. https://digital-commons.usnwc.edu/cgi/viewcontent.cgi?article=3124&context=ils 4Schematic of a simplified network of Florida-based nonprofits and the Iranian regime-linked actors affiliated with them. At the center of this network is Sami Al-Arian, who was convicted of providing material support for PIJ, then deported from the U.S. in 2015 as a condition of his sentencing. 5Node One: Sami Al-Arian and Center for Islam and Global Affairs (CIGA) Sami Al-Arian is best understood as the principal connective node in this network. A former University of South Florida professor convicted of providing material support to Palestinian Islamic Jihad3 and subsequently deported from the United States, 4 Al-Arian remains active as a convener, moderator, and featured speaker across nonprofit, academic, and transnational media settings. He currently serves as the Director of the Center for Islam and Global Affairs (CIGA) at Istanbul Zaim University in Türkiye. 5 His documented activity since deportation spans three overlapping domains: sustained engagement with PIJ- and Hamas-linked figures, including individuals sanctioned by OFAC; repeated participation in forums oriented toward Iranian regime interests; and continued affiliation with and amplification by U.S. -based501(c)(3) organizations. It is the intersection of all three – not any one domain in isolation – that makes Al-Arian analytically central to this report. Iran-Facing Activity: Webinars and State Media Al-Arian's connections to the Iranian influence ecosystem extend beyond his documented engagement with PIJ and Hamas-linked figures. Al-Arian participated as a featured speaker in at least one webinar organized around pro-Iran themes and hosted with the involvement of a U.S. university, 6 and in a separateCIGA-hosted webinar with similar focus. 7 The significance of these appearances is amplified by an October 2024 CIGA conference, where Al-Arian shared a program not only with sanctioned Hamas official Osama Hamdan, but simultaneously with a senior Iranian government-affiliated academic. This event reflects anorganizational architecture that brought PIJ, Hamas, and Iranian regime-adjacent figures onto the same institutional platform at once. This activity does not assert that Al-Arian acts under Iranian direction, though it does establish that Al-Arian occupies a consistent position within a media and advocacy ecosystem that intersects with Iranian influence interests – and that this positioning is directly connected to his contemporaneous amplification by U.S.-based 501(c)(3) organizations. CIGA Events Featuring Hamas Officials (2021–2025) 3 https://www.justice.gov/archive/opa/pr/2006/April/06_crm_221.html 4 https://www.politico.com/blogs/under-the-radar/2015/02/al-arian-saga-ends-with-deportation-202233 5 https://www.izu.edu.tr/en/ciga/about-us/director's-message 6 https://jewishonliner.org/p/san-francisco-state-university-hosts-convicted-terror-financier-at-pro-iran-webinar 7 https://www.youtube.com/watch?v=nIUTNPiC5qs 6 In 2025, Al-Arian, in his capacity as the Director of CIGA, organized and hosted multiple public events featuring Majed Al-Zeer, who had been designated by OFAC in 2024. 8 These events occurred months after designation, defeating any "isolated lapse" explanation. February 7, 2025 Event On February 7, 2025, CIGA hosted Al-Zeer for a seminar presenting his book Palestinian Popular Action in Europe: Achievements, Challenges, and Prospects. According to the event moderator, Fadi Al-Zaatari, Al-Arian initiated the presentation and discussion of the book and invited the authors to speak at the university. Approximately 70 minutes into the discussion, Al-Zaatari invited Al-Arian on stage to share remarks. Al-Arian thanked the authors for writing the book and discussed its content. At the conclusion of the event, Al-Zaatari again invited Al-Arian on stage, where Al-Arian presented Al-Zeer with an award from CIGA, publicly embraced him, and kissed him on the cheeks. During the closing remarks, the moderator announced that there would be a book signing, with signed copies provided to audience members.9 The event was promoted on CIGA's social media channels,10,11 including posts tagging Al-Zeer's personal account. 12 Al-Zeer also advertised the event on his own social media13 and later posted video footage from the seminar on his personal Instagram page. 14 8 https://sanctionssearch.ofac.treas.gov/Details.aspx?id=48631 9 https://www.youtube.com/watch?v=b9VhaA2vfI0 10 https://www.facebook.com/share/p/17wv8qZvLr/ 11 https://x.com/cigaistanbul/status/1886770915884593556 12 https://x.com/cigaistanbul/status/1884510461749604643 13 https://x.com/mzeer2/status/1887540714956845322 14 https://www.instagram.com/reel/DF0W7pHitHW/ 7Sami Al-Arian presenting Majed Al-Zeer with an award from CIGA at the February 2025 book event. 8May 13, 2025 Event On May 13, 2025, Al-Arian moderated a second CIGA-hosted book discussion featuring Al-Zeer, promoting his book Al-Daymuma (The Permanence of the Struggle): Factors Keeping the Palestinian Cause Alive. 15 During closing remarks, Al-Arian again embraced Al-Zeer and kissed him on the cheeks, and informed the audience that there would be a book signing with copies available for those who wished to obtain one. 16 While physical gestures such as public embraces or the conferral of awards may appear symbolic, in the sanctions context they are relevant insofar as they signal endorsement, confer legitimacy, and reinforce reputational standing. OFAC guidance and enforcement history make clear that reputational and promotional support can constitute prohibited services when knowingly provided to designated individuals. Facilitating book signings and the distribution of copies (including free copies) arguably constitutes commercial facilitation and provision of things of value to a designated individual under Executive Order 13224, regardless of whether revenue amounts can be independently verified. Sami Al-Arian embracing Majed Al-Zeer at the May 2025 book event. 15 https://www.facebook.com/cigaistanbul/posts/join-us-for-a-powerful-conversation-on-al-daymuma-the-permanence-of- the-struggle/1242329581236105/ 16 https://www.youtube.com/watch?v=2ztcHIwyQEA 9Both CIGA17 and Al-Zeer18 promoted this event on their respective social media platforms. Videos posted on CIGA's social media also show Al-Arian and Al-Zeer together at CIGA's Nakba exhibit, following the onstage discussion. 19,20,21,22 Facilitating book signings and the distribution of copies (including free copies) potentially constitutes commercial facilitation and provision of things of value to a designated individual under Executive Order 13224, regardless of whether revenue amounts can be independently verified. From a sanctions-compliance perspective, these activities go beyond passive association or incidental contact. The repeated organization of events, moderation of discussions, facilitation of book promotion, and provision of signed materials constitute affirmative services and things of value provided to a designated individual. Under Executive Order 13224, such conduct may implicate prohibitions regardless of whether direct monetary transfers can be independently quantified. October 6-7, 2024 Event Al-Arian and CIGA also hosted the Fourth International Conference on Palestine from October 6–7, 2024, which featured opening remarks by U.S. -sanctioned senior Hamas official Osama Hamdan,23,24,25 who was billed as the "Representative of the Palestinian Resistance."26 At the conference, Al-Arian and Hamdan were both seated in the front row, with only one individual seated between them. 27The inclusion of a U.S.-sanctioned senior Hamas official in a featured speaking role, rather than incidental attendance, further reinforces the pattern of affirmative platforming and legitimization of designated individuals through institutional forums. 17 https://www.instagram.com/p/DJYiQGeCBrL/ 18 https://x.com/mzeer2/status/1922314128263131206 19 https://www.facebook.com/reel/1912403122894203 20 https://www.facebook.com/reel/1667089927260916 21 https://www.instagram.com/reel/DJwjazFi 2k_ 22 https://www.instagram.com/reel/DJrYtgfiLe8/ 23 https://sanctionssearch.ofac.treas.gov/Details.aspx?id=7913 24 https://www.youtube.com/live/l1nHOUBhJ7Y?t=5931s 25 https://www.instagram.com/p/DBBw2i5i90X/ 26 https://www.izu.edu.tr/docs/default-source/ciga-documents/conf-booklet/program-2-1.pdf 27 https://www.izu.edu.tr/en/ciga/home/2024/10/09/gathered-for-palestine-on-the-anniversary-of-the-gaza- occupation 10 Osama Hamdan giving opening remarks at CIGA's Fourth International Conference on Palestine. Cropped photograph of Osama Hamdan (left) and Sami Al-Arian (right) at the conference, seated in close proximity in the front row. The conference also featured U.S. academics – including Joseph Massad (Columbia University) and John Quigley (Ohio State University) – and media personnel, such as Max Blumenthal of Grayzone News. Actors linked to the Iranian regime were also invited guests: Mohammad Marandi – a professor at the University of Tehran, an advisor to the Iranian nuclear negotiating committee,28 and a prolific guest on Press 28 https://www.cnn.com/2022/08/10/middleeast/iran-talks-trump-shadow-mime-intl/index.html11TV29,30,31,32,33,34,35,36,37,38,39,40,41,42,43,44,45,46,47,48,49,50,51 – was featured as a panelist alongside Sami Al-Arian and Max Blumenthal in a session titled "A Conversation with Experts on Toufan Al-Aqsa and its Consequences" . This was not the only political panel in which Mohammad Marandi and Sami Al-Arian both participated in 2024; Marandi and Al-Arian also both contributed to panels on the state-controlled media outlets RT52 and Al Jazeera53 . Notably, these panels all occurred during the same year Al-Arian hosted a "teach-in" via video call at the University of Chicago encampment (May 1, 2024), further extending his reach into U.S. campus-based activist networks. 54,55 29 https://www.presstv.ir/Detail/2024/09/26/734030/-There-is-no-chance-for-the-Israeli-regime-to-win-in-Lebanon- 30 https://www.presstv.ir/Detail/2024/09/28/734103/Collective-West-supporting-Israel-%E2%80%98to-wipe-out-the-Pale stinian-population%E2%80%99--Academic 31 https://www.presstv.ir/Detail/2025/05/20/748290/Trump's-Negotiations-Fail 32 https://www.presstv.ir/Detail/2025/07/03/750529/Israel-is-done-(part-1) 33 https://www.presstv.ir/Detail/2025/07/03/750525/Israel-is-done-(part-2) 34 https://www.presstv.ir/Detail/2023/11/27/715346/ISRAELI-ATROCITIES 35 https://www.presstv.ir/Detail/2022/11/09/692410/Terror-groups-admitted-leading-riots-Iran 36 https://www.presstv.ir/Detail/2018/03/03/554269/iran-us-lebanon-marandi 37 https://www.presstv.ir/Detail/2023/05/04/702783/Academic--Time-is-not-on-the-side-of-American-tormentors-of-Syrian s 38 https://www.presstv.ir/Detail/2023/07/04/706469/Shanghai-Cooperation-Organization-Mohammad-Marandi-security-pr osperity- 39 https://www.presstv.ir/Detail/2022/11/15/692793/Iran-rioters-Western-media 40 https://www.presstv.ir/Detail/2020/04/23/623692/US-Islamic-Republic-Iran-war 41 https://www.presstv.ir/Detail/2021/06/19/660423/Ebrahim-Raeisi-president-elect-Iran-economic-policy-JCPOA- 42 https://www.presstv.ir/Detail/2021/07/10/661946/Israel-uses-MKO-impair-Iran-security 43 https://www.presstv.ir/Detail/2015/08/22/425896/US-Iran-Israel-Obama-war-rhetoric-Mohammad-Marandi 44 https://www.presstv.ir/Detail/2022/03/02/677820/Ukraine-Russia-conflict-nothing-with-Iran-deal-advisor 45 https://www.presstv.ir/Detail/2022/09/21/689590/West-should-keep-silent-on-human-rights-as-they-encourage-anti-Ira n-violence,-impose-sanctions--Analyst 46 https://www.presstv.ir/Detail/2021/11/30/671722/Iran-sanctions-Vienna-talks-Marandi?ht-comment-id=3367695 47 https://www.presstv.ir/Detail/2021/11/10/670319/US-conspiracy-against-Iran- 48 https://www.presstv.ir/Detail/2021/09/17/666728/Iran-SCO-membership-US-sanctions-hegemony-Asia 49 https://www.presstv.ir/Detail/2021/06/18/660336/Iran-Elections-Democracy- 50 https://www.presstv.ir/Detail/2022/02/20/677224/Iran-Vienna-negotiations-sanctions-Press-TV-exclusive 51 https://www.presstv.ir/Detail/2015/03/16/402145/Confab-on-Leader-letter-starts-in-Tehran 52 https://www.rt.com/shows/crosstalk/606661-israel-winning-middle-east/ 53 https://www.aljazeera.com/video/inside-story/2024/1/3/how-will-hamas-react-to-the-killing-of-one-of-its-top-leaders 54 https://chicagomaroon.com/42443/news/live-updates-pro-palestine-encampment-enters-third-day-on-quad/ 55 https://www.youtube.com/watch?v=Z5YCcvdCBas 12Left: Sami Al-Arian, Mohammad Marandi, and Max Blumenthal, among other invited speakers, for an "expert" panel on the "Toufan Al-Aqsa and its consequences" . Right: Senior Hamas official Osama Hamdan at the conference being interviewed by U.S. journalist Max Blumenthal. This image is featured on CIGA's Instagram page. June 14, 2021 Event On June 14, 2021, CIGA hosted a webinar containing a panel discussion titled "Development of Palestinian Narrative in 2021 Israeli Aggression on Palestine" 56.Two of the panelists were Sami Al-Arian and senior Hamas official Basem Naim; though Naim was sanctioned for his leadership role in Hamas in 2024, 57,58 he was not, at the time of the panel discussion, formally sanctioned by the U.S. government. 56 https://www.instagram.com/p/CQGJOsQg2S5/ 57 https://home.treasury.gov/news/press-releases/jy2720 58 https://sanctionssearch.ofac.treas.gov/Details.aspx?id=49604 132021 CIGA webinar featuring Sami Al-Arian and senior Hamas official Basem Naim as co-panelists. Pattern and Network Relevance Taken together, these activities indicate that Al-Arian functions as a repeat convening and amplification node for sanctioned individuals, Hamas-linked officials, and Iranian regime-adjacent figures across multiple platforms and jurisdictions. The relevance of these activities is heightened by Al-Arian's contemporaneous affiliation with, promotion by, and collaboration with U.S.-based 501(c)(3) organizations, including the Coalition for Civil Freedoms59 and Council on American-Islamic Relations (particularly its Florida chapter, CAIR-FL). 60 Al-Arian's affiliations with U.S. university personnel add a further legitimizing element: In addition to featuring Professors Massad and Quigley at the Fourth International Conference on Palestine, Al-Arian and CIGA have repeatedly hosted discussions with faculty from major U.S. universities,61,62,63 further extending the reach and legitimacy of these platforms. Al-Arian has appeared via video at U.S. university events, including a teach-in at the University of Chicago encampment in May 2024,64 extending his reach into campus activist networks while remaining outside U.S. jurisdiction. Separately, one of CCF's member organizations is the 59 https://www.civilfreedoms.org/sites/default/files/2024-09/terror-trap.pdf 60 https://www.youtube.com/watch?v=4EEOt8Z4_GI 61 https://www.instagram.com/p/CUw49dIg7yy/ 62 https://www.youtube.com/watch?v=ZIQ-JZpp4eY 63 https://www.youtube.com/watch?v=LZx7n6pWuyQ 64 https://www.youtube.com/watch?v=b_xDydp3b4I 14Creating Law Enforcement Accountability and Responsibility project at the City University of New York School of Law (CUNY-CLEAR), underscoring the integration of this network with U.S. academic institutions. 65 The record demonstrates a sustained pattern in which Sami Al-Arian has repeatedly organized, moderated, and promoted public engagements with individuals designated under U.S. sanctions authorities, often after designation and through nonprofit platforms. The frequency, visibility, and escalation of these activities are inconsistent with incidental or inadvertent contact. When viewed in conjunction with his amplification by U.S. -based 501(c)(3) organizations, and his parallel participation in Iran-focused media and academic forums, this conduct raises material questions regarding sanctions compliance, nonprofit governance, and the effectiveness of existing oversight mechanisms. Al-Arian's role is best understood not as that of a passive academic or former defendant, but as an active intermediary who connects designated individuals to institutional platforms, audiences, and affiliated U.S. -based nonprofits. This intermediary function materially increases the reach, normalization, and perceived legitimacy of sanctioned actors within civil-society and advocacy ecosystems. It lowers the practical barriers for designated individuals to access U.S. audiences, donors, and institutional credibility, increasing downstream compliance exposure for affiliated nonprofits. Node Two: Coalition for Civil Freedoms (CCF) – Sponsoring "Political Prisoners" The Coalition for Civil Freedoms (CCF) is a 501(c)(3) deeply embedded in the Al-Arian network. Founded in 2010 (originally as the National Coalition to Protect Civil Freedoms) by Sami Al-Arian while he was under house arrest, CCF portrays itself as a civil-liberties organization advocating for Muslims accused or convicted of terrorism, whom it routinely describes as "political prisoners. "66 Based on observed activities, CCF's structure and operations position it functionally as a direct financial support mechanism for individuals convicted of terrorism-related offenses – a characterization grounded in its own publicly documented programmatic activity, not in any criminal charge or finding. 67While publicly framed as a civil-liberties organization, CCF's core activities – particularly its sponsorship of incarcerated terrorism defendants and convicts – 65 https://www.civilfreedoms.org/sites/default/files/2025-07/Annual%20Report%20-%202024%20%20.pdf 66 https://www.civilfreedoms.org/page/faq 67 References in this report to CCF's functional role describe organizational conduct based on publicly available records. They do not assert criminal "material support" liability or any other unlawful conduct by CCF as an organization. 15raise material compliance risks under U.S. sanctions law, nonprofit governance standards, and Florida charitable solicitation statutes. Leadership Structure and Iranian Ecosystem Overlap CCF functions as a central support node within the Al-Arian network, providing direct financial assistance, advocacy infrastructure, and reputational reinforcement for individuals convicted in terrorism-related cases, while also overlapping with a broader media and activist milieu that has intersected with Iran-aligned messaging channels. ***Hatem Fariz, a co-defendant in the Al-Arian trial who was later convicted of providing nonviolent support or services to PIJ, 68 serves as chairman, development director, and treasurer. 69 Sami Al-Arian's daughter, Leena Al-Arian, has also served in senior leadership roles at CCF. CCF co-sponsored a publication with Al-Arian's CIGA; this report, "The Terror Trap: The Impact of The War on Terror on Muslim Communities since 9/11"70 was coauthored and edited by Sami Al-Arian, and frames U.S. counterterrorism policy as a system of racialized repression, likens post-9/11 prosecutions to COINTELPRO-style abuses, and calls for dismantling core national security laws enacted after 9/11. Another member of the CCF Board of Directors, Sara Flounders, presents a distinct and independently significant overlap with the Iranian influence ecosystem. Flounders has had extensive documented call records with Press TV, the Iranian state broadcasting outlet, between 2019 and 2022; she also appeared as a featured commentator on that platform on multiple occasions over the past decade. 71 The significance of this is not her speech itself – which is constitutionally protected – but the governance-level placement of an individual with sustained Iranian state media ties on the board of a Florida-registered nonprofit72 that provides direct financial support to individuals convicted of terrorism-related offenses. The Flounders-Al-Arian relationship also has notable depth and duration. At a January 2002 International ANSWER rally in Washington, D.C.73 – a large 68 https://www.justice.gov/archive/opa/pr/2006/April/06_crm_221.html 69 https://www.civilfreedoms.org/page/about-us 70 https://www.civilfreedoms.org/sites/default/files/2024-09/terror-trap.pdf 71 https://networkcontagion.us/reports/the-hidden-switchboard-how-iranian-state-media-and-domestic-networks-drive-inf luence-operations-on-u-s-soil/ 72 https://search.sunbiz.org/Inquiry/corporationsearch/SearchResultDetail?inquirytype=EntityName&directionType=Initial &searchNameOrder=COALITIONFORCIVILFREEDOMSACTIO%20N200000140181&aggregateId=domnp-n200000 14018-e8c5bad5-5264-4ed7-96a9-360aeb481b0b&searchTerm=COALITION%20FOR%20ATTAINABLE%20HOMES %2C%20INC.&listNameOrder=COALITIONFORATTAINABLEHOMES%20N070000110470 73 https://www.c-span.org/program/public-affairs-event/international-answer-rally/139404 16pro-Palestine demonstration – both Flounders74 and Al-Arian75 were featured speakers, in addition to Nihad Awad of CAIR National and Brian Becker (National Coordinator for the ANSWER Coalition who, like Flounders, received dozens of calls from Press TV between 2019 and 2022). Flounders was a prominent public campaigner for Al-Arian's release from federal custody in 2006–2008, speaking alongside his daughters at press conferences on his behalf. 76,77 These pressconferences and campaigning activities were also attended, organized, and amplified by CAIR representatives78 – providing an early documented point of overlap between the CCF-Al-Arian network and CAIR's advocacy infrastructure. Al-Arian has publicly praised Flounders' published work in highly favorable terms. 79Sami Al-Arian's review of Sara Flounder's book "War Without Victory" , included with other 'celebrity' quotes on the first page after the cover. In October 2020, Flounders was listed as a featured speaker alongside Al-Arian in a CCF fundraising event whose promotional post was also published by CIGA's official Instagram account, with Al-Arian's personal Instagram tagged. 80 While none of these individual facts independently establish direction or control by Iranian actors, they do document a sustained and multi-year overlap between the CCF-Al-Arian governance structure and an advocacy sphere that has repeatedly and substantially intersected with Iranian state media and Iranian regime-adjacent networks. Financial Support to Convicted Terrorism Offenders CCF's central program involves direct financial sponsorship to incarcerated terrorism defendants and convicts. 81 The organization publicly acknowledges providing monthly stipends and Ramadan cash payments to hundreds of inmates convicted in terrorism cases. 82,83,84 74 Timestamp: 00:13:08 75 Timestamp: 01:08:48 76 https://www.workers.org/2008/us/al-arian_0717/ 77 https://www.workers.org/2008/us/al-arian_0424/ 78 https://www.cair.com/press_releases/cair-to-join-amt-shabazz-center-to-call-for-al-arians-release/ 79 https://www.workers.org/ww_books/war_without_victory.pdf 80 https://www.instagram.com/p/CF6iWgZAf5m/ 81 https://www.civilfreedoms.org/page/our-work 82 https://www.instagram.com/p/C8usUtpo5rh/ 83 https://www.instagram.com/p/C8-Iv-zNyDX/ 84 https://www.instagram.com/p/Crwflkwrc3v/ 17Digital poster advertising CCF's "Sponsor a Political Prisoner" program and soliciting direct donations. Posted by the CCF Instagram account in 2024. While CCF does not publicly disclose their full list of donation recipients, OSINT review shows that it has funded named individuals convicted of providing material support to foreign terrorist organizations, including ISIS-related offenses, attempted mass-casualty attacks and material-support convictions. One of the recipients of the CCF's $100 Ramadan gifts is Shukri Abu Baker, the former CEO of the Holy Land Foundation convicted in federal court of providing material support for Hamas. 85 It is noteworthy that, while CAIR-FL is a member organization of CCF and CAIR-San Francisco Executive Director Zahra Billoo also serves on the CCF Board of Directors, CAIR was also identified as an unindicted co-conspirator on the Holy Land Foundation trial86,87 (though CAIR has publicly disputed this designation, 88which was not accompanied by any charge or finding of liability). 85 https://www.justice.gov/archives/opa/pr/federal-judge-hands-downs-sentences-holy-land-foundation-case 86 https://www.texasattorneygeneral.gov/sites/default/files/images/press/Petition_7.pdf 87 https://www.investigativeproject.org/documents/case_docs/423.pdf 88 https://www.cair.com/dispelling-rumors-about-cair/ 18Baker's gratitude for the gift was publicized in a CCF Instagram post, which thanked the organization for sending Ramadan gifts to prisoners like him, and appealed to raise additional funds for prison gifts and stipends. 89 Instagram post from the Coalition for Civil Freedoms (CCF) featuring a letter from Shukri Abu Baker, the former CEO of the Holy Land Foundation who was convicted in federal court of financing Hamas, thanking CCF for sending Ramadan gifts to him and other prisoners. The post urges supporters to donate and states that the organization will "amplify their voices and stand with them and their families until they are free. Another CCF grant recipient is Leon Davis, who was convicted for attempting to provide material support to ISIL and traveled to try to join the U.S. -designated foreign terrorist organization. 90 Davis receives a monthly $100 stipend from CCF and has been used for CCF's public donation solicitations. 91,92 From a sanctions-compliance perspective, CCF's direct financial sponsorship of incarcerated individuals convicted of terrorism-related offenses presents elevated risk. U.S. sanctions law prohibits the provision of funds, goods, or services to 89 https://www.instagram.com/p/DVjWtP8kfiq/ 90 l https://www.justice.gov/usao-sdga/pr/georgia-man-sentenced-15-years-prison-attempting-provide-material-support-isi 91 https://www.instagram.com/p/C-x6xnSty-7/ 92 https://www.instagram.com/p/C-X6WJ2t8Oc/ 19designated individuals absent a specific license, and liability does not depend on intent or public framing. The absence of public disclosure regarding recipients materially impedes independent verification of sanctions compliance and undermines the controls sanctions regimes rely upon to function. CCF's decision to withhold recipient identities is not a peripheral governance choice, but a central operational feature that functionally prevents regulators, donors, and the public from assessing compliance with federal sanctions and nonprofit governance requirements. Florida Jurisdictional Nexus Although CCF publicly presents itself as a Washington, D.C. –based organization, its registration as a Florida nonprofit entity93 and its documented fundraising activity within the state create a direct jurisdictional nexus for Florida regulators. CCF does not appear to hold a valid business license in Florida,94 nor do they have an EIN on file with the state. Unlike religious institutions, CCF does not qualify for Florida's solicitation exemptions. If CCF has raised funds in Florida without proper registration or disclosure, state authorities may have authority to compel production of donor records, recipient lists, and sanctions-screening documentation. CCF operates as a sustained financial support mechanism for individuals convicted of terrorism-related offenses, while systematically obscuring recipient identities and operating across jurisdictions with limited transparency. Its governance structure, leadership overlap with convicted individuals, board-level overlap with the Iranian state media ecosystem, and fundraising activity in Florida collectively raise material questions regarding sanctions compliance, nonprofit oversight, and the adequacy of existing regulatory enforcement. ***Node Three: Islamic Community of Tampa (ICT) – Masjid Al-Qassam The Islamic Community of Tampa (ICT), also known as Masjid Al-Qassam, functions as an institutional continuity and resource node within the Al-Arian network. Founded and led by individuals who later became senior figures in Palestinian Islamic Jihad, the mosque has continued to operate under the leadership of an individual convicted of terrorism facilitation and has provided financial, logistical, and reputational support to allied organizations. ICT's 93 https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=Initi al&searchNameOrder=COALITIONFORCIVILFREEDOMSACTIO%20N200000140181&aggregateId=domnp-n20000 014018-e8c5bad5-5264-4ed7-96a9-360aeb481b0b&searchTerm=coalition%20for%20civil%20freedoms&listNameOr der=COALITIONFORCIVILFREEDOMS%20N200000140180 94 As per the Florida Department Of Business & Professional Regulation license lookup: https://www.myfloridalicense.com/wl11.asp?mode=1&SID=&brd=&typ= 20significance lies not only in its origins, but in its persistence as a governance structure through which network actors retain influence and operational capacity. ICT was founded in the late 1980s and incorporated in the 1990s by Sami Al-Arian, who was convicted in 2006 for providing material support to Palestinian Islamic Jihad. In 1994, Sami Al-Arian wrote to immigration officials on ICT letterhead to petition on behalf of Ramadan Abdullah Shallah, stating his offer to hire him as an imam at ICT for a salary of $30,000 a year, plus health insurance and vacation time.95 The following year, in 1995, Shallah served as an early ICT official and imam at ICT,96,97 became the Secretary-General of PIJ,98 and was sanctioned under OFAC as a Specially Designated Terrorist;99 Shallah's official start as PIJ Secretary General and his OFAC designation both overlapped with his formal affiliation with ICT, at least according to IRS filings from 1995 and 1996. Shallah was later placed on the FBI's Most Wanted list in 2007, with a multimillion-dollar reward offered for his arrest. 100 These facts establish that ICT's very genesis was embedded in Iranian proxy networks – specifically PIJ, which receives sustained material and financial support from Iran's IRGC and is considered a core node in Iran's proxy architecture – not merely adjacent to them. The ICT's governance was, from its inception, intertwined with designated terrorist leadership, and this did not end with Al-Arian's conviction or deportation. Instead, leadership and operational influence transitioned seamlessly to one of his co-defendants: Hatem Fariz. After Al-Arian's indictment, conviction, and deportation, ICT did not sever ties with his network, instead, becoming a continuing hub for his associates. Hatem Naji Fariz – who was convicted of conspiracy to provide nonviolent support or services to PIJ, and served approximately 37 months in federal prison101 – now serves as ICT's director and registered agent. 102,103,104 Fariz also serves multiple 95 https://www.investigativeproject.org/documents/case _docs/267.pdf 96 https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C1607 %5C0119%5CAR007229.tif&documentNumber=N50793 97 https://search.sunbiz.org/Inquiry/CorporationSearch/ConvertTiffToPDF?storagePath=COR%5C1996 %5C0201%5C90594015.TIF&documentNumber=N50793 98 https://www.justice.gov/archive/opa/pr/2003/February/03 crm 099.htm __ 99 https://sanctionssearch.ofac.treas.gov/Details.aspx?id=4257 100 https://archives.fbi.gov/archives/news/stories/2007/february/rewards 021207 _ 101 https://www.justice.gov/archive/opa/pr/2006/April/06 crm 221.html _ 102 https://ictampa.org/?page id=2126 _ 103 https://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName& directionType=CurrentList&searchNameOrder=ISLAMICCOMMUNITYTAMPA%20N507930&aggregateId =domnp-n50793-85155638-a593-4eeb-a8ba-0b92e0d6b248&searchTerm=The%20Islamic%20Communit y%20Of%20Tampa%2C%20Inc.&listNameOrder=ISLAMICCOMMUNITYTAMPA%20N507930 104 https://www.linkedin.com/in/hatem-fariz-21a03233 21leadership roles, including Development Director and Treasurer, in the Coalition for Civil Freedoms (CCF), a 501(c)(3) that was also initially founded by Al-Arian. 105 Despite this record, Fariz has since been publicly rehabilitated as a "community leader" in Tampa, organizing pro-Palestinian rallies and being described by local officials as a "trusted" figure. His past as an individual who provided nonviolent support to PIJ, however, is a matter of federal record and remains directly relevant to ICT's governance and activities. ICT's current governance structure places operational control in the hands of an individual convicted of providing support or services to a U.S. -designated terrorist organization. As director and registered agent, Fariz exercises fiduciary authority over the mosque's finances, property, and institutional decision-making. This concentration of control is material from an oversight perspective, as it determines who directs fundraising, allocates resources, and represents the institution to external partners. A striking example of this concentration of control is a $9,000 grant from the CCF awarded to ICT in 2021. 106 The transfer is significant because it demonstrates an internalized funding loop between two Al-Arian-linked institutions, both of which where Hatem Fariz holds leadership positions. ***With Hatem Fariz holding senior fiduciary roles at both entities – including treasurer at CCF and director at ICT – the grant reflects a consolidation of financial discretion within a single convicted network actor. This overlap eliminates meaningful independence between grantor and grantee, raises conflict-of-interest concerns, and underscores how resources can be directed across aligned organizations without external checks. From an oversight and risk perspective, the grant illustrates how ICT continues to function as a beneficiary node within a tightly controlled ecosystem of affiliated nonprofits, enabling the movement of funds, legitimacy, and institutional support through shared governance rather than transparent, independent decision-making. ICT has also played an active financial and operational role in supporting allied organizations.107,108,109110 Most notably, Masjid Al-Qassam (ICT) was a leading sponsor of CAIR-Florida's 2021 fundraising gala, 111,112 providing financial backing and venue support; this was during the same fiscal year in which ICT received $9,000 from CCF in order to support the "needs of the organization". In effect, a 105 https://www.civilfreedoms.org/page/about-us 106 https://projects.propublica.org/nonprofits/organizations/451653796/202201369349305635/full 107 https://www.cair.com/press _ releases/cair-florida-islamic-community-of-tampa-and-family-of-sayfollah- musallet-to-hold-emergency-community-vigil/ 108 https://youtu.be/IaZfCeILrrM?si=9MT49xP2XrgfrGop&t=15 109 https://www.facebook.com/100064587523594/posts/1161165069379733/?rdid=AEVYwvEkkreOGs2l 110 https://www.wmnf.org/wmnf _ events/10th-annual-community-potluck/ 111 https://www.youtube.com/live/xBS09KpfWm4?si=DOLvezYQChljLyMp&t=1160 112 https://www.facebook.com/1446908550/posts/10219827519305547/ ***22mosque founded and managed by PIJ operatives became a principal financial and logistical pillar of a self-described civil-rights organization, despite apparently needing funds from a closely related nonprofit with overlapping personnel. Screencapture from a recording of CAIR Florida's 2021 fundraising gala, with the full video posted on the CAIR Florida official YouTube channel. CAIR-FL thanks the Islamic Community of Tampa for being a leading sponsor of this gala. As a religious institution, ICT is exempt from Florida's charitable solicitation registration requirements, allowing it to raise funds without the disclosure obligations imposed on other nonprofits. While lawful, this exemption materially reduces regulatory visibility at the precise point where individuals with terrorism-related convictions exercise institutional control. ICT's legal designation as a religious institution creates additional financial opacity; where CCF as a 501(c)(3) is required to disclose certain financial information in its tax filings, ICT is exempt from this required funding transparency. It creates a durable institutional node through which the flow of funding becomes increasingly difficult to track. Node Four: CAIR-Florida – Extremism, Fundraising, and Political Intervention The Council on American-Islamic Relations Florida chapter (CAIR-FL) functions as a normalization, fundraising, and political-intervention node within the broader Al-Arian network. Through repeated platforming of individuals convicted of terrorism-related offenses, integration of their narratives into donor appeals, and sustained political messaging during active election cycles, CAIR-FL has blurred the line between civil-rights advocacy and conduct that raises material compliance 23risks under IRS 501(c)(3) restrictions, federal funding requirements, and Florida nonprofit law. CAIR-FL has repeatedly platformed, promoted, and fundraised with Sami Al-Arian and Hatem Fariz, reframing both men as victims of persecution while minimizing or omitting the factual basis of their terrorism convictions. These engagements included gala previews, donor solicitations, webinars, documentary sponsorships, and public testimonials—some occurring during fiscal years in which CAIR-FL reported receiving government funds. CAIR-FL has also integrated these individuals into its fundraising ecosystem, using their narratives to mobilize donors. Fariz, for example, appeared in gala videos recounting how CAIR "provided relief" during his criminal proceedings, while Al-Arian was featured in webinars and paid events framed as civil-rights advocacy. More recently, CAIR-FL's activities have crossed into explicit and implicit election intervention, including direct exhortations to vote against named candidates and sustained praise of specific officeholders during active election cycles – conduct that the IRS has repeatedly identified as prohibited campaign intervention for 501(c)(3) organizations. " Sustained Engagement With Convicted PIJ Facilitators During Periods of Public Funding Publicly available records indicate that CAIR-FL has, over multiple years, engaged in repeated, affirmative interactions with individuals convicted in U.S. federal court of providing material support or services to Palestinian Islamic Jihad (PIJ), a U.S.-designated Foreign Terrorist Organization within the Iranian Regime proxy network.113 These engagements occurred during periods in which CAIR-FL reported receiving government funding, according to its IRS Form 990 filings. These interactions include fundraising-related use of convicted individuals' reputations, event hosting, promotional activity, public advocacy, and content dissemination, including during fiscal years in which CAIR-FL reported thousands of dollars in public funds. CAIR-FL's repeated use of convicted terror conspirators as featured speakers, testimonial subjects, and fundraising symbols constitutes organizational conduct rather than incidental speech. These engagements were planned, promoted, monetized, and integrated into CAIR-FL's donor ecosystem, transforming criminal convictions into affirmative fundraising and legitimacy assets. 113 https://www.state.gov/foreign-terrorist-organizations 24Sami Al-Arian's case has been heavily supported by CAIR National and a multitude of regional CAIR chapters, including CAIR-FL, for over two decades. Prior to any convictions, CAIR-FL organized a "Call for Justice" rally and news conference for Al-Arian in 2006. 114 After Al-Arian was convicted of providing material support to Palestinian Islamic Jihad, CAIR-FL sponsored a local showing of a documentary about Al-Arian in 2008. 115,116,117,118 This documentary "takes the family's perspective" during Sami Al-Arian's legal proceedings and conviction, and characterizes the investigation as "post-Sept. 11 hysteria and the persecution of a Muslim" 119 . On May 18, 2020, Hassan Shibly – then-Executive Director of CAIR-FL – promoted on his personal Facebook page a Zoom webinar with Sami Al-Arian that doubled as a "unique" and "exclusive" online fundraising event "in support of justice" . 120 This webinar was cosponsored by the Coalition for Civil Freedoms, which in 2020 listed CAIR-FL as a member organization and Hassan Shibly on the Advisory Council. 121 The entrance fee to listen to Al-Arian speak cost £5. Three months later, on August 16, 2020, CAIR-FL featured Al-Arian in a heavily-publicized webinar about his experience as a "political prisoner" 122,123,124,125,126 . Screencapture of a Facebook post by Hassan Shibly, then-Executive Director of CAIR-Florida, 114 https://www.cair.com/press_releases/cair-fl-call-for-justice-in-al-arian-case/ 115 https://www.cair.com/cair_in_the_news/cair-fl-film-on-al-arian-opens-next-week/ 116 https://www.cair.com/cair_in_the_news/cair-fl-al-arian-documentary-tours-country/ 117 https://www.cair.com/cair_in_the_news/fl-paper-profiles-cair-tampa-rep/ 118 https://www.cair.com/cair_in_the_news/cair-fl-1200-turn-out-for-al-arian-doc-premier/ 119 https://www.cair.com/cair_in_the_news/cair-fl-al-arian-film-takes-familys-perspective/ 120 https://www.facebook.com/share/1GzcR77pQx/ 121 https://www.civilfreedoms.org/sites/default/files/2024-10/CCF-2020_Annual_Report_v2.0-PAGES.pdf 122 https://www.youtube.com/watch?v=4EEOt8Z4_GI 123 https://www.instagram.com/p/CDuYqJYgeQW/ 124 https://www.youtube.com/watch?v=TSFTNYp-FeI 125 https://www.eventbrite.com/e/exposed-episodes-1-4-tickets-115991009231 126 https://www.facebook.com/15700293/posts/10106830858531698/ 25promoting an online fundraising event featuring Sami Al-Arian. Shibly's post characterizes Al-Arian as unjustly imprisoned, references his hunger strike, and directs viewers to register for a paid Zoom event organized by the Coalition for Civil Freedoms. CAIR-FL webinar featuring Sami Al-Arian speaking about his experience being under federal investigation, convicted, and deported to Türkiye. In this video, CAIR-FL portrays Al-Arian – like Fariz – as a former "political prisoner" who was unjustly targeted by the US government for his pro-Palestine activism. In addition to platforming Al-Arian, CAIR-FL also amplified and raised funds with Hatem Fariz, a co-defendant in the Al-Arian trial. Fariz – who was convicted in U.S. federal court of providing non-violent services or material support to PIJ127 and later convicted for wire fraud and money laundering in a food stamp scheme128 –was also featured in a CAIR-FL webinar about his experience as a "political prisoner" in 2020. 129 The same year, he was nominated for CAIR-FL's 2020 Annual Protect Award. 130During the 2020 fiscal year, CAIR-FL received $110,100 from government funds131 while sponsoring and promoting three separate events to platform convicted terror conspirators. Hatem Fariz was also featured in promotional material for CAIR-FL's 20th annual fundraising gala in 2021, which raised over $100,000 for CAIR-FL. 132,133,134 In this crm 221.html 127 https://www.justice.gov/archive/opa/pr/2006/April/06 128 https://www.nbcnews.com/id/wbna14416473 129 https://www.youtube.com/watch?v=QWiq7Urj2PQ 130 https://www.facebook.com/share/1CuJJD91Yd/ 131 https://projects.propublica.org/nonprofits/organizations/651110616/202132529349300718/full 132 https://www.facebook.com/CAIRFlorida/videos/we-face-a-grave-threat-to-our-rights-with-hatem-fariz-20- year-gala-previewhatem-/556358915468070/ 133 https://www.youtube.com/watch?v=mDA4uyvYy8U 134 https://www.instagram.com/p/CVV4PzusHjt/ 26promotional video, Fariz made reference to receiving "relief" from CAIR during his legal proceedings. Through this donor appeal, CAIR-FL utilized Fariz's name and status to mobilize donors. As a convicted individual, his story – framed as being "unjustly targeted by the FBI"– was used to advance CAIR-FL's appeal for donations and gala attendance. Fariz also appeared as a guest speaker during this gala, soliciting funds for CAIR-FL by framing his legal proceedings as unjust and "baseless" . 135 Notably, CAIR-FL reported receiving $182,171 in government funds during the same fiscal year as this fundraising appeal. 136 Screencaptures from the 2021 CAIR-FL gala fundraising video featuring Hatem Fariz. He was positioned as endorsing CAIR-FL because of support he received throughout his federal investigation and conviction for PIJ-related offenses. Taken together, these activities reflect a consistent organizational practice of converting criminal convictions into donor-facing narratives, rather than isolated or inadvertent uses of controversial speakers. The compliance significance of these activities is heightened by CAIR-FL's receipt of government funding during the same fiscal years in which it platformed and fundraised with individuals convicted of providing material support to a U.S. -designated terrorist organization. Public funding regimes impose heightened expectations of internal controls, reputational risk management, and adherence to federal law; repeated reliance on convicted individuals as organizational representatives raises questions regarding whether those expectations were met. Fariz also solicited donations for CAIR-FL's 18th and 19th Annual Banquets on his personal Facebook account, including a stated $10,000 fundraising goal for one event. 137,138 135 https://www.youtube.com/live/xBS09KpfWm4?si=fXdgFnv8-byMLiw7&t=1932 136 https://projects.propublica.org/nonprofits/organizations/651110616/202233129349300403/full 137 https://www.facebook.com/share/v/1ESqNGTDS7 138 https://www.facebook.com/share/1bMsDgYkag 27Hatem Fariz solicited donations for CAIR-FL Annual Banquets in 2018 and 2019. Left: Donation drive for the CAIR-FL 18th Annual Banquet on his personal Facebook account in 2018. His stated fundraising goal was $10,000, and he appeared to have raised a total of $250 through his donation link. Right: Donation drive for the CAIR-FL 19th Annual Banquet on his personal Facebook account in 2019. Though Hatem Fariz does not appear to hold an official position for CAIR-FL, both Fariz and the Islamic Community of Tampa (which he directs and serves as president) have collaborated with CAIR-FL for events and fundraisers. CAIR-FL designated Hatem Fariz as an organizer and contact personnel for their Tampa Week of Action held October 17, 2023 through October 21, 2023.139,140,141,142 The Islamic Community of Tampa also cosponsored a community fundraiser with CAIR-FL in 2022. 143 Repeated Campaign Intervention In addition to fundraising and normalization activities, CAIR-FL has repeatedly engaged in political messaging that raises independent and significant compliance 139 https://www.instagram.com/p/CyghF6QAUWU 140 https://x.com/cairflorida/status/1714330130196148447 141 https://www.instagram.com/p/CygpdeaPTdk/ 142 https://x.com/cairflorida/status/1714348836469051849 143 https://m.facebook.com/story.php?story_ fbid=5241359602565059&id=100000732120533&http_ ref=ey J0cyI6MTc2NTU3MTkyMTAwMCwiciI6IiJ9 28risk under IRS rules governing tax-exempt organizations. CAIR-FL, as a tax-exempt 501(c)(3) organization, is strictly prohibited under 26 U.S.C. § 501(c)(3) and Treas. Reg. § 1.501(c)(3)-1(c)(3)(iii) from intervening in political campaigns for or against candidates for public office. 144,145 This ban includes explicit endorsements or opposition, as well as implicit actions such as urging people to vote for or against a specific candidate, rating or ranking candidates in a way that favors one, coordinating messaging with a candidate or campaign, or timing communications to influence an election. The prohibition applies to all forms of communication, including statements, social media posts, events, videos, and links to external materials; violations can occur even without specific language like "vote for" or "vote against" . Explicit Praise or Condemnation of Named Candidates or Elected Officials with a Call to Action Directed at Them Expressed opposition to then-Presidential candidate Donald Trump in 2015 Hassan Shibly, then-Executive Director of CAIR-FL, stated in a radio interview in 2015 during the Presidential election campaign,"We really just need to stand united and stand against the likes of Trump that are just destroying our nation. If you want to destroy America, vote for Trump because that's exactly what he'll do."146 144 https://uscode.house.gov/view.xhtml?req=%28%22cross+reference%22%29+AND+%28%28title%3A %2826%29%29%29+AND+body%3A%28 145 https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR062882ac6495 890/section-1.501(c)(3)-1 146 https://www.wmnf.org/cair-florida-speaks-out-against-trumps-call-to-ban-muslims-from-entering-us/ 29Screencapture of the webpage containing Hassan Shibly's interview in which he opposed Trump (quoted remarks begin at 10:48). The interview was billed as an officially sanctioned conversation with CAIR-FL, and Hassan Shibly's title of Executive Director of CAIR-FL is used both in the interview and in print. Acting in his capacity as Executive Director of CAIR-FL, Hassan Shibly provided clear, explicit opposition to a named presidential candidate during an active election cycle, and directly instructed listeners how to vote. This presents what IRS guidance describes as a high-risk example of prohibited campaign intervention, as explicit opposition to an identifiable candidate during a campaign is a classic example of prohibited campaign intervention. 147Implicitly endorsed Representative Angie Nixon in 2023 CAIR-FL published repeated promotional posts praising Representative Angie Nixon's "courage, " "leadership," and "values", and encouraged readers to send messages of gratitude to her official legislative email address.148,149 CAIR-FL co-hosted and advertised a press conference and rally featuring Rep. Nixon as a named speaker, due to her filing a ceasefire resolution in the Florida House in 147 https://www.irs.gov/charities-non-profits/charitable-organizations/restriction-of-political-campaign-intervention-by-secti on-501c3-tax-exempt-organizations 148 https://www.instagram.com/reel/CzpN03Uux7S/ 149 https://www.instagram.com/reel/CzXFO3ROCel/ 30November 2023. 150,151,152 These posts also frequently paired endorsements of Representative Nixon with donation requests to CAIR-FL, and several posts contained comments from CAIR-FL tagging Rep. Nixon with supportive emojis. In September 2023, Rep. Nixon announced a call for her reelection as state representative and asked for campaign donations, 153 placing CAIR-FL's November 2023 statements in the context of an active electoral campaign. Repeated praise, amplification, and calls to action directed at a sitting elected official closely resemble implicit endorsement, especially outside a neutral voter-education context. While neutral issue advocacy is permitted, IRS guidance warns that 501(c)(3)s cannot publish or distribute statements on behalf of any candidate for public office. Repeated praise of an officeholder that goes beyond neutral issue coverage, especially paired with explicit calls for supporters to contact her, can be interpreted as implicit endorsement or partisan intervention. 150 https://www.instagram.com/p/CzeSUj-g4pG/ 151 https://www.instagram.com/reel/CzoxJYIgjZq/ 152 https://www.instagram.com/reel/Czr-kpXrM2a/ 153 https://www.instagram.com/p/Cw3Fot4Ot8I/ 31CAIR-FL social media posts appearing to endorse Rep. Angie Nixon, November 2023. Top left: CAIR-Florida Instagram video featuring Rep. Nixon speaking at a CAIR-FL sponsored Tallahassee press conference, with the caption "Witness again Representative Nixon's courage," a donation solicitation to CAIR-FL, and a comment from CAIR-FL tagging Rep. Nixon with a heart emoji. Top right: CAIR-FL promotional graphic advertising their "Stand for Ceasefire" multi-faith press conference and rally at the Florida State Capitol, prominently naming Rep. Angie Nixon as the guest speaker and highlighting her role in introducing a ceasefire resolution in the Florida House. Bottom left: CAIR-FL Instagram post showing Rep.Nixon speaking on the Florida House floor, accompanied by text commending her for "boldlychampioning the ceasefire resolution" and directing followers to email Rep. Nixon to express thanks. Bottom right: CAIR-FL Instagram video of an interfaith press conference at the Florida State Capitol supporting Rep. Nixon's ceasefire resolution, with a caption explicitly stating support for her legislative action and linking to CAIR-FL donation pages. 32Expressed opposition to Representative Randy Fine in 2025 CAIR-FL selected the frame containing the text "Florida has the chance to vote him out today. Will they?" as the video thumbnail for the post. 154 The post also includesthe hashtag #HoldThemAccountable in the caption. Though phrased as a question, this appears to be electoral advocacy aimed at influencing the outcome (removal) of a specified officeholder. IRS guidance emphasizes that intervention includes publishing or distributing statements that favor or oppose a candidate, which applies to messaging intended to encourage voters to vote against someone. CAIR-FL Social media content referencing Rep. Randy Fine's bid for reelection. The language and visual framing directly reference voting against a specific candidate during an election period. Left: Screencapture from CAIR-Florida's official Instagram account showing a video post featuring Florida Representative Randy Fine during a legislative hearing. The post's selected thumbnail and overlaid text read: "Florida has the chance to vote him out today. Will they?" The post includes the hashtag #HoldThemAccountable. Right: Close-up view of the same CAIR-Florida video post. The framing centers on the prospect of electoral removal of a named, identifiable candidate for public office, rather than discussion of a policy issue in the abstract. Viewed collectively, CAIR-FL's conduct reflects a sustained pattern of political intervention rather than isolated misstatements. Over multiple election cycles, the organization has engaged in explicit opposition to named candidates, repeated praise of specific officeholders during active campaigns, and calls to action directed at voters through official organizational channels. This pattern aligns with conduct the IRS has consistently identified as high-risk for 501(c)(3) organizations. Analytical Takeaway 154 https://www.instagram.com/reel/DL5lTIZuH1l 33CAIR-FL functions as a key normalization and fundraising conduit for individuals convicted of terrorism-related offenses while simultaneously engaging in conduct that raises substantial risk under IRS campaign-intervention rules and public-funding compliance standards. Its repeated platforming of convicted individuals, monetization of their narratives, and sustained political messaging during election cycles suggest systemic governance failures rather than isolated lapses. CAIR-FL does not operate in isolation from the Al-Arian and CCF networks. Its repeated collaboration with the same individuals, shared fundraising narratives, and overlapping leadership roles demonstrate operational interoperability rather than arm's-length association. This interoperability magnifies compliance risk by allowing conduct originating in one node – such as sanctions exposure or financial opacity – to propagate through others. Overall Conclusion155 This report documents a networked set of relationships and activities linking Florida-based nonprofit, religious, and advocacy organizations to individuals convicted of terrorism-related offenses or designated under U.S. sanctions authorities. Viewed individually, many of the actions described – public speaking events, fundraising appeals, institutional partnerships, or political messaging – might be framed as protected expression or isolated governance failures. When examined collectively, however, they reveal a consistent and reinforcing pattern in which the same individuals, narratives, and institutions recur across organizational boundaries, jurisdictions, and regulatory regimes. The network documented in this report is analytically consistent with the kind of layered domestic infrastructure that benefits Iran's broader proxy strategy – not because any of the organizations are shown to operate under Iranian direction, but because the structure performs functions that serve Iranian influence interests regardless of the question of direction. Iran's approach to proxy influence has historically relied on ideologically aligned actors who share strategic goals, rather than a requirement for direct command relationships. The co-platforming of PIJ facilitators, Hamas officials, and Iranian government-affiliated academics through the same institutional forums, fundraising apparatus, and advocacy channels – across years and jurisdictions – is consistent with a shared ideological ecosystem that intersects with, and benefits, Iran's regional strategy. 155 References in this report to 'support' describe organizational conduct such as fundraising, platforming, sponsorship, or advocacy, and do not assert criminal 'material support' liability by any organization. All findings are based on publicly available records and are presented for purposes of policy analysis, regulatory review, and public-interest research. 34This assessment is offered as analytical judgment for policymakers and regulators, not as a finding of law. The evidence base supports the compliance and oversight conclusions with greater certainty than it supports conclusions about intent or direction. Across all four nodes examined (Sami Al-Arian and CIGA, the Coalition for Civil Freedoms, CAIR-Florida, and the Islamic Community of Tampa), several common characteristics emerge. First, individuals with documented terrorism-related convictions or sanctions designations are repeatedly positioned not as marginal figures, but as central actors whose reputations are rehabilitated, whose narratives are amplified, and whose participation is actively monetized or legitimized through institutional platforms. Second, these activities are not confined to a single organizational form: they span academic programs, civil-rights advocacy, religious institutions, and donor-funded nonprofits, allowing conduct originating in one domain to propagate through others with limited friction. Third, the network demonstrates a recurring reliance on structural opacity. Whether through the nondisclosure of funding recipients, the use of religious exemptions that reduce regulatory visibility, or the diffusion of responsibility across formally separate but operationally interoperable entities, oversight mechanisms appear repeatedly strained. This opacity functions as a structural feature – not an incidental one – that impedes independent verification of sanctions compliance, nonprofit governance standards, and restrictions tied to public funding or tax-exempt status. Fourth, the evidence suggests that Florida plays a materially significant role in this ecosystem. Multiple entities are incorporated, registered, or operationally active within the state; fundraising and political activity has occurred within Florida's jurisdiction; and Florida-based institutions have provided financial, logistical, or legitimizing support to allied organizations. As a result, state-level regulatory authorities possess independent jurisdictional tools, distinct from federal enforcement mechanisms, that are directly relevant to assessing compliance, transparency, and governance practices. This report does not assert criminal liability or presume enforcement outcomes. It presents a consolidated factual record indicating that existing oversight frameworks for sanctions enforcement, nonprofit regulation, charitable solicitation, and campaign-intervention prohibitions may not be functioning cohesively or effectively in the contexts examined. The persistence and interoperability of the network described herein suggest that regulatory review 35conducted in isolation – entity by entity – may miss systemic risk that only becomes visible when patterns are assessed across institutions and time. Accordingly, the findings support the need for coordinated review by relevant federal, state, and institutional authorities to evaluate compliance with applicable laws and regulations, assess governance and disclosure practices, and determine whether corrective, remedial, or policy responses are warranted. At a moment of elevated U.S. -Iran tensions, the domestic dimensions of Iran's proxy ecosystem warrant attention not only as a compliance matter but as a national security one. 36 |
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