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[371] One piece of evidence was a strategy memorandum which sets out the goal of the Shariah faithful in theU.S.:

4- Understanding the role of the Muslim Brother in North America:

The process of settlement is a “Civilization-Jihadist Process” with all the word means. The Ikhwan must understand that their work in America is a kind of grand Jihad in eliminating and destroying the Western civilization from within and “sabotaging” its miserable house by their hands and the hands of the believers so that it is eliminated and God’s religion is made victorious over all other religions. Without this level of understanding, we are not up to this challenge and have not prepared ourselves for Jihad yet. It is a Muslim’s destiny to perform Jihad and work wherever he is and wherever he lands until the final hour comes, and there is no escape from that destiny except for those who chose to slack. But, would the slackers and the Mujahedeen be equal.

Government Exhibit 003-0085, U.S. v. Holy Land Found. for Relief and Dev., CR NO. 3:04-CR-240-G (N.D. Tex. 2007) (Arabic), available at (last visited Feb. 2, 2008).

[372] Editorial, Motion for Retrial, Investor’s Business Daily, Oct. 23, 2007, available at (last visited Feb. 2, 2008).

[373] Investigative Project on Terrorism, Muslim Students Association Dossier, available at (last visited Feb. 2, 2008).

[374] DJIF Prospectus, supra note 365, at 12.

[375] Terrorism: Growing Wahhabi Influence in the United States: Hearing Before the Subcomm. on Terrorism, Technology and Homeland Security of the S. Comm. on the Judiciary, 108th Cong. (2003). The Qur’anic Literary Institute affair appeared in a Wall Street Journal story and was recounted in an article in The Tax Lawyer, the American Bar Association’s tax journal:

[I]n 1991, a Mr. Qadi, an investor in BMI [a company connected to Hamas and tied to funding of terror], transferred $820,000 through one of his companies from a Swiss bank account to the Qur’anic Literacy Institute, a Chicago-based organization. The U.S. government has alleged that the Qur’anic Institute “lent substantial assistance, through means of repeated and possibly illegal subterfuge and misrepresentation, to a man who is an admitted operative of Hamas.” Mohammad Salah, an employee of the Qur’anic Literary Institute, was arrested in Israel in 1993 “with a large sum of cash and a cache of notes describing meetings with various Hamas cells,” and later pled guilty in an Israeli court “to being a top Hamas operative involved in raising money for the terror group.” n58 A 1995 confession by Mr. Salah stated that while in Chicago “in the early 1990s, he trained recruits to work with ‘basic chemical materials for the preparation of bombs and explosives,’ as well as various toxins.”

Mindy Herzfeld, Restricting the Flow of Funds from U.S. Charities to International Terrorist Organizations–A Proposal, 56 Tax Law. 875, 875 n.57 (2003). The story, as told by the media at the time, was that the Qur’anic Literacy Institute was operated out of a residential apartment building in Chicago and was funneling hundreds of thousands of dollars to Hamas. See, e.g., Darlene Gavron Stevens & Matt O’Connor, Friends Defend Bridgeview Man Linked to Terror, Chi. Trib., June 11, 1998.

[376] Eric Lichtblau & James C. Mckinley, 2 Albany Men Are Arrested in Plot to Import a Missile and Kill a Diplomat, N.Y. Times, Aug. 6, 2004, at B-1.

[377] Brian Nearing, Trust Owns Mosque Location; Group Spent $40,000 For Central Avenue Site; Others Linked To Terror Activities, Reports Reveal, Times Union (Albany,NY), Aug. 6, 2004.

[378] Statement of Additional Information, supra note 364, at 13.

[379] See, e.g., 31 C.F.R. § 103.131 (2003) (emphasis added):

(b) Customer identification program: minimum requirements.

(1) In general. A mutual fund must implement a written Customer Identification Program (“CIP”) appropriate for its size and type of business that, at a minimum, includes each of the requirements of paragraphs (b)(1) through (5) of this section. The CIP must be a part of the mutual fund’s anti-money laundering program required under the regulations implementing 31 U.S.C. 5318(h).

(2) Identity verification procedures. The CIP must include risk-based procedures for verifying the identity of each customer to the extent reasonable and practicable. The procedures must enable the mutual fund to form a reasonable belief that it knows the true identity of each customer. The procedures must be based on the mutual fund’s assessment of the relevant risks, including those presented by the manner in which accounts are opened, fund shares are distributed, and purchases, sales and exchanges are effected, the various types of accounts maintained by the mutual fund, the various types of identifying information available, and the mutual fund’s customer base. At a minimum, these procedures must contain the elements described in this paragraph (b)(2)

. . .

(C) Additional verification for certain customers. The CIP must address situations where, based on the mutual fund’s risk assessment of a new account opened by a customer that is not an individual, the mutual fund will obtain information about individuals with authority or control over such account, including persons authorized to effect transactions in the shareholder of record’s account, in order to verify the customer’s identity. This verification method applies only when the mutual fund cannot verify the customer’s true identity using the verification methods described in paragraphs (b)(2)(ii)(A) and (B) of this section. (Emphasis added.)

[380] Azzad Asset Management, (last visited Feb. 2, 2008)

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