# Foreign Terrorist Organization A **Foreign Terrorist Organization** is an organization designated by the Secretary of State under section 219 of the Immigration and Nationality Act (8 U.S.C. § 1189), after consultation with Treasury and the Attorney General, with seven days' advance notice to congressional leadership and a Federal Register notice. It is a [[Department of State]] track, not an [[Office of Foreign Assets Control]] one. It carries consequences no IEEPA listing does: - knowingly providing "material support" becomes a felony under 18 U.S.C. § 2339B; - members and supporters become inadmissible; - U.S. banks must block the organization's funds; - the Anti-Terrorism Act opens private treble-damages suits. Judicial review is confined to the D.C. Circuit, within 30 days, on the administrative record, and a designated organization may not relitigate the designation's facts in a later criminal case. Revocation may be sought by petition two years after designation, and the Secretary must review every designation every five years. Congress may block or revoke a designation by Act of Congress, which makes this the one listing in the sanctions system Congress can reach by name. ## FTO versus SDGT The two are routinely paired but they are not the same. - **Specially Designated Global Terrorist (SDGT).** An executive-order listing under E.O. 13224, made by State or Treasury. It freezes assets and bars transactions. - **FTO.** The statutory designation that turns support into a crime. The material-support ban is broad by design. *Holder v. Humanitarian Law Project* (2010, 6–3) upheld it even as applied to training and expert advice on peaceful dispute resolution given in coordination with a designated group. Speech coordinated with an FTO can be a felony. ## The 2025–26 expansion The designation was built for jihadist and nationalist insurgent groups. In 2025–26 it was stretched in three directions. - **Cartels (February 20, 2025).** Eight Latin American criminal organizations were designated at once, including Tren de Aragua, MS-13, the Sinaloa Cartel and CJNG. Cartel de los Soles was designated an SDGT by Treasury in July 2025 and an FTO effective November 24, 2025, naming [[Nicolás Maduro]] as its head. That label became the narcoterrorism predicate for his capture on January 3, 2026. - **"Antifa" abroad (November 2025).** Four European militant groups were designated on November 13, effective as FTOs on November 20. They were Germany's Antifa Ost, the Italian-rooted Informal Anarchist Federation, and two Greek groups. It was the first time the label was applied to groups tied to antifa activism. It followed the domestic [[Antifa]] designation and [[NSPM-7]] (see [[Donald Trump - antifa terrorist designation]]). - **The [[Muslim Brotherhood]] (January 13, 2026).** Under Executive Order 14362 (November 24, 2025), the Lebanese branch was designated an FTO and SDGT. The Egyptian and Jordanian branches were designated SDGT only, the weaker label. The cartel and antifa expansions matter because of the material-support statute. Once a group is an FTO, the question of who counts as "supporting" it becomes a federal criminal question, and courts defer heavily to the designation. ## See Also - [[Sanctions Designation Pipeline]] · [[Secondary Sanctions]] · [[Office of Foreign Assets Control]] - [[Department of State]] · [[Nicolás Maduro]] · [[Venezuela]] - [[Antifa]] · [[NSPM-7]] · [[Muslim Brotherhood]]