Via Hand Delivery


September 20, 2001


The Honorable Charles O. Rossotti


Internal Revenue Service

1111 Constitution Ave, NW

Washington, DC 20224


Re: Complaint Concerning Certain Tax Exempt And Other Organizations Reportedly Used As Money Laundering Front Operations For Terrorist Activities In

The United States And Abroad.



Dear Commissioner Rossotti:




Judicial Watch, Inc., the public interest law firm that investigates and prosecutes government abuse and corruption, hereby files a complaint against certain tax exempt and other organizations that are, based on publically available information, reportedly being used as money laundering front organizations for radical Islamic terrorists, to include but not limited to associates of Osama bin Laden and “HAMAS,” and their operations, in both the United States and abroad.[1]


As set forth below, the Internal Revenue Service (“IRS”) must, given the current state of war with terrorists and states which harbor them, expeditiously investigate the misuse of these tax exempt and other organizations, and, if necessary, shut them down forthwith. A copy of this letter is being provided to the President of the United States, Attorney General John Ashcroft, and other government agencies, including but not limited to all members of Congress (Senate and House), to insure that the IRS and other authorities take swift appropriate action.

In the past several years, the IRS has seen fit, largely under your direction, to audit tax exempt entities and individuals who were perceived to be adverse to President Bill Clinton and his administration. Scores of persons and entitities, many of whom are Judicial Watch clients, such as Billy Dale, Gennifer Flowers, Juanita Broaddrick, Katherine Prudhomme, the Western Journalism Center, United We Stand America, and others were harassed. In addition, over 20 conservative foundations, which criticized President Clinton and his administration, were audited, resulting in great damage to their financial condition and reputations.  Not a single liberal organization supportive of President Clinton, such as Jesse Jackson’s Rainbow–P.U.S.H. Coalition, was audited and harassed.  Indeed, Jesse Jackson’s own accountant has publically confirmed that Rainbow – P.U.S.H. has never been audited, despite publicly reported misuse of tax exempt monies.  As a Clinton appointee, and given the pattern of political audits, it is obvious that you were responsible for this selective prosecution.


However, while you and the IRS engaged in a pattern of political audits on behalf of your benefactor, President Bill Clinton – who not coincidentally granted you a waiver for your conflict of interest concerning AMS[2], a company you own and which contracts with the IRS for tens of millions of dollars in business – you looked the other way when it came to investigating and taking action against radical Islamic front groups which reportedly launder money to fund terrorist operations on American soil.


As a result, and as set forth below, please immediately take appropriate action against the following tax exempt and other organizations. The failure to do so would constitute a gross dereliction of duty as an American, and under your authority as Commissioner of the IRS.





HAMAS is an acronym for the Arabic term for “The Islamic Resistance Movement” – Harakat al Muqawama al Islamiyya.  It is an off-shoot of the Muslim Brotherhood (MB), and has repeatedly engaged in terrorism.  Key U.S.-based leaders of the HAMAS organization, including but not limited to Mousa Abu Marzook[4], Ismail Elbarassee, Nasser Al Khatib and Mohammad Salah[5], established major non-profit organizations such as religious, educational, scientific, literary, and research organizations in the United States from which HAMAS reportedly has organized, recruited, trained and planned terrorist attacks.


Non-profit entities organized under Section 501(c)(3) of the IRS Code have been used to “launder” financial transactions and facilitate the transfer of funds supporting violent terrorist attacks by HAMAS and others.  Some of these non-profit organizations have partnered with “HAMAS controlled” for-profit businesses in elaborate and complicated financial transactions intended to mask the flow of terrorist funds into and out of the United States.  Based on our analysis of publically available documents, and other published reports, it is clear that this U.S.-based network has also provided financial resources for Osama bin Laden and his terrorist operations.



A.  Tax Exempt Organizations That Reportedly “Front” For HAMAS:


1.                  United Association for Studies and Research[6]

5524 Hempstead Way

Springfield, VA 22151

(Office in Chicago, IL)


Comment: United Association for Studies and Research (“UASR”) reportedly serves as the headquarters of the political arm of HAMAS in the United States.  Mousa Abu Marzook served as the UASR “political director.”  Marzook was subsequently deported from the United States to Jordan.


2.                  Islamic Association for Palestine[7]

888 S. Greenville, Suite 307

Richardson, TX 75081

(Offices in Chicago, IL and California)


3.                  North American Islamic Trust[8]

2622 East Main Street

Plainfield, Indiana 46168

(Offices in Pittsburgh, PA and Toledo, OH)


4.                  Islamic Relief Association[9]

1504 B Mount Vernon Ave.Alexandria, VA 22301


5.                  Islamic African Relief Agency[10]

201 E. Cherry, Suite #DColumbia MO 65203


Comment: The Islamic African Relief Agency (“IARA”) reportedly received 2 U.S. State Department grants in 1998 worth $4.2 million dollars.  IARA reportedly transferred money to Mercy International, another non-profit Muslim organization that purchased the vehicles used by Osama bin Laden to bomb the U.S. embassies in both Kenya and Tanzania on August 8, 1998.


6.                  Holy Land Foundation for Relief and Development[11]

(Formerly, the Occupied Land Fund)


Comment: The Holy Land Foundation provides annuities to the families of suicide bombers.  In Israel, the offices were closed down and the organization’s chairman was  arrested and indicted for aiding HAMAS.  Marzook claimed a $210,000 dollar cash donation after establishing the organization.

7.                  Mostan International[12]


8.                  Muslim American Society


9.                  Cultural Society


10.              Muslim Arab Youth Association (MAYA)[13]

2346 S. LynhurstSuite 302Indianapolis IN 46241

(Offices in Royal Oak, MI and Shawnee Mission, KS)


11.              Alaqsa Educational Fund


12.              Council on American Islamic Relations (CAIR)

1301 NW Highway, Ste 212Garland, TX 75041

(Offices in Washington, DC, Southfield MI, Santa Clara, CA, Brooklyn, NY, Columbus, OH)


13.              Islamic Society of North America (ISNA)[14]


14.              Islamic Circle of North America (ICNA)[15]

166-26 89th AvenueJamaica, NY 11432


15.              American Middle Eastern League for Palestine

888 S. Greenville, Ste. 307Richardson TX 75081


16.              Quaranic Literacy Institute (“QLI”)[16]

Oaklawn, IL


Comment: The QLI represents itself as a not-for-profit research institute devoted to the translation of sacred Islamic texts and to scholarly research devoted to such topics.  QLI’s principals included its President, Ahmad Zaki Hameed (“Zaki”), Corporate Secretary and Trustee, Amer Haleem and Treasurer, Abraham Abusharif.


In June and July 1991, QLI reportedly engaged in a for-profit land sale and development project in Woodbridge, Illinois with two firms known as Golden Marble, Inc. and Kadi International (a Saudi firm).  Ultimately, the deal netted QLI at least $600,000 profit, of which not a penny was ever reported to the IRS.  QLI was granted their 501(c)(3) tax-exempt status in March 1992.  QLI reportedly did not file IRS Form 990s for tax years 1991 through 1995.[17]



B.  For-Profit Entities Reportedly Supporting HAMAS:


1.                  BMI, Inc.

Secaucus, NJ


Comment:  BMI was financed by Marzook (a US Designated Terrorist); Yassin Kadi, financier of HAMAS terrorist Mohammad Salah, and two siblings of Osama bin Laden.  BMI has developed property in Indianapolis, IN, Baltimore, MD and other locations.  The development schemes parallel those of QLI and Golden Marble, Inc. (above).


2.                  Kadi International, Inc.


3.                  Golden Marble, Inc.


4.                  Mecca Investment International[18]

1525 Hi Point St #102Los Angeles, CA 90035





On behalf of the American people, Judicial Watch demands that you and the IRS do your duty and investigate and, if necessary, shut down these organizations, before more terrorist incidents occur.


Judicial Watch, and the American people, await your speedy, affirmative response to our complaint.










Larry Klayman                                                 Thomas Fitton

Chairman and General Counsel                                    President




cc:            President George W. Bush

The White House


Honorable John D. Ashcroft

Attorney General of the United States


Honorable Paul O’Neil

Secretary of the Treasury


Michael Chertoff, Esq.

Assistant Attorney General

Criminal Division

U.S. Department of Justice


All Members of Congress

(Senate and House)

[1]Judith Miller, “Some Charities Suspected of Terrorist Role,” The New York Times, Saturday, February 19, 2000, page 5 (Exhibit 1).

[2]John Berlau, “IRS Boss Snagged Clinton Waiver,” Insight Magazine, May 7, 2001.

[3]Judicial Watch does not equate terrorist funded activities with the Arab-American community in general.

[4]Steven Greenhouse, “U.S. Detains Arab Tied To Militants,” The New York Times, Friday, July 28, 1995, page 1 (Exhibit 2).

Charles W. Hall; Robert O’Harrow, Jr., “Virginia Man Suspected of Terrorism Known for Anonymity,” The Washington Post, Tuesday, August 8, 1995, Page B1, (Exhibit 2).

Michael Daly, “Fan of Suicide Bombing,” New York Daily News, Sunday, May 20, 2001, Page 2 (Exhibit 2).

[5]Judith Miller, “Israel Says That a Prisoner’s Tale Links Arabs in U.S. to Terrorism,” The New York Times, Wednesday, February 17, 1993, page 1 (Exhibit 3).

[6]Bank & Lender Liability Litigation Reporter, “Suit Accusing Groups of Funding Terrorism Can Continue,” February 8, 2001, Vol. 6; No. 12; Pg 10 (Exhibit 4).

[7]Steve McGonigle, “Grand Jury Pursues Records; Palestinian Group’s Files Subpoenaed After Raid By Terrorism Task Force,” The Dallas Morning News, Friday, September 7, 2001, Page 33A (Exhibit 5).

Judith Miller, “FBI Searches Internet Concern In Inquiry Into Mideast Terrorism,” The New York Times, Friday, September 7, 2001, page A15 (Exhibit 5).

[8]Agence France Presse, “Chicago-Area Moslem Groups Allegedly Launder Money For Hamas,” September 8, 1998 (Exhibit 6)

Ben Tinsley, “Arlington Islamic Society Leader Temporarily Reinstated,” The Dallas Morning News, Thursday, July 6, 2000, Page 27A (Exhibit 6).

[9]Jacob Dallal, “State Unsure How To Deal With Moslem Charity,” The Jerusalem Post, Friday, August 4, 1995. Page 8 (Exhibit 7).

[10]Judith Miller, “U.S. Contends Muslim Charity Is Tied To Hamas,” The New York Times, Friday, August 25, 2000, page 21 (Exhibit 8).


The Dallas Morning News, “Holy Land Foundation Chronology,”Sunday June 11, 2000, page 10J (Exhibit 9).

Robert Clow, “Citi’s Unholy Mess – Defends Biz With Charity Allegedly Tied To Hamas,” The New York Post, Wednesday, January 24, 2001, Page 36 (Exhibit 9).

[12]Arab Press Service Organization, “HAMAS – Profile – Moussa Mohammed Abu Marzuk,” March 3, 1997, No. 3, Vol. 33. (Exhibit 10).

[13]PR Newswire, “Terrorism Expert Reveals New Bin Laden Connections,” October 30, 1998, (Exhibit 11).

[14]Faisal Kutty, “Algerian Islamist Sheikh Mahfoud Nahna Addresses ISNA Conference,” Canadian Chronicle, as reported in Washington Report on Middle East Affairs, August 31, 1998, Vol.XVII; No. 5; Pg. 75. (Exhibit 12)

[15]Richard Sisk, “Hamas Uses U.S. Fronts To Raise Cash, Sez Freeh,” New York Daily News, March 13, 1996, page 6 (Exhibit 13).

[16]Associated Press, “Feds Seize Assets In Hamas Case,” Wednesday, June 10, 1998 (Exhibit 14).

[17]Judith Miller, “Suit Accuses Islamic Charities of Fund-Raising for Terrorism,” The New York Times, Saturday, May 13, 2000, page 10 (Exhibit 15).

[18]Richard Cole, “Fraud, Drug Trafficking and Charities in U.S. Help Finance Terrorists,” The Associated Press, Monday, May 26, 1997 (Exhibit 16).