Financial Infrastructure & Legal Obstruction: How the Network Funds and Defends Itself

Key Judgments

• [CONFIRMED] – Despite a public CAIR website statement claiming the organization “does not receive funding from foreign organizations or governments,” Middle East Forum research based on public filings documents CAIR benefiting from at least $7.7 million tied to the Saudi-based Islamic Development Bank, including a $30 million CAIR Plaza project the bank helped finance beginning in 2013.
• [CONFIRMED] – Despite the FBI’s 2009 formal suspension of liaison relationships with CAIR following the Holy Land Foundation trial, multiple federal and state agencies have continued directing public funds to CAIR and Brotherhood-linked affiliates in the years since: a $100,000 DHS Nonprofit Security Grant to CAIR and a separate $100,000 DHS grant to Dar al-Hijrah; over $15 million in HHS Office of Refugee Resettlement funds routed to CAIR-California since 2022 for Afghan resettlement work; $10.6 million in HHS funding to ICNA Relief; $90,000 to a MAS Sacramento chapter; and $340,000 in HHS sub-grants to Dar al-Hijrah for COVID-19 vaccine outreach.
• [CONFIRMED] – A Department of Justice investigation found suspected misuse of federal grant funds by CAIR-California, including redirection of $3.6 million in Afghan Legal Services Project funds back to CAIR’s own Los Angeles office and non-independent chapters, and inconsistent grant-related entity reporting on IRS Form 990 filings. Rep. Chip Roy formally requested HHS suspend and debar CAIR from federal programs in April 2026; separate legislation, the “Designating Hamas Affiliates in America Act of 2026,” was introduced the same month.
• [CONFIRMED] – In late 2025, Texas and Florida became the first US states to formally designate CAIR a terrorist organization at the state level (Texas, November 18, 2025; Florida via Executive Order 25-244, December 8, 2025). CAIR and CAIR-Florida, joined by the Southern Poverty Law Center, sued to block the Florida order on First Amendment, Supremacy Clause, and due process grounds; a federal judge blocked enforcement of the order pending litigation.
• [CONFIRMED] – Within weeks of the Florida designation, CAIR’s own headquarters building in Washington, DC moved through two newly created shell nonprofits – Sage Foundation and the renamed Washington Trust Foundation – culminating in a February 13, 2026 deed transferring a 45% ownership stake in the property to the North American Islamic Trust (NAIT), a HLF trial unindicted co-conspirator, for $4,000,000. No public announcement of the transaction appears on CAIR’s website or donor communications as of this writing.

The Foreign Funding Question

CAIR’s public messaging has for years included direct denials of foreign financial support – one representative claim, still posted, reads: “CAIR does not receive funding from foreign organizations or governments.” Public records reviewed by the Middle East Forum tell a different story: at least $7.7 million connected to the Saudi-headquartered Islamic Development Bank (ISDB), including support for a $30 million headquarters project (“CAIR Plaza”) the bank began financing in 2013. This is not, on its own, evidence of a Hamas-support relationship – the ISDB is a formal multilateral development institution, not a designated terrorist entity.

• [ASSESSED] – CommandEleven assesses the significance lies less in the funding’s origin and more in the documented gap between the funding’s existence and CAIR’s own public statements denying it – a credibility pattern relevant to every other CAIR public statement examined across this series, including its characterization of the HLF trial record addressed in Part I.

Public Money, Private Network

The more consequential financial story is domestic. Since the FBI’s 2009 decision to suspend all liaison and outreach relationships with CAIR – a decision reaffirmed in writing to Congress and never formally reversed – a separate arm of the federal government has continued funding the same network:

• DHS Nonprofit Security Grant Program: $100,000 to CAIR directly, and a separate $100,000 to Dar al-Hijrah, both flagged in contemporaneous reporting as inconsistent with the FBI’s own standing guidance.
• HHS/Office of Refugee Resettlement: More than $15 million sub-granted to CAIR-California through the California Department of Social Services since 2022, primarily for Afghan resettlement programming, including $7.2 million specifically for the Afghan Legal Services Project.
• ICNA Relief (the humanitarian arm of the Islamic Circle of North America): $10.6 million in HHS funding.
• Muslim American Society, Sacramento chapter: $90,000 for a women’s health literacy program – notable given that a federal appeals court record, per Part I of this series, has described MAS as the Brotherhood’s overt American arm.
• Dar al-Hijrah: $340,000 in HHS sub-grants for COVID-19 vaccine outreach, separate from the DHS security grant above.

• [DATA DEFICIT] – This dossier does not assert that any individual grant recipient misused funds for purposes connected to the organizational history examined in Parts I and II. The pattern documented here is one of continued federal and state funding eligibility despite the FBI’s standing non-liaison policy – a governance and oversight question distinct from, though related to, the network’s historical conduct.

When Oversight Finds Something

The California case moved beyond pattern into documented misconduct. A Department of Justice investigation identified suspected misuse of federal grant funds by CAIR-California, including a reported diversion of $3.6 million in Afghan Legal Services Project funding back into CAIR’s own Los Angeles office and non-independent chapters – a structure investigators characterized as raising self-dealing and conflict-of-interest concerns – alongside inconsistent entity naming across grant applications and IRS Form 990 filings that reported far less government funding than records show was actually received.

That finding produced a direct congressional response. In April 2026, Rep. Chip Roy formally asked HHS Secretary Robert F. Kennedy Jr. to suspend CAIR’s federal funding and initiate debarment proceedings, and separately introduced the Designating Hamas Affiliates in America Act of 2026, which would designate CAIR a Specially Designated Global Terrorist entity and revoke its 501(c)(3) status. As of this writing, neither the debarment request nor the legislation has been finalized.

The State Designation Wave and CAIR’s Legal Response

Texas designated CAIR a terrorist organization by state proclamation on November 18, 2025; Florida followed on December 8, 2025, via Executive Order 25-244, directing state agencies to bar CAIR from state funding, contracts, and employment. CAIR and CAIR-Florida, joined by the Southern Poverty Law Center, sued in the Northern District of Florida, arguing the order violates the First Amendment, the Supremacy Clause (on grounds that terrorism designation is a federal, not state, power), and due process. A federal judge blocked enforcement pending the litigation’s outcome – meaning the Florida designation remains legally contested rather than settled, a distinction this series treats carefully rather than presenting the designation as final law.

The Headquarters Transfer

Part I of this series introduced the core sequence; this section examines it in full. On December 23, 2025 – two weeks after Florida’s designation – the Washington Trust Foundation (CAIR’s own renamed original 1994 corporate entity) deeded CAIR’s Washington, DC headquarters building to Sage Foundation, a nonprofit incorporated just eight months earlier by CAIR Foundation treasurer Eyas Abdeen, with CAIR General Counsel Lena Masri as registered agent. Sage held the property for seven weeks. On February 13, 2026, Sage executed a deed transferring an undivided 45% interest in the building to NAIT – the same organization named on the 1988 Chart and 1991 Explanatory Memorandum examined in Part I, and identified as an unindicted co-conspirator/joint venturer at the HLF trial – for $4,000,000, retaining the remaining 55% itself. Sage Foundation’s DC corporate registration status is listed as “Active, Not in Good Standing” for a missed biennial report as of this writing. No announcement of either transaction appears in CAIR’s public communications or donor materials.

• [ASSESSED] – CommandEleven assesses the timing sequence – a major asset transfer beginning within days of a state terrorism designation, executed through two newly formed shell entities controlled by the same small set of CAIR officers – is more consistent with a deliberate asset-protection strategy than coincidence, though this dossier does not have direct evidence of CAIR’s internal deliberations or intent, and presents this as analytical judgment rather than a legal finding.

Series Continuity

Part IV turns to the institutional capture question this financial architecture ultimately serves: mosque networks, K-12 and university-level activity, and the political access the preceding three parts of this series have made possible – including the January 2026 federal FTO/SDGT designations of the Lebanese, Egyptian, and Jordanian Muslim Brotherhood chapters, and documented US political connections.

Sourcing Base (Confidence-Tiered, with Links)

CONFIRMED – Primary Record, Government Filings & Reporting:

• Lara L. Burns, Written Testimony, US Senate Committee on the Judiciary, Aug. 5, 2026 (CAIR/NAIT headquarters transfer, full deed and corporate-filing detail)
• Middle East Forum, “Revealed: CAIR’s $7.7 Million of Foreign Financing“
• Just The News, “Two federal agencies routed taxpayer dollars to terror-linked charities, new reports find“
• Rep. Chip Roy, “Rep. Roy Asks Health and Human Services to Suspend Funding for CAIR,” press release, April 2026
• LegalClarity, “CAIR: Civil Rights Work, Terror Designations, and FBI Ties” (Florida EO 25-244 and litigation status)
• Florida Phoenix, “Federal Judge Blocks DeSantis Executive Order Declaring CAIR a Terrorist Organization”

ASSESSED – Credible Secondary Reporting:

• RAIR Foundation, “BREAKING EXCLUSIVE: CAIR–California Exposed for $27 Million in Taxpayer-Funded Abuse“
• RAIR Foundation, “Defund CAIR NOW: Rep. Chip Roy Demands RFK Jr. Immediately Debar the Hamas-Linked Terror Front“
• The Investigative Project on Terrorism, “Government Continues Turning a Blind Eye to Radical Islamist Grant Recipients” (2010-era DHS grant history, background context)
• CAIR-California, “FAQ: CAIR-CA Grant Funding” (CAIR’s own public response)

Excluded from this dossier: Any characterization of the DOJ’s CAIR-California grant investigation as concluded or adjudicated. As of this writing, the investigation and related congressional requests are active and unresolved; this dossier treats them as such rather than presenting a finding of guilt.

The Muslim Brotherhood Series

• The Conspiracy Documented – Origins of the Muslim Brotherhood’s American Front
• The Affiliate Network – Dar al-Hijrah, CAIR, and the American Brotherhood’s Web
• Financial Infrastructure & Legal Obstruction – How the Network Funds and Defends Itself
• Institutional Capture – Mosques, Classrooms, Campuses, and Congress
• What Four Decades of Evidence Adds Up To