Info@ZachorLegal.

org

July 17, 2023

Patrick Collison
Chief Executive Officer
Stripe, Inc.
354 Oyster Point Blvd.
South San Francisco, California
94080

Via USPS and email (Complaints@Stripe.com)

Dear Mr. Collison:

On behalf of Zachor Legal Institute, the undersigned respectfully asks Stripe, Inc.
(“Stripe”) to investigate the account of an organization known as The Alliance for Global Justice
("AFGJ"), a Tucson, Arizona, based organization, that uses your services to process donations
for the benefit a United States’ designated terrorist organization.

By way of background, Zachor Legal Institute has been active in legal issues relating to
civil liberties and the Constitution and has an active United States Supreme Court practice. The
founder of Zachor Legal Institute is the author of a number of legal papers analyzing
constitutional issues with an emphasis on terror financing, anti-discrimination laws and the First
Amendment.

After significant research, we have found that AFGJ is providing fiscal sponsorship and
payment services through its platform to an organization designated as a terrorist group by the
name of Samidoun. We have recently learned that AFGJ is now processing donations by using
Stripe’s services.

While we understand that your company is required by various laws to know your
customers, the fact that you are doing business with an organization that provides funding for a
designated terror group indicates that AFGJ may have slipped through your compliance reviews.
By providing the payment services to Samidoun, we believe that AFGJ, and its providers such as
Stripe, are enabling the transfer of funds to an organization involved in terrorist activity in
violation of federal law.

Specifically, we would like to refer your attention to the following:

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• Samidoun is a North American-based non-governmental organization which has
significant ties with the Popular Front for the Liberation of Palestine (PFLP), a
designated terrorist organization in the US as well as additional countries in the
world;
• Recently Samidoun was designated as a terrorist organization by Israel;
• Much of Samidoun’s leadership overlaps with members of the PFLP, with a
number of Samidoun leaders being senior members of the PFLP and even
members of the PFLP Central Committee;
• The chief coordinator of Samidoun is Khaled Barakat. Barakat is a senior member
of PFLP, and in the past served as the head of PFLP abroad;
• Additional members of Samidoun include the following terror-related individuals:
o Charlotte Kates – International coordinator of Samidoun. Wife of Khaled
Barakat;
o Mohammed Khatib – PFLP activist in Belgium. Samidoun coordinator in
Europe;
o Mustapha Awad – PFLP activist in Belgium. He was imprisoned in Israel,
after he was sent by the PFLP to Lebanon, where he underwent military
training by Hezbollah. Afterwards, he arrived in Israel to promote the
activities of Samidoun. Currently, he is still an activist of the PFLP in
Belgium;
o Maram Saadi – Samidoun coordinator in Lebanon. Associated with the
PFLP and Hezbollah; and
• Samidoun runs campaigns that support and/or glorify convicted terrorists and the
PFLP campaign website uses elements identical to those on the Samidoun
website.

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 In light of the above, it is clear that Samidoun is an alter ego of the designated terror
organization PFLP.1 Further, based on our research, we believe that donations made to
Samidoun by using the AFGJ platform have provided support to, and if allowed to continue to
use your services will continue to support, designated terror organizations and specific terrorist
activities throughout the world. As such, AFGJ, as the fiscal sponsor of Samidoun, appears to be
providing material support to terror in violation of 18 U.S.C. § 2339A and B as well as support
for international terrorism in violation of the criminal and civil provisions of the United States’
Anti-Terrorism Act (18 U.S.C. § 2331 et seq.).

As Stripe’s own policies provide, Stripe users may not use Stripe’s services to engage in
a number of activities, including the provision of funding for terrorism.2

We draw your attention to the provisions of the Justice Against Sponsors of Terrorism
Act, which provides for civil aiding and abetting liability in relation to any financial services
company that knowingly provides support, such as payment processing services, to an entity
known to be connected to a designated terror organization. Our most recent law review article
explains why it is important for you to not provide support to those aiding and abetting terror
organizations.3

Other companies that have previously enabled AFGJ’s funding of Samidoun have
terminated their relationships with AFGJ upon being informed of the illicit use of their
platforms, such as Mastercard, Visa and American Express, as well as PayPal, Donorbox, Plaid
and Discover. In the past months, virtually every other financial services company that AFGJ has
used have also terminated their provision of services to AFGJ after the Washington Examiner
published an expose on AFGJ’s unlawful support of terror organizations.4 At the time of that
story, Zachor also submitted complaints to both the Internal Revenue Service and the
Department of Treasury’s Office of Foreign Assets Control, informing them that by virtue of the
fact that AFGJ is providing funding for United States’ designated foreign terror organizations, it

1
Further details on the connection between Samidoun and the PFLP can be found in the brief we filed in district
court in Arizona, available at https://zachorlegal.org/wp-content/uploads/2018/02/Zachor-Legal-Institutes-Amicus-
Brief-Filed-in-support-of-Arizona-HB-2617.pdf?189db0&189db0.
2
Stripe’s policies prohibit the use of Stripe’s services in support of “…individuals or entities named to a restricted
person or party list of the U.S., United Kingdom, European Union or United Nations, including the sanctions lists
maintained by the U.S. Office of Foreign Assets Control or the Denied Persons List or Entity List maintained by the
U.S. Department of Commerce…” and “[a]ny business or organization that a. engages in, encourages, promotes or
celebrates unlawful violence or physical harm to persons or property, or b. engages in, encourages, promotes or
celebrates unlawful violence toward any group based on race, religion, disability, gender, sexual orientation,
national origin, or any other immutable characteristic.” https://stripe.com/legal/restricted-businesses#restricted-
businesses. Samidoun’s activities clearly violate these rules.
3
https://papers.ssrn.com/abstract=4377025, Volume 43 of the Review of Banking and Financial Law (forthcoming
Spring 2024).
4
See https://www.msn.com/en-us/news/technology/major-left-wing-charity-unable-to-process-credit-card-
donations-following-washington-examiner-report/ar-AA17x7s4,
https://www.washingtonexaminer.com/news/alliance-for-global-justice-nonprofits-complaint-collectif-palestine-
vaincra and https://www.washingtonexaminer.com/policy/foreign/liberal-charity-fundraising-palestinian-terror-
group-illegal.

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(and those who facilitate its activities) is in violation of applicable federal laws prohibiting
support of terrorism.

The Washington Examiner just published a new story on AFGJ’s terror support, naming
Stripe as the new funding processing for AFGJ.5 This news story quotes a number of members
of Congress, including Representative Elise Stefanik, who stated, with regard to Stripe’s
provision of services in support of terror, "American companies should not be providing services
to any entity that actively fundraises for Palestinian terrorist organizations or promotes anti-
Semitism." Another member of Congress, Representative Mike Lawler, a member of the House
Foreign Affairs Committee, stated "The Alliance for Global Justice was rightly stripped of its
ability to process credit card donations because of this unholy alliance and credit card companies
severed their ties to the organization. For Stripe to give them a lifeline and allow them to again
process transactions is deeply concerning."

Since AFGJ uses your services to process donations in support of Samidoun, a PFLP
affiliate, we strongly urge you to take this information into consideration when reviewing its
account for compliance with your rules and laws applicable to your company. We also want to
notify you that we will be in contact with relevant federal agencies, including the Internal
Revenue Service and the Treasury’s Office of Foreign Assets Control, to inform them that Stripe
is now processing payments that fund foreign terror organizations.

Please contact me at marc@ZachorLegal.org or 925-328-0128 should you have any

questions.

Sincerely,

Marc Greendorfer

5
https://www.washingtonexaminer.com/news/stripe-payment-processor-palestinian-terror-linked-alliance-for-
global-justice-israel.

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