Ammon Blair’s Testimony Before the Texas House Committee on Homeland Security, Public Safety & Veterans’ Affairs

Testimony of Ammon Blair
Senior Fellow, secure and Sovereign Nation
Texas Public Policy Foundation

Chairman Hefner, Vice Chairman Lopez, and distinguished members of the Committee:

Thank you for the opportunity to testify. My name is Ammon Blair. I am a Senior Fellow with the Texas Public Policy Foundation. I served twenty-two years in the United States Army and more than a decade as a United States Border Patrol Agent in the Rio Grande Valley Sector. My work has focused on cartels, transnational criminal organizations, terrorist-support networks, and foreign influence operations affecting Texas.

Foreign adversary influence is not a prospective threat to Texas. Foreign governments and terrorist organizations have already used Texas as a target, an operating environment, a source of financing, and a platform for political and institutional activity.

These threats do not operate in isolation. Foreign governments, terrorist organizations, cartels, criminal facilitators, and domestic intermediaries exploit many of the same vulnerabilities: an unsecured border, untracked movement, hidden financing, false identities, commercial access, institutional relationships, and weak disclosure requirements. The border provides an entry point, but the threat does not end there. Once people, money, influence, or operational capability enter Texas, established criminal and institutional networks can move them into the interior, conceal their origins, and convert them into enduring access, influence, and operational reach.

The first layer of that system is the Mexican cartel infrastructure operating immediately across and within Texas.

From the Mexican Cartel System to the Interior Threat

Mexican cartels maintain an established cross-border logistics system consisting of guides, scouts, drivers, stash houses, fraudulent documents, financial facilitators, transportation networks, and interior receiving cells. The same infrastructure supports the movement of people, narcotics, weapons, bulk cash, and other contraband from Mexican plazas into Texas and onward to major interior markets.

From fiscal years 2021 through 2024, CBP recorded more than 8.7 million southwest-border encounters, while approximately two million known gotaways evaded apprehension (House Committee on Homeland Security, 2024). By February 26, 2026, ICE’s non-detained docket had reached approximately 7.3 million people, including roughly 1.6 million with final orders of removal (Kandel & Singer, 2026).

These figures demonstrate that the number of people subject to immigration screening, supervision, adjudication, or removal exceeds the federal government’s operational capacity. The resulting gaps in identity verification, custody, location information, and enforcement have enlarged the operating space available to cartels, traffickers, hostile state actors, and terrorist-linked networks.

The relevant threat to Texas therefore extends beyond unlawful entry at the border. It includes the interior infrastructure, unresolved identities, coercive relationships, financial channels, and criminal support networks that remain after individuals disperse into American communities.

Cartel control over transportation, debt, documents, housing, or employment can continue after entry and can be used to compel labor, silence, transportation, or participation in criminal activity. Smuggling organizations frequently require only partial payment of fees upfront, leaving migrants with substantial remaining debt that is enforced through threats against family members still in their home countries. Once inside the United States, these networks retain leverage by controlling housing arrangements, confiscating

identity and immigration documents, directing employment, and monitoring compliance. This post-entry control is routinely used to extract forced labor, compel silence, facilitate further movement of people or contraband, and coerce participation in other criminal activity (U.S. Department of Homeland Security, 2025; U.S. Department of State, 2025; U.S. Department of Justice, 2026c).

This is the point at which illegal migration becomes an interior-security and foreign-threat issue. The question before Texas is whether state and local institutions can identify, report, and disrupt hostile or criminal activity when the federal immigration system cannot provide reliable visibility, custody, or enforcement at the scale required.

That is the interior threat Texas must now confront.

Weaponized Mass Migration and the Loss of Operational Control

Weaponized mass migration occurs when state or non-state actors deliberately generate, direct, facilitate, or exploit large population flows to overwhelm institutional capacity, create strategic leverage, or gain access to a target country (Petty, 2022; Greenhill, 2010).

The threat arises when migration volume exceeds the government’s ability to establish identity, screen for criminal and national-security risk, adjudicate claims, maintain custody, track location, enforce immigration law, and execute removal orders.

Along the border, cartel-controlled corridors and undetected crossings provide access without reliable screening or record creation. During processing, mass release, parole, and multiyear asylum backlogs allow individuals to disperse before identity, eligibility, and risk are fully resolved. Inside the country, visa overstays, sanctuary restrictions, weak worksite enforcement, organized onward transportation, and fragmented government databases make unlawful presence easier to sustain and enforcement more difficult to execute (U.S. Citizenship and Immigration Services, 2026; DHS OIG, 2024b; DHS OIG, 2024c).

Together, these conditions convert migration from a point-in-time border event into a durable interior-access system. Individuals can enter or evade detection, disperse throughout the country, obtain transportation, housing, and employment, and remain for years while the government loses reliable visibility over identity, location, legal status, and foreign or criminal affiliations.

That operating environment is available for exploitation by transnational criminal organizations, foreign intelligence services, terrorist-linked facilitators, and hostile states seeking access, concealment, movement, finance, recruitment, or placement inside the United States.

The issue is therefore larger than how many people crossed the border. The governing question is whether the federal government retained identity, custody, location, and control after entry (DHS OIG, 2025a).

Foreign Adversaries and Terrorist-Linked Networks Exploit the Interior Access System

Once migration volume exceeds the government’s capacity to verify identity, preserve custody, track location, and enforce final decisions, the resulting system becomes available to actors seeking access and concealment inside the United States.

Mexican cartels provide much of the physical infrastructure: controlled corridors, guides, fraudulent documents, stash houses, transportation, debt collection, financial channels, and interior receiving networks. Federal processing and release then move people beyond the border. Weak interior

enforcement, fragmented databases, employment, housing, and prolonged adjudication allow individuals to remain and disperse.

Foreign adversaries and terrorist-linked organizations do not need to create a separate pathway into the country. They can exploit this existing system to move personnel, conceal affiliations, transfer money, establish relationships, recruit supporters, collect intelligence, or position operatives inside American communities (U.S. Department of Homeland Security, 2024).

The next question is therefore evidentiary: Which foreign threat networks have exploited American access, immigration, settlement, and institutional systems, and what does their conduct require Texas to identify, report, prohibit, or disrupt?

Screening and Identity Failures: Releasing Risk Before Resolving It

The federal government did not lose visibility only because millions of people crossed the border. It lost visibility because volume changed the operating standard from verifying identity and risk before release to attempting to resolve both after individuals had dispersed into the country (DHS OIG, 2024b).

Identity verification requires more than recording a name, nationality, and date of birth supplied by the person being processed. It requires reliable documents, biometrics, intelligence queries, foreign records, effective interviews, database access, and the resolution of conflicting information before custody ends. During the migration surge, federal audits found failures at each of those points (DHS OIG, 2024a).

In 2023, the DHS inspector general examined the release of one illegal alien whose initial screening produced an inconclusive Terrorist Screening Dataset match. CBP sent an interview request to the wrong email address, obtained information sought by the FBI’s Terrorist Screening Center but failed to transmit it, and released the individual before fully coordinating with the Center. ICE then faced additional information sharing problems while planning the arrest. The case did not involve an unknown threat that escaped every screen. The system generated the warning and then failed to act on it before release (DHS OIG, 2023).

That case was not isolated. A 2024 House Judiciary Committee interim staff report, citing information supplied by DHS, found that Border Patrol encountered more than 250 individuals whose records matched the terrorist watchlist at the southwest border during fiscal years 2021 through 2023. DHS released at least 99 of them into the United States, while at least 34 others remained in DHS custody without having been removed. The report identified watchlist encounters involving foreign nationals of 36 countries (U.S. House Committee on the Judiciary, 2024).

A watchlist match does not establish that every person is a terrorist operative. It establishes that the federal screening system identified a national-security concern requiring resolution. Releasing the person before resolving that concern transfers the risk from a controlled border environment into the interior.

The same breakdown affected the identification of special-interest aliens—foreign nationals whose travel patterns, origin, associations, or other circumstances require enhanced examination because of possible national-security concerns. In 2025, the DHS inspector general found that CBP lacked an agency-wide policy governing their identification and screening. The San Diego Field Office and Border Patrol’s Yuma and El Centro sectors had procedures for identifying and providing additional screening, while the San Diego sector did not. As a result, foreign nationals from countries associated with terrorism entered through at least one region without the additional screening applied elsewhere (DHS OIG, 2025b).

The problem was therefore not only insufficient information. It was inconsistent use of the information available. The level of scrutiny depended in part on where the person was encountered and which local process applied.

The processing of Chinese nationals provides another example of volume displacing examination. The House Committee on Homeland Security reported that in April 2023 DHS reduced the interview protocol for Chinese nationals from approximately 40 questions to five in order to accelerate processing. The five retained questions addressed military service, university affiliation, place of birth, employment, and political-party membership—the subjects most likely to reveal connections to the Chinese Communist Party, People’s Liberation Army, state institutions, or intelligence activity. Border Patrol leadership warned the Committee that language barriers and abbreviated interviews increased the risk that an entrant’s ideology, affiliations, and purpose would be missed (U.S. House Committee on Homeland Security, 2024).

Reducing the interview protocol from roughly forty questions to five did not mean every Chinese national posed a threat. It meant the government chose to conduct less rigorous examination of nationals from its principal strategic adversary precisely when those encounters were rising sharply — and while the Chinese Communist Party was expanding espionage, intellectual-property theft, and transnational repression operations on U.S. soil (House Committee on Homeland Security, 2025).

DHS’s own audits identify broader technological and procedural weaknesses. In 2024, the inspector general found that DHS technology, procedures, and coordination were not fully effective for screening asylum seekers and noncitizens seeking admission. CBP could not access all federal data necessary for complete screening, used varied and inconsistent inspection procedures at land ports, and lacked the technology to perform biometric matching on travelers arriving in vehicle lanes. The inspector general also recommended continuous rescreening of asylum applicants whose cases remained pending beyond 180 days so that derogatory information discovered after initial processing would trigger action (DHS OIG, 2024b).

That finding exposes a second failure. Screening was often treated as a single event rather than a continuing security obligation. An individual could clear an initial check, remain in the country for years while a claim was pending, and never receive meaningful rescreening as new intelligence, criminal information, aliases, travel records, or foreign-government associations emerged.

Document and relationship verification suffered similar weaknesses. The DHS inspector general found that CBP conducted only 314 familial DNA tests from September 2021 through September 2024, despite approximately 2.7 million foreign nationals crossing while claiming membership in a family unit. That represented testing of roughly 0.01 percent of the population. More than 14 percent of the limited tests administered found no biological relationship, yet CBP did not substantially expand testing (DHS OIG, 2025c).

The significance extends beyond immigration fraud. A false family relationship can conceal child smuggling, trafficking, repeated recycling of minors, fraudulent identity claims, or coercive control. When the government accepts the claimed relationship without effective verification, it creates an identity record based on the smuggler’s narrative.

DHS also concluded in 2024 that CBP, ICE, and TSA had not fully assessed the risks associated with releasing noncitizens who lacked identification and then allowing them to travel on domestic aircraft. An individual released without reliable identification does not become better identified when issued a federal

processing document based substantially on self-reported information. The government has created a record, but it has not necessarily established the person’s true identity (DHS OIG, 2024c).

These findings establish a systemic failure. Federal agencies released or admitted foreign nationals before resolving watchlist matches, applied different national-security screening standards in different locations, reduced interviews to accelerate processing, lacked access to complete federal data, could not perform biometric matching in important land-port environments, rarely tested claimed family relationships, and failed to rescreen long-pending cases consistently.

That system repeatedly transferred unresolved identity and security risk into the interior and the consequences fall directly on Texas. Once a foreign national is released, evades apprehension, overstays a visa, or remains for years during adjudication, the next meaningful government encounter is often a traffic stop, arrest, jail booking, licensing application, employment check, fraud investigation, protective-services case, or contact with a state-regulated institution.

Texas cannot repair every federal screening failure at the border. It can refuse to preserve those failures inside the state.

A federal processing record is not proof of identity, and release is not proof that risk was resolved. The cases that follow show why that distinction matters. Foreign adversaries and terrorist-linked networks exploit the space between the identity a person claims, the affiliations the government can prove, and the activity that state and local institutions are able to see.

Iran and Hezbollah: The Blueprint for Long-Term Foreign-Threat Infrastructure

Iran’s activity in the Western Hemisphere did not begin with the 2026 Kata’ib Hizballah terrorism charges or recent Hezbollah-financing cases (U.S. Department of Justice, 2026b; Burman, 2026). It began as a deliberate strategic project after the 1979 Iranian Revolution (U.S. House Committee on Homeland Security, 2013).

Iran has waged a decades-long asymmetric war against the United States and the broader West since 1979 — through terrorism, proxy warfare, illicit finance, cyber operations, criminal convergence, and gray-zone warfare deliberately designed to remain below the threshold of conventional conflict (Eisenstadt, 2020; Gilmore, 2018; U.S. Department of the Treasury, 2026).

A 1980 U.S. intelligence assessment concluded that Iran’s new leaders were ideologically committed to exporting their revolution and building foreign constituencies capable of advancing Iranian objectives outside conventional diplomatic and military channels (Central Intelligence Agency, 1980). Argentine prosecutor Alberto Nisman later documented the Western Hemisphere component of that strategy in a 2013 judicial filing. He described a systematic Iranian program to establish clandestine intelligence stations capable of promoting, financing, preparing, and supporting terrorist activity throughout Latin America (Montaruli, 2021).

The indictment’s importance lies in the architecture it documented and the later judicial rulings, federal cases, and sanctions actions that corroborated central parts of the model.

The clearest early example was Mohsen Rabbani. He arrived in Buenos Aires in 1983 on a tourist visa, later obtained residency, and developed a dual role as an Iranian commercial representative and an imam. The commercial role provided legitimate cover for travel, financial activity, and government contacts. The

religious and cultural role provided access for recruitment, relationship-building, and ideological development (Barnett, 2013).

The indictment described a segmented structure: visible diplomatic, religious, cultural, and commercial institutions operated above the surface, while selected channels beneath them supplied protection, communications, financing, intelligence, recruitment, and operational support.

This dual-use model is the essential blueprint. An embassy, mosque, cultural center, charity, or business is not itself a threat. The threat arises when Iran covertly directs, finances, tasks, or uses a particular institution or individual for intelligence collection, recruitment, sanctions evasion, terrorist support, or operational preparation.

The Tri-Border Region—where Argentina, Brazil, and Paraguay meet—became a principal financial and logistical hub. Legitimate trade, illicit commerce, criminal services, diaspora relationships, cross-border mobility, and weak enforcement operated in the same environment. Treasury later designated individuals, companies, and financial networks in the region for providing money and logistical support to Hezbollah (U.S. Department of the Treasury, 2006).

The operational result was the July 18, 1994 bombing of the Argentine Israelite Mutual Association in Buenos Aires, which killed 85 people and wounded hundreds. In 2024, Argentina’s Federal Criminal Cassation Court, the country’s highest federal criminal appellate court, concluded that Iran sponsored and directed the attack and that Hezbollah executed it. The court classified the bombing as a crime against humanity (Oyelakin, 2023).

The attack was not improvisation. It required long-term access, intelligence collection, local relationships, target development, protected communications, logistics, financing, and layers of separation between Tehran and the final perpetrators.

Later federal actions further corroborated the architecture. The Department of Justice charged Hezbollah operative Samuel Salman El Reda with assisting the AMIA operation and later recruiting and managing operatives internationally (U.S. Department of Justice, 2023). Treasury identified Amer Mohamed Akil Rada as a senior Hezbollah operative associated with the attack and reported that his network used commercial enterprises to generate revenue and sustain Hezbollah activity across South America and Lebanon (U.S. Department of the Treasury, 2023).

The same model remains active today. In May 2026, federal prosecutors charged—and later indicted—Mohammad Baqer Saad Dawood Al-Saadi, a senior Kata’ib Hizballah and IRGC operative, with terrorism-related offenses involving nearly twenty attacks and attempted attacks across Europe and the United States. Prosecutors allege that the attacks were conducted under the name Harakat Ashab al-Yamin al-Islamiya, a purportedly independent organization that was actually a front for Kata’ib Hizballah and related terrorist organizations (U.S. Department of Justice, 2026b).

A separate 2026 Western District of Texas indictment charged Iranian national Jafar Tafakori with coordinating the smuggling of primarily Iranian nationals through South and Central America and Mexico into the United States (U.S. Department of Justice, 2026a). Taken together, the Al-Saadi and Tafakori cases expose two related vulnerabilities: Iranian-backed actors’ continued use of fronts and intermediaries to obscure attribution, and access to Mexican cartel controlled illicit corridors capable of moving Iranian nationals through Venezuela, Central and South America, and Mexico into the United States. Their convergence creates a hybrid threat environment (Rios Maya, 2021). Iranian networks have previously

been financially linked to these same cartel systems, as documented in the 2012 HSBC investigation and related Senate findings (U.S. Department of Justice, 2012).

Texas Commercial Channels and Iranian Sanctions Evasion

The Iranian threat has already intersected directly with Texas commerce.

Zhenyu “Bill” Wang of Dallas and Daniel Ray Lane of McKinney were convicted at trial and sentenced to 45 months in prison for attempting to purchase sanctioned Iranian petroleum, conceal its origin, sell it to buyers in China, and launder the proceeds (U.S. Attorney’s Office, Eastern District of Pennsylvania, 2024).

The conspirators planned an initial shipment of 500,000 barrels and intended to increase the volume to one or two million barrels per month. They sought foreign passports, offshore accounts, sham contracts, shell entities, disguised ownership, and an initial $5 million payment that included $4 million in cash. Lane offered to use mineral-rights transactions through his business to conceal Iranian profits. Wang arranged Chinese buyers and bribe payments to Chinese officials.

Texas energy expertise, companies, mineral interests, financial relationships, and international commercial access can be converted into sanctions-evasion capabilities. The defendants did not need ideological loyalty to Iran. Profit supplied the motivation. Their proposed service would nevertheless have generated revenue for a hostile foreign state while defeating national security sanctions.

This is why foreign threat policy cannot focus only on declared agents, diplomats, ideological supporters, or nonprofit organizations. Commercial actors pursuing personal profit can provide the same access, concealment, financing, and sanctions-evasion services.

What the record establishes is a durable architecture: ideology produces recruitment; recruitment produces access and intelligence; intelligence enables logistics and target development; and established infrastructure can then be activated for terrorism. Iran supplies direction, state resources, and deniability. Hezbollah and locally positioned facilitators supply execution. Hostile-state actors and terrorist proxies can exploit the same types of smuggling corridors, corrupt intermediaries, and illicit logistical systems used by cartels and transnational organized crime.

Texas should not expect a single organization to announce itself as an Iranian intelligence station or Hezbollah support cell. The historical model shows that the threat is more likely to appear as a network of apparently separate actors connected through foreign direction, financing, beneficial ownership, tasking, travel, commercial activity, protected communications, recruitment, and concealed support.

The state must therefore evaluate networks, not labels. It must distinguish protected religious, cultural, charitable, political, and commercial activity from conduct knowingly directed, financed, or controlled by Iran, the Islamic Revolutionary Guard Corps, Hezbollah, a sanctioned entity, or an undisclosed intermediary.

Entities seeking sensitive contracts, grants, licenses, infrastructure access, charitable privileges, money-services authority, university partnerships, or protected information should be screened against federal terrorism and sanctions records. Where risk indicators exist, Texas should identify beneficial owners, controlling persons, related companies, foreign financing, intermediaries, and ultimate beneficiaries rather than relying only on the legal name appearing on an application.

Screening failures create opportunities. Iran and Hezbollah show how a capable foreign-threat system converts that opportunity into intelligence collection, terrorist financing, sanctions evasion, target development, political violence, and operations inside the United States.

Institutional Network Strategy

Iran and Hezbollah built clandestine infrastructure through state direction and proxy organizations. The Muslim Brotherhood developed a different model: a distributed institutional network that separates fundraising, political influence, communications, research, education, community activity, organizational security, and legal protection among outwardly independent entities (ISGAP, 2025).

The Brotherhood described that strategy in its own internal documents (Akram, 1991). Its 1991 Explanatory Memorandum defined the North American objective as establishing “an effective and a stable Islamic Movement led by the Muslim Brotherhood.” It called the movement’s work in America a “Civilization-Jihadist Process” and instructed that its work constituted “a kind of grand jihad in eliminating and destroying the Western civilization from within.”

The memorandum placed Islamic centers at the center of the architecture, describing them as the movement’s “axis,” “base,” and institutional platform. It envisioned twelve mutually reinforcing functions: da’wa and education; political activity; media and communications; economic and financial activity; scientific, educational, and professional activity; cultural and intellectual activity; social and charitable work; youth activity; women’s organizations; administration and coordination; security; and legal and judicial activity. The centers would educate members, develop personnel, publish materials, organize families and youth, conduct political and social activity, and build what the memorandum called “a small Islamic society” (ISGAP, 2025).

These categories do not establish that every American mosque, charity, school, civil-rights organization, or Muslim professional association operates under Brotherhood control. They identify the functions the Brotherhood intended for its network to perform, and the relationships of investigators must examine direction, financing, common leadership, coordinated activity, concealed beneficiaries, and operational continuity.

After Hamas’s creation, the Muslim Brotherhood’s U.S. Palestine Committee divided essential functions among separate organizations. The Holy Land Foundation served as its principal fundraising organization. The Islamic Association for Palestine operated as a media entity. The United Association for Studies and Research performed a research and publication function. Internal records placed those entities under the Palestine Committee’s umbrella, with senior Hamas figure Mousa Abu Marzook identified as committee chairman (Vidino, 2023).

The organizations performed different functions, but the evidence demonstrated a common enterprise: HLF raised and transferred money; IAP supplied media and public communications; UASR produced research and intellectual material; Infocom supplied commercial infrastructure; and the Palestine Committee coordinated the network.

1. Religious Outreach and Education

The Brotherhood’s core organizational and pedagogical engine is a staged, small-group system of ‘daʿwa’, invitation and outreach, and ‘tarbiya’, education, formation, and discipline, designed to develop committed members and reshape society along Islamist lines (Trager, 2011)

Hassan al-Banna’s model progresses through al-taʿrīf’, introduction to the Brotherhood’s message; al-takwīn, systematic formation through education and organization, particularly within the usra, or “family,” circle; and al-tanfīdh, implementation through organized social and political action. Brotherhood usras, traditionally reinforce instruction, internal cohesion, accountability, and organizational commitment.

This sequence operationalizes the Brotherhood’s conception of Islam as niẓām kāmil wa-shāmil, a complete and all-encompassing system governing personal conduct, social relations, institutions, legislation, and political life.

2. Political Activity

Political activity included government relations, coalition building, electoral engagement, public-policy advocacy, and efforts to influence American decision-making. The FBI-recorded 1993 Philadelphia meeting of Palestine Committee participants showed them discussing continued support for Hamas (referred to as “Samah”), opposition to the Oslo peace process, and the need to present their objectives in language acceptable to American audiences. Political participation itself remained lawful; the evidentiary issue was whether the activity was independent or coordinated with a foreign or designated principal (Vidino, 2023).

3. Media and Communications

The Islamic Association for Palestine performed the network’s media and public-communications function. It published materials, organized conferences, disseminated messaging, and helped create a national audience for the Palestine Committee’s objectives.

IAP and the Holy Land Foundation later became judgment debtors in the $156 million Boim Antiterrorism Act judgment arising from Hamas’s murder of 17-year-old American David Boim. That was a civil judgment, not a criminal conviction, but it demonstrates that communications, propaganda, fundraising, and organizational services can create liability when knowingly supplied in support of a terrorist enterprise (Boim v. Holy Land Foundation, 2008).

4. Economic and Financial Activity

The Holy Land Foundation and Infocom Corporation provide the strongest Texas evidence of the financial and commercial functions.

HLF operated from Richardson and presented itself as a humanitarian charity. Federal prosecutors proved that it functioned as the Palestine Committee’s principal fundraising arm and transferred approximately $12.4 million through Hamas-affiliated committees and organizations after financial support to Hamas became unlawful. A Dallas jury convicted HLF and five leaders in 2008 of material support, prohibited transactions, money-laundering, tax, and related offenses (United States v. Holy Land Foundation for Relief and Development, 2008). The court-imposed sentences ranging from 15 to 65 years and reaffirmed

the $12.4 million money judgment. The Fifth Circuit affirmed the convictions and sentences (United States v. El-Mezain, 2011).

Infocom was a legitimate Richardson computer and internet-services company operated by the Elashi brothers. Ghassan Elashi simultaneously served as Infocom’s vice president of marketing and HLF’s chairman. Federal juries convicted Infocom and members of the Elashi family of export-control violations, false statements, money laundering, and prohibited financial dealings involving Hamas leader Mousa Abu Marzook.

These cases demonstrate that lawful commerce and unlawful foreign threat activity can coexist within the same corporate structure.

5. Scientific, Educational, and Professional Activity

The United Association for Studies and Research performed the Palestine Committee’s research and publication function. Trial records placed UASR, HLF, and IAP beneath the same Palestine Committee umbrella (Vidino, 2023).

Research institutions, professional associations, universities, and credentialed experts can provide legitimacy, institutional access, intellectual products, and policy influence. UASR was not convicted in the HLF prosecution. Its significance lies in the divided function architecture documented in the admitted records.

6. Cultural and Intellectual Activity

Publications, conferences, lectures, research papers, and cultural programming supplied the ideas and narratives needed to sustain the movement and shape public understanding.

UASR’s publication role and IAP’s media and conference activity show how intellectual production reinforced the network’s political, fundraising, and community functions. The relevant issue is not the viewpoint expressed but whether an organization knowingly operates under common direction or supplies coordinated services to a prohibited entity (Vidino, 2023).

7. Social and Charitable Activity

HLF provides an adjudicated example.

The recipient committees funded by HLF performed some genuine humanitarian and social-service work. The Fifth Circuit nevertheless found that they functioned as Hamas social institutions that increased Hamas’s popularity, strengthened its authority, and allowed it to direct other resources toward violent activity.

The case established an important rule: the existence of genuine charitable activity does not resolve who controls the institution, who ultimately benefits, or whether the donor knowingly supplies prohibited support (United States v. Holy Land Foundation for Relief and Development, 2008; United States v. El-Mezain, 2011).

8. Youth Activity

The Brotherhood’s strategy identified youth education, camps, schools, student organizations, leadership development, and generational recruitment as distinct functions (Vidino, 2023).

The strategic record establishes that the function was contemplated. It does not supply a comparable adjudicated Texas case proving that a present youth or student organization operates under Brotherhood control. Historical associations and overlapping personnel can justify enhanced review; they do not establish current liability without evidence of direction, financing, coordination, or operational continuity.

9. Women’s Organizations

The memorandum also identified women’s organizations as a separate function for family organization, education, community development, and movement continuity (Akram, 1991).

The strategic material establishes the intended architecture. It does not supply a comparable adjudicated Texas case proving that a present women’s organization is Brotherhood-controlled. Historical associations can justify enhanced review; they do not establish current liability without evidence of direction, financing, coordination, or operational continuity.

10. Administration and Coordination

The Palestine Committee supplied the central administrative structure.

Organizational charts, bylaws, annual reports, meeting agendas, telephone records, financial records, and overlapping officers documented the relationship among HLF, IAP, UASR, individual leaders, and Hamas officials. The Fifth Circuit concluded that the evidence demonstrated a joint enterprise supporting Hamas through HLF and the zakat committees, with coordinated action through the Palestine Committee.

This is the function that connects the other eleven. Separate corporate names do not establish independence when the same leadership, financing, assignments, beneficiaries, and strategic direction connect the entities (United States v. Holy Land Foundation for Relief and Development, 2008; United States v. El-Mezain, 2011).

11. Security Functions

Security in this model did not require a conventional armed unit. It included compartmentalization, controlled terminology, protection of relationships, information discipline, concealment of affiliations, and continuity planning.

At the Philadelphia meeting, participants referred to Hamas as “Sister Samah”—Hamas spelled backward—and agreed to describe the gathering as a joint HLF-IAP workshop if questioned. The Fifth Circuit cited the discussion as evidence of deception and an intent to conceal the Hamas connection (United States v. Holy Land Foundation for Relief and Development, 2008; United States v. El-Mezain, 2011).

12. Legal and Judicial Activity

The Brotherhood’s strategic materials contemplated litigation, legal advocacy, rights-based claims, institutional defense, and efforts to influence law and public policy.

Legal representation, civil-rights advocacy, constitutional litigation, and “Know Your Rights” programs are protected and often essential activities. They become relevant to foreign-threat analysis only when evidence establishes that legal services are knowingly coordinated with a designated organization, used to facilitate prohibited conduct, or supplied as part of a concealed foreign-directed enterprise.

The public record reviewed here does not provide a separate Texas conviction proving that a current legal organization operates as the Brotherhood’s legal arm. Historical associations can justify enhanced review; they do not establish current liability without evidence of direction, financing, coordination, or operational continuity (Akram, 1991; Vidino, 2023).

What the Strategic Record and the Texas Cases Establish

The Muslim Brotherhood’s own strategic documents state the objective with clarity. The 1991 Explanatory Memorandum describes the Brotherhood’s work in North America as a “Civilization-Jihadist Process,” a form of grand jihad aimed at eliminating and destroying Western civilization from within so that Islamic law is made victorious. That is not advocacy for policy change within the existing constitutional order. It is a declared design to replace that order (Akram, 1991; Vidino, 2023).

The Texas record supplies the operational proof that this design was not theoretical.

HLF and Infocom produced criminal convictions for material support to Hamas. The Boim (2008) litigation produced civil liability. The Palestine Committee records and the Philadelphia meeting transcripts show coordination, divided functions, and deliberate concealment. These cases demonstrate that the network constructed parallel institutional capacity, financial, charitable, commercial, media, research, political, administrative, and security, while operating under a strategic framework that rejects the legitimacy of the constitutional system it seeks to inhabit and influence.

This record establishes the existence of a documented strategy whose explicit purpose is the subversion of the constitutional order, and a Texas evidentiary record showing that key components of that strategy were put into practice.

Historical association therefore does more than justify “enhanced review.” It triggers a duty to examine whether the same design, settlement, institutional capture, and the progressive displacement of constitutional authority, continues under new names and new vehicles.

Texas Implication: Convert Threat Identification into Enforceable Consequences

Texas already possesses significant tools against foreign adversaries and foreign terrorist organizations. State law addresses foreign-influence reporting, transnational repression, unauthorized enforcement of foreign law, restricted real-property acquisitions, foreign access to critical infrastructure, higher-education research security, and the protection of state-government systems. Texas also criminalizes organized criminal activity conducted as a member of a foreign terrorist organization. These measures are necessary, but they remain divided among separate codes, agencies, definitions, and enforcement mechanisms.

Two structural gaps remain.

First, Texas lacks a single, generally applicable rule governing the civil effect of foreign law and foreign, religious, or private adjudicatory decisions. Existing law provides important safeguards for foreign-country judgments and requires threshold validity and enforceability determinations in specified family-law arbitration cases. It does not establish one uniform rule requiring Texas courts, before compelling arbitration, enforcing an agreement, confirming an award, or recognizing another legal determination, to decide whether enforcement would violate constitutional rights, Texas public policy, due process, statutory protections, or the rights of a child or nonconsenting party.

Texas should build on Florida’s Chapter 2026-28 by prohibiting every Texas court, agency, arbitrator, hearing officer, and other adjudicatory authority from applying or enforcing foreign or religious law when the result would violate a right guaranteed by the United States Constitution, the Texas Constitution, or a controlling state or federal law (Florida Legislature, 2026). The rule should remain facially neutral and apply equally to every foreign legal system and every religious or private tribunal.

Second, Texas lacks a unified mechanism that converts a federal or state threat designation into consistent consequences across state-created privileges. Designation without consequence is incomplete.

A designated organization, its controlled affiliates, and entities knowingly providing material support should not receive state grants, contracts, procurement awards, state tax exemptions, licenses, public property, higher-education partnerships, access to protected information, or state-chartered and state-regulated financial privileges. Texas should also authorize appropriate suspension, revocation, administrative dissolution, debarment, or civil enforcement when current evidence satisfies defined statutory standards.

Texas must evaluate networks, not isolated corporate names. Entities seeking state-created privileges should disclose controlling officers, beneficial owners, parent and subsidiary organizations, related entities, fiscal sponsors, material foreign funding, sanctioned counterparties, and ultimate beneficiaries. Review should identify common leadership, shared addresses, transferred assets, recurring financial relationships, coordinated communications, successor organizations, and continuity of operations.

Historical associations alone should not produce automatic liability. It should trigger an enhanced review. Enforceable consequences must rest on current evidence of material support, sanctions violations, concealed foreign direction or control, fraud, false certification, prohibited financial relationships, or operational continuity with a designated organization.

The standard must remain neutral and conduct based. Religion, ethnicity, lawful charity, independent political advocacy, academic work, and legal representation do not establish foreign agency or terrorist support. The relevant questions are who direct the activity, who controls the entity, who finances it, who receives the benefit, and whether state resources or legal processes are being used to facilitate unlawful conduct.

Texas governs access to state-created privileges and determines the civil effect of legal instruments presented to its courts, subject to the United States Constitution, valid federal law, federal preemption, and applicable arbitration requirements. Federal supremacy does not eliminate Texas authority over its courts, contracts, corporations, charities, procurement systems, professional licenses, public institutions, property, and public safety.

Texas courts should not give civil effect to a foreign judgment, private agreement, religious ruling, or arbitral award when enforcement violates constitutional rights, controlling law, due process, or a fundamental public policy of this state. Likewise, Texas should not extend state-created privileges to an organization that current evidence establishes is controlled by, operating for, or knowingly providing material support to a designated foreign adversary or terrorist organization.

Texas must connect designation to disclosure, disclosure to investigation, and proven threat activity to enforceable consequence.

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