A terrorism-financing investigation can place liberty, reputation, banking access and organizational continuity at risk before charges are filed. We represent individuals, financial institutions, charities, NGOs, executives and other organizations in federal investigations and prosecutions involving alleged support, funds, services or resources connected to terrorism.
Federal material-support statutes are broad but not identical. Section 2339A addresses material support or resources provided with knowledge or intent that they be used in preparation for, or in carrying out, specified terrorism offenses. Section 2339B addresses knowing provision of material support or resources to a designated foreign terrorist organization, including circumstances in which the person knows of the designation or knows the organization has engaged or engages in terrorist activity or terrorism. The definition of material support can reach currency, financial services, lodging, training, expert advice or assistance, communications equipment, personnel and transportation. A serious defense therefore begins with the exact statutory theory, not a generalized allegation of association.
Our first task is to stabilize the matter. We identify preservation duties, secure relevant communications and transaction data, establish who has contacted the client, and stop uncoordinated interviews or internal speculation. We build a privileged chronology across bank records, donor files, device data, travel, contracts, humanitarian programs and counterparties. The team tests what decision-makers actually knew, when they knew it, what controls were used, and whether lawful, licensed or constitutionally protected activity is being characterized incorrectly. When OFAC blocking, immigration, FARA, export-control or money-laundering issues run in parallel, those strands are managed through one strategy.
In a national-security investigation, speed matters—but disciplined accuracy matters more. The record created in the first days may shape every later forum.
What we do
The scope is tailored to the posture of the case, from confidential pre-charge inquiries to indictment, trial, sentencing, appeal and related regulatory proceedings.
- Emergency response to FBI contact, search warrants, seizures, border questioning and requests for voluntary interviews.
- Grand-jury subpoena analysis, document preservation, collection protocols, privilege review and negotiated production schedules.
- Defense under 18 U.S.C. §§ 2339A and 2339B, including knowledge, intent, designation and material-support issues.
- Transaction reconstruction using bank, payment, wallet, trade, remittance, donor and beneficiary records.
- Parallel OFAC, FinCEN, BSA/AML, immigration, FARA, export-control and asset-forfeiture risk assessment.
- Classified Information Procedures Act planning and coordination with counsel holding appropriate clearances when required.
- Witness preparation, proffer strategy, internal interviews and protocols for current or former employees.
- Charity and humanitarian-program defense, including restricted-party controls, licenses, end-use records and diversion allegations.
- Cross-border evidence, mutual legal assistance, extradition analysis, data localization and foreign-counsel coordination.
- Sentencing, forfeiture, restitution, collateral-consequence and post-resolution compliance strategy when a matter proceeds.
Who we advise
We advise banks, money services businesses, fintechs and crypto exchanges when a customer or transaction becomes the subject of a terrorism-financing inquiry, and when law enforcement requests information that implicates BSA confidentiality, privacy, account restrictions or cross-border data. We represent charities and NGOs accused of inadequate diligence, diversion, prohibited dealings or material support, with attention to humanitarian authorizations and evidence of program controls.
For individuals, executives and boards, our role is to explain the investigative posture clearly, protect legal rights, and make decisions based on evidence rather than fear. For organizations, we also preserve operational continuity: regulator communications, employee guidance, insurer notice, donor or counterparty questions, and public statements are coordinated so they do not create inconsistent records.
Our approach
Every defense is individualized, but the operating method is consistent: establish control, test the government theory, develop credible evidence and coordinate all decision-makers.
Stabilize
Secure records, define the response team, preserve privilege and manage urgent contacts, restrictions or searches.
Reconstruct
Build a defensible chronology of funds, services, communications, controls and knowledge across jurisdictions.
Challenge
Test statutory elements, attribution, sources, translations, analytics, designations and investigative assumptions.
Resolve
Pursue declination, narrowing, negotiated resolution or trial strategy while addressing sanctions and compliance consequences.
