I never thought I would have to do a thread on U.S. sanctions law and Shi'a theology in one place, but...

A group of Shi'a Muslims in Houston was arrested for collecting "khums" money on behalf of the Ayatollah Khamenei.

THREAD 1/12 https://www.justice.gov/opa/pr/two-us-citizens-one-pakistani-national-charged-moving-us-currency-iran

What is khums? Shi'a Muslims have to donate 20% of their surplus income every year. Half of it goes to the poor, and half of it goes to religious institutions.

Khums is collected by a marja', the believer's chosen religious authority, or an authorized agent of the marja'

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It's important to note that Shi'ism is not like Catholicism—there's no bishop assigned to a specific geographical area.

Instead, Shi'a Muslims around the world choose which marja' to follow. There are 86 marja's (also known as grand ayatollahs) in total.

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Now, enter "Islamic Pulse."

It's a group that makes educational videos for English-speaking Shi'a Muslims.

And in 2019, they started collecting donations for Yemen on behalf of three marja's: Sistani, Makarem, and Khamenei.

4/12

The Justice Department press release is vague but does not allege that the money was spent on anything but charity in Yemen.

The problem was that it was being collected on behalf of Khamenei, who is also the political leader of Iran.

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For the Islamic Pulse guys, this was apparently no problem.

One of them lives in Iran and allegedly fought in the Iranian military in Syria.

But the Trump admin put sanctions on Khamenei in mid 2019. U.S. law now says you can't do financial transactions with him.

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The Islamic Pulse group allegedly tried to get around this by collecting donations in cash, and refusing to put it in writing how exactly the money was getting to Yeme.

Not exactly best practices for a charity!

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The law eventually caught up to them.

Zaidi and his associate Asim Naqvi were arrested in Houston yesterday.

The third person involved with Islamic Pulse, a Pakistani national named Ali Chawla, still lives in Iran. It's very unlikely he will see jail time.

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Note that it is *not* illegal to collect khums by itself. The Zahra Trust, for example, is a legit registered 501(c)(3) charity that collects money on behalf of several ayatollahs based in Iraq.

https://zahratrust.org/ 

The Zahra Trust has raised money for Yemen legally.

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However, the case could create problems for more innocuous khums collection

The Islamic Pulse group were in "a different class from most of us," but "the worry is that the feds could tie the office of virually any marja" to the Iranian regime, one Shi'a-American tells me

10/12

I would personally wonder whether the "on behalf of" could cause problems as well.

If money is collected in America and spent on 100% U.S.-based charity projects, but it's overseen by the representative of an Iranian cleric, does that run afoul of sanctions law?

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I'll add that everything the Justice Department said is just allegations, and high-profile Iran sanctions cases have fallen apart at trial in the past.

We'll have to see what happens as this case progresses.

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