The political advocacy branch of the Council of American-Islamic Relations (CAIR), known as CAIR Action, is allegedly operating without the necessary legal permissions in the 22 states where it conducts political activity and fundraising, according to an investigation shared with The Washington Free Beacon.
The watchdog group that conducted the investigation suggests that CAIR's nationwide political operations may be part of an illegal fundraising scheme, as the organization has consistently avoided state and federal regulators.
CAIR Action, incorporated in Washington, D.C., directs a national political operation that endorses candidates, solicits donations, organizes campaigns to influence voters, and maintains the infrastructure for its extensive advocacy network. However, according to a joint investigation by the Network Contagion Research Institute (NCRI) and the Intelligent Advocacy Network (IAN), CAIR Action has not obtained the Basic Business License (BBL) required for it to legally operate or solicit funds within D.C. or elsewhere.
The report describes CAIR's operations as "an unlicensed interstate political-solicitation enterprise operating entirely outside the legal framework required for entities seeking funds across state lines." The lack of legal authority for CAIR to operate could potentially make it liable for charges of wire fraud, deceptive solicitation, and false statements to the IRS.
The investigators were unable to find any evidence of the necessary corporate registration, charitable filings, solicitation licenses, or any other form of legal authorization in any of the 22 states where CAIR Action operates.
This report follows a series of actions against CAIR at both the state and federal levels. Texas Governor Greg Abbott (R.) recently ordered an investigation into the group, designating it a Foreign Terrorist Organization and accusing it of being a front group for Hamas, citing the FBI. In Congress, Senator Tom Cotton (R., Ark.) has called on the Department of Education to investigate a potentially illegal partnership between CAIR and K-12 schools and has urged the IRS to review the group's tax-exempt status. Alongside Representative Elise Stefanik (R., N.Y.), Cotton has also requested the Treasury Department to investigate links between Hamas and CAIR, whose leader, Nihad Awad, expressed happiness at Hamas's Oct. 7, 2023, attack against Israel.
According to the report, the D.C. Department of Licensing and Consumer Protection could not find CAIR Action's Basic Business License when contacted by NCRI investigators in September and October.
In California, one of CAIR's most active hubs, CAIR Action is only registered as an out-of-state nonprofit corporation. It is not registered with the California Attorney General's Registry of Charitable Trusts, which is required within 60 days of fundraising in the state, and has not filed the necessary CT-1 form for any charitable organization to operate.
The report includes a Nov. 3 letter from the California Attorney General's office stating that CAIR Action "has received no authorization to solicit funds."
Despite lacking charitable authorization or solicitation registration, CAIR Action's California operation continues to solicit donations and paid memberships, issue political endorsements, and direct voter-targeted mobilization campaigns. This could potentially expose the organization to federal scrutiny across multiple agencies.
Despite its unclear legal status, CAIR Action continues to solicit donations and paid memberships, issue national political endorsements, and run voter-influence campaigns through its website, email lists, and digital platforms, all originating from Washington, D.C., where it lacks the legal authority to operate. The investigators argue that CAIR Action's failure to obtain a business license in D.C. renders its fundraising efforts both within and outside the city illegal.
The report states that "because CAIR Action is not legally authorized to operate even in its home jurisdiction, every state where it solicits can treat its fundraising and political influence as presumptively unlawfuland since CAIR Action is openly presented as CAIR National's political arm, any unauthorized solicitation or electioneering it conducts becomes CAIR National's responsibility."
In the 21 other states where it operates, CAIR Action maintains specific webpages that allow users to donate or become members. These state-specific sites also list political endorsements and essentially serve as live fundraising portals for the organization's political work.
However, the report states that "in the 21 states beyond California, multiple searches revealed no required corporate registration, state charitable filings or solicitation licenses, and no legal authorization of any kind. Despite this complete absence of compliance, CAIR Action continues to solicit money, promote paid memberships, and engage voters while portraying itself as a lawful national political entity."
In response to the report, CAIR Action told the Free Beacon that it "fully complies with all applicable federal and state laws governing 501(c)(4) organizations" and that the "characterizations in this report are inaccurate and misleading." The group also stated that it will continue to review all applicable compliance requirements to ensure full adherence to the law as the organization's activities expand.
CAIR Action also stated that it "cannot respond to or verify the specific characterizations attributed to the unnamed 'report' referenced in your inquiry because it has not been provided with a copy of that report, nor given an opportunity to review or respond to its contents," even though the Free Beacon shared the information in the report with CAIR Action.
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