Brandeis Center urges Justice Department to investigate UNRWA USA over ‘failure’ to register as foreign agent

The Brandeis Center’s central argument is that UNRWA USA’s activities extend beyond the narrow humanitarian fundraising exemption provided under FARA.

By Corey Walker, The Algemeiner

The Brandeis Center for Human Rights Under Law, a leading civil rights and Jewish advocacy organization, is urging the US Justice Department to investigate whether UNRWA USA violated federal law by failing to register as a foreign agent, arguing that the nonprofit’s multimillion-dollar fundraising operation and lobbying campaign on behalf of the United Nations’ Palestinian refugee agency warrant greater scrutiny.

In an Oct. 22 letter to Attorney General Todd Blanche and the Justice Department’s Foreign Agents Registration Act (FARA) Unit, the Brandeis Center alleges that UNRWA USA operates as an agent on behalf of a controversial foreign entity.

The legal group argues that close coordination with the United Nations Relief and Works Agency for Palestine Refugees in the Near East (UNRWA), combined with political advocacy and public relations activities, may trigger federal registration requirements for UNRWA USA.

According to UNRWA USA’s most recent tax filing, cited in the letter, the organization raised more than $51 million in 2024, with nearly all of the money ultimately going to UNRWA.

The Brandeis Center says UNRWA USA is among the agency’s top 10 funders and maintains regular contact with UNRWA staff to monitor and manage projects financed through its grants.

“Americans have a right to know when an organization operating in the United States is raising millions of dollars, lobbying Congress, and conducting public relations campaigns on behalf of a foreign entity with alleged terrorist connections,” said Kenneth Marcus, the Brandeis Center’s chairman and CEO and a former US assistant secretary of education, said in a statement.

“UNRWA USA openly describes UNRWA as its ‘partner,’ funds its operations, and advocates for its interests before lawmakers and the American public,” Marcus continued.

He argued that allegations of extremism and antisemitism within UNRWA’s ranks make transparency particularly important.

The Brandeis Center is asking federal authorities to determine whether the organization’s activities require registration under FARA, a law intended to disclose when individuals or organizations in the United States act on behalf of foreign principals.

The Brandeis Center’s central argument is that UNRWA USA’s activities extend beyond the narrow humanitarian fundraising exemption provided under FARA.

The law contains an exemption for certain fundraising conducted exclusively to provide medical assistance, food, and clothing to relieve human suffering.

Evan Slavitt, the lead attorney for the Brandeis Center, told The Algemeiner that the advocacy group is “hoping the [Department of Justice] will investigate and then require them to register under FARA to demonstrate they are a foreign agent under UNRWA.”

He contends that the public deserves transparency into the inner workings of the organization and that “they’ll understand that [UNRWA USA] is not operating as an independent and fair voice” and instead operating on behalf of the controversial UNRWA organization operating in Gaza.

The Brandeis Center argues that UNRWA USA’s support for education, training, summer camps, building projects, and direct financial assistance, alongside its political advocacy, falls outside the humanitarian exemption.

The letter cites UNRWA USA’s own descriptions of its relationship with the UN agency, including its stated mission of advocating for US government funding so that UNRWA can carry out its mandate.

The organization also describes efforts to mobilize Americans, arrange meetings with lawmakers, and influence public perceptions of Palestinian refugees and the agency that serves them.

Slavitt said that the organization “raises money for education for UNRWA” which does not advance a “non-partisan education” in the Gaza enclave.

Earlier this week, an UNRWA teacher alleged that the organization advances an anti-Jewish educational curriculum, radicalizing Palestinian children.

According to the Brandies Center’s documentation, UNRWA USA advocates recently met with more than 50 congressional offices across both chambers and parties to press for the restoration of US funding.

The group also supported legislation seeking to restore federal assistance to UNRWA.

The Brandeis Center contends that such activities, coupled with fundraising and coordination over grant-funded projects, could make UNRWA USA an agent of a foreign principal under FARA.

Its legal argument does not depend solely on whether the United Nations itself qualifies as a foreign government, the letter says, because UNRWA is headquartered and operates outside the United States.

The request comes amid continuing scrutiny of UNRWA over allegations that some of its employees participated in terrorism or maintained ties to Hamas, the US-designated foreign terrorist organization responsible for the Oct. 7, 2023, attacks on Israel.

The Israeli government and research organizations have publicized findings showing numerous UNRWA-employed staff, including teachers and school principals, are active Hamas members, some of whom were directly involved in the Palestinian terrorist group’s Oct. 7, 2023, invasion of and massacre across southern Israel, while many others openly celebrated it.

Israel has maintained that the agency still employs hundreds of terrorist operatives in Gaza, even after firing several over their alleged involvement in Hamas’s Oct. 7 onslaught.

Many countries, including the US, paused funding to UNRWA amid allegations that the agency aided Hamas terrorists. UNRWA employs 14,000 staff members in Gaza.

UNRWA officials have denied the agency’s complicity in the Oct. 7 massacre and argued their aid work in Gaza is crucial to alleviating the humanitarian crisis in the war-torn enclave.

UNRWA has consistently maintained that it serves a critical humanitarian role for Palestinian refugees and has stated that employees found to have engaged in terrorism-related activities should be investigated and held accountable.

Earlier this year, the inspector general’s office for the US Agency for International Development (USAID) revealed that it found evidence showing 101 current and former UNRWA employees also operated as Hamas terrorists.

According to the federal watchdog, several of the UNRWA individuals referred for suspension or debarment simultaneously held positions within Hamas’s military apparatus.

The Brandeis Center letter also raises questions about whether funds designated for humanitarian purposes can be adequately separated from an organization’s other activities when allegations of terrorist infiltration remain unresolved.

It argues that the narrowness of FARA’s humanitarian exemption warrants scrutiny of how UNRWA USA raises and distributes its money.

The United States has provided more than $6 billion to UNRWA since 1950. However, the Trump administration paused US funding of the group amid concerns over its conduct and ties to Hamas.

The Brandeis Center has also called for investigations into American universities’ financial relationships with Qatar, arguing that ties with such regimes could compromise academic integrity and influence curriculum and staffing decisions.

Qatar has been a long-time backer of Hamas, financing the group and hosting its top leaders.

In the UNRWA USA case, the Brandeis Center is asking the Justice Department to determine whether the nonprofit acts as a representative, publicity agent, or political advocate for UNRWA within the meaning of federal law.

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