Terrorist designation is one of the most powerful nonmilitary tools available to governments in the fight against terrorism. A designation can freeze assets, criminalize material support, restrict international travel, disrupt financial networks, facilitate investigations and prosecutions, and isolate organizations from legitimate political and financial systems. In some cases, it can also reinforce the broader legal and political justification for counterterrorism operations.
But the growing use of terrorist designations raises an increasingly important question: What happens when the terrorist label becomes not simply a counterterrorism instrument, but a political one?
This question is especially important in parts of the Muslim world, where governments face genuine terrorist threats, yet expansive terrorism laws have also been used against political opponents, journalists, civil society organizations, protesters, and other perceived adversaries. The problem is not terrorist designation itself. Designation remains an indispensable counterterrorism tool. The problem arises when the evidentiary threshold separating terrorism from political opposition becomes unclear.
From Al-Qaeda to Cartels: The Expanding American Model
The United States provides an important starting point.
The modern U.S. Foreign Terrorist Organization (FTO) framework was established under the Antiterrorism and Effective Death Penalty Act of 1996, with the first organizations designated in 1997. Under U.S. law, an organization must be foreign, must engage in terrorism or terrorist activity, or retain the capability and intent to do so, and that activity must threaten U.S. nationals or the national security of the United States.
The early FTO list was dominated by organizations associated with jihadist terrorism, ethno-nationalist insurgencies, and revolutionary violence. Over time, however, the architecture of designations expanded as the terrorist threat itself evolved.
One particularly significant development occurred in 2019, when the first Trump administration designated Iran’s Islamic Revolutionary Guard Corps (IRGC) as an FTO. This marked an extraordinary expansion of the designation framework because the IRGC was part of the governmental apparatus of a sovereign state rather than a conventional non-state terrorist organization.
The second Trump administration again expanded the conceptual boundaries. In February 2025, six Mexican cartels, including the Sinaloa Cartel and the Jalisco New Generation Cartel, and the transnational gangs MS-13 and Tren de Aragua were designated as FTOs and Specially Designated Global Terrorists.
This development demonstrates how the terrorism designation system has moved considerably beyond the organizational profile that dominated the immediate post-9/11 era. Terrorism, insurgency, organized crime, proxy warfare, and other forms of political and criminal violence increasingly overlap.
Expansion, however, makes consistent criteria even more important.
Designation Is Powerful, but It Does Not Necessarily Defeat Terrorism
The logic behind designation is compelling. Once an organization is formally designated as terrorist, governments gain additional tools to disrupt financing, prosecute material support, restrict movement, share intelligence, and isolate the organization internationally.
Yet designation should not be confused with organizational defeat.
More than two decades of counterterrorism operations demonstrate the remarkable resilience of terrorist organizations. Al-Qaeda survived the destruction of its sanctuary in Afghanistan and the death of Osama bin Laden. ISIS lost the territorial caliphate it once controlled across large portions of Iraq and Syria, yet its branches remain active in several regions. Al-Qaeda affiliates and ISIS branches continue to exploit weak governance, civil conflict, local grievances, and ungoverned spaces, particularly in parts of Africa, the Middle East, and South Asia.
This does not mean that designation and the counterterrorism policies associated with it have failed. Success should not be measured solely by whether every designated organization disappears.
Twenty-five years after the September 11 attacks, one of the most consequential achievements of U.S. counterterrorism policy is that jihadist organizations have been unable to repeat an attack on the American homeland comparable to 9/11. Counterterrorism pressure has disrupted leadership structures, financing, communications, training infrastructure, and external operations. In many cases, it has constrained organizations geographically even when it has failed to eliminate them.
Designation therefore works best as one component of a broader counterterrorism strategy rather than as an end in itself.
There is another paradox. For some extremist organizations, being designated by a major international power can itself become propaganda. Groups seeking revolutionary credibility can portray designation as evidence that they have become important enough to threaten a powerful government. The terrorist label may therefore simultaneously constrain an organization’s financial and operational capabilities while increasing its notoriety among potential sympathizers.
The Muslim World’s Terrorism Challenge
The debate over designation cannot ignore a fundamental reality: Muslim-majority countries have borne an enormous share of the human cost of modern terrorism.
Afghanistan, Iraq, Pakistan, Syria, Somalia, Nigeria, and other countries have experienced sustained campaigns by ISIS, al-Qaeda affiliates, the Taliban, Boko Haram, al-Shabaab, Tehrik-i-Taliban Pakistan, and numerous other violent organizations. Muslim civilians themselves have constituted a substantial share of the victims of jihadist terrorism.
Governments across the Muslim world have consequently developed extensive counterterrorism systems. These include domestic lists of proscribed organizations, asset freezes, terrorism-financing legislation, special courts, intelligence operations, border controls, rehabilitation programs, and international cooperation. Regional organizations have likewise developed counterterrorism mechanisms.
These measures respond to real security threats. But precisely because terrorism is such a serious threat, governments must protect the meaning of the term.
When governments apply the same terrorist designation to organizations responsible for bombings and assassinations and to political, educational, religious, or civil-society networks without demonstrating comparable involvement in terrorist violence, the distinction between counterterrorism and political repression begins to erode.
Türkiye provides an important case study.
Türkiye and the Expansion of the Terrorism Label
Türkiye has faced genuine and severe terrorist threats for decades. The Kurdistan Workers’ Party (PKK), ISIS, and the Revolutionary People’s Liberation Party/Front (DHKP/C) have all conducted terrorist attacks in the country. At the same time, Türkiye’s application of terrorism laws has generated extensive controversy.
The most consequential example involves the movement associated with the Turkish cleric Fethullah Gülen.
President Recep Tayyip Erdoğan’s government accused Gülen and his followers of allegedly orchestrating the failed and highly contested July 15, 2016 coup attempt and formally describes the movement as the “Fethullah Terrorist Organization,” or “FETÖ,” although the Gülenist network had not previously been associated with the type of documented violent attacks conventionally attributed to terrorist organizations. Gülen consistently denied directing the coup until his death in the United States in 2024.
Following the coup attempt, Turkish authorities launched an enormous campaign against alleged members and associates of the movement. Public employees were dismissed, businesses and media organizations were seized or closed, schools and universities were shuttered, and large numbers of people were investigated, detained, or prosecuted.
The scale and methodology of this campaign are particularly relevant to the question of politicized terrorist designation. Rather than limiting investigations to individuals for whom authorities could establish direct participation in the coup attempt or acts of violence, prosecutors frequently relied on indicators of affiliation or association with the Gülen movement. These included employment at Gülen-linked institutions, accounts at Bank Asya, membership in affiliated professional or charitable organizations, subscriptions to certain publications, and attendance at Gülen-associated schools.
As a result, the practical scope of terrorism investigations expanded far beyond individuals accused of personally committing violent acts. Membership in a religious or social movement, employment by an affiliated institution, possession of a bank account, charitable donations, or participation in educational activities do not, by themselves, constitute terrorist violence. When such activities become principal indicators of terrorism without individualized evidence showing participation in violence, preparation for violence, or knowing material support for terrorist activity, designation risks becoming a mechanism of collective attribution rather than an evidence-based assessment of terrorist conduct.
The U.S. State Department’s human-rights reporting documented concerns about the breadth of Türkiye’s post-coup approach. Human-rights organizations and international institutions have likewise raised concerns about expansive terrorism prosecutions, detention practices, due-process protections, and the treatment of alleged followers of Gülen and other government critics.
Another particularly important issue is the use of activities that were lawful when they occurred as subsequent indicators of terrorist affiliation. Gülen-affiliated schools, businesses, charities, media organizations, and other institutions operated openly in Türkiye for years. Individuals attended these schools, worked for these institutions, subscribed to newspapers, deposited money in financial institutions, and participated in professional or charitable associations that were lawful at the time.
This raises an important rule-of-law question: To what extent can previously lawful social, financial, educational, or professional relationships subsequently become evidence of terrorist membership without proof that the individual knew of, supported, or participated in terrorist conduct?
Counterterrorism law should punish demonstrable conduct rather than presume that broad populations sharing educational, professional, financial, religious, or social connections possess the same criminal intent.
An important international distinction is often overlooked: Türkiye’s designation does not automatically make the Gülen movement a U.S.-designated Foreign Terrorist Organization. Despite years of diplomatic pressure from Ankara, the United States has not designated the Gülen movement as an FTO. This divergence is particularly significant because Gülen lived in the United States for many years and Türkiye repeatedly sought his extradition.
The Gülen case consequently represents more than a dispute between the Turkish government and a religious movement. It provides a broader case study of what can happen when the boundaries among political opposition, organizational affiliation, and terrorism become blurred.
Exporting Designations Abroad: The Pakistan Case
Türkiye did not restrict its campaign against Gülen-linked institutions to its own territory. Ankara pursued an extensive diplomatic effort encouraging other governments to close, transfer, or take action against institutions it considered affiliated with the movement.
Pakistan provides one of the clearest examples.
In November 2016, Pakistani authorities ordered more than 100 Turkish staff associated with the PakTurk International Schools and Colleges to leave the country even though they had visas. The decision came as President Erdoğan visited Pakistan and publicly welcomed Islamabad’s actions against institutions Ankara associated with Gülen.
The process subsequently moved beyond immigration policy.
In April 2019, Pakistan’s Supreme Court directed the Interior Ministry to declare the Pak-Turk International Cag Education Foundation a “proscribed organization” under Pakistan’s Anti-Terrorism Act and ordered that the schools be transferred to the Türkiye Maarif Foundation. Interestingly, this designation came after the court’s president visited Türkiye and received lavish hospitality in December 2018.
The distinction here is important. It would be inaccurate to simply state that Pakistan designated the entire global Gülen movement as a terrorist organization in exactly the same manner as Türkiye. Pakistan’s legal action specifically targeted the educational foundation associated with the movement.
Nevertheless, the case demonstrates the international political dimension of terrorist designation. Ankara’s diplomatic campaign against Gülen-linked organizations clearly extended beyond Türkiye’s borders, and Pakistan’s subsequent actions occurred amid increasingly close Turkish-Pakistani relations.
The timing also raises broader questions about how terrorist designations can become intertwined with bilateral diplomacy. When a government adopts terrorism-related measures against a foreign educational or civil-society network after sustained diplomatic pressure from an allied government, the evidentiary basis for that decision warrants careful scrutiny.
The fundamental question is not whether Türkiye had the right to present security evidence to Pakistan. Governments routinely exchange intelligence on suspected terrorist organizations. Rather, the question is whether the receiving state independently evaluates that evidence against its own terrorism laws or whether political and diplomatic considerations begin to determine who receives the terrorist label. In Pakistan’s case, allegations of corrupt relationships surrounding the decision raise additional concerns that the designation may have been influenced by political interests rather than solely by an independent assessment of terrorism-related evidence.
Regional Organizations and the Gülen Question
Türkiye’s effort to internationalize its position was not confined to individual governments.
Following the attempted coup, Ankara also sought support from international and regional organizations for its position toward the Gülen network.
The Gulf Cooperation Council’s 2016 Foreign Ministers resolution formally acknowledged Türkiye’s classification of the Gülen network as a terrorist organization. The resolution described the network as posing risks to Türkiye and other Islamic countries.
One factor that may help explain the willingness of some Gulf states to support Türkiye’s position was the broader religious and ideological competition within the Muslim world. Gülen-affiliated educational and civil-society networks promoted an interpretation of Islam distinct from the Wahhabi and Salafi traditions historically supported by some Gulf actors. In countries where both networks sought religious, educational, or social influence, the Gülen movement could be perceived as a competing source of Islamic influence. While this does not by itself establish the motivation behind the GCC’s position, such ideological competition provides additional context for examining its willingness to support Ankara.
Here again, terminology matters.
Recognizing Türkiye’s classification or politically endorsing Ankara’s position is not necessarily equivalent to each member state independently completing a domestic legal FTO designation process. Political declarations by international organizations, national proscription decisions, sanctions designations, and judicial findings should therefore not be treated as interchangeable.
This distinction highlights a broader problem in contemporary counterterrorism: the term “terrorist” increasingly functions as a legal category, a security assessment, a diplomatic instrument, and a political accusation.
Once these functions become blurred, terrorist designation can migrate across borders through diplomatic relationships even when different countries apply substantially different legal standards.
The Danger of Politicizing Terrorist Designations
The consequences of exploiting terrorist designations extend far beyond the organization being targeted.
First, politicization undermines the credibility of legitimate counterterrorism institutions. If governments apply the terrorist label too broadly, citizens and international partners may become skeptical, even when authorities identify organizations that pose genuine violent threats.
Second, expansive designation creates serious rule-of-law concerns. Terrorist designation can trigger asset seizures, criminal investigations, travel restrictions, dismissal from employment, closure or confiscation of businesses, immigration consequences, and potentially lengthy imprisonment. Such extraordinary consequences demand an equally serious evidentiary threshold.
Third, politicized designation can normalize guilt by association. When membership in a family, educational network, religious community, professional organization, financial institution, or civil-society organization becomes sufficient to generate terrorism suspicion, individualized criminal responsibility begins to disappear.
Fourth, politicized designation complicates international cooperation. One country’s terrorist may be another country’s insurgent, political organization, religious network, or civil-society movement. When differences arise from credible disagreements over evidence, international diplomacy can manage them. When they appear to result primarily from political bargaining, however, trust between counterterrorism partners suffers.
Fifth, excessive use of the terrorist label risks diverting security resources. Intelligence agencies and law-enforcement organizations have finite personnel, budgets, and investigative capacity. Treating broad categories of political opponents or loosely associated individuals as terrorist suspects can draw resources away from organizations actively planning bombings, assassinations, mass-casualty attacks, and other acts of violence.
There is also a longer-term societal consequence. People wrongly or excessively associated with terrorism may lose employment, property, freedom of movement, professional status, and social standing. Their families may experience consequences despite never having been accused of violence themselves. The terrorist designation therefore has the capacity to extend punishment far beyond the individuals actually responsible for violent conduct.
Finally, politicization risks destroying one of counterterrorism’s most valuable assets: definitional credibility.
If virtually any political opponent can become a terrorist, the word eventually loses its analytical value. And when that happens, governments may find it more difficult to persuade their populations and international partners when they confront organizations that genuinely do use terrorism.
Terrorism Must Describe Behavior, Not Political Identity
The international community has struggled for decades to agree upon a universal definition of terrorism. Political disagreements will inevitably continue, and no designation system will ever be entirely free of foreign-policy considerations.
But a workable principle remains possible.
Terrorism should be defined primarily by conduct, not by whether governments approve or disapprove of an organization’s ideology, religious orientation, political agenda, or relationship with the ruling elite.
Organizations that deliberately use or credibly threaten violence against civilians or other protected targets to advance political, ideological, or religious objectives belong within the terrorism framework. Organizations and individuals that knowingly finance, facilitate, plan, or materially support such violence can appropriately face terrorism-related sanctions and prosecution.
Political opposition, protest, journalism, education, religious affiliation, lawful financial activity, and criticism of governments, however, should not become terrorism merely because a government regards them as threatening.
This distinction becomes increasingly important as the terrorist designation model expands. The United States has moved from traditional terrorist organizations to an Iranian state institution and, more recently, powerful transnational criminal organizations. Governments in the Muslim world are simultaneously developing and applying their own increasingly extensive designation systems.
Expansion itself is not necessarily the problem. Threats evolve, and counterterrorism policy must evolve with them.
The danger arises when the definition evolves to suit political convenience rather than observable behavior and credible evidence.
Twenty-five years after 9/11, governments possess counterterrorism powers unimaginable before the attacks. Those tools have undoubtedly prevented attacks, disrupted terrorist networks, weakened dangerous organizations, and saved lives.
The challenge for the next quarter-century is therefore not simply to make counterterrorism more powerful. It is to make sure that this power remains directed toward terrorism.
When terrorist designation is based on demonstrable violent conduct, credible intelligence, individualized responsibility, and transparent legal standards, it can be an extraordinarily effective instrument. When it is expanded to settle political disputes, punish association, silence opposition, or satisfy diplomatic relationships, the same instrument can undermine the rule of law and ultimately weaken counterterrorism itself.
A terrorist designation should remain one of the strongest conclusions a government can reach about an organization, not one of the easiest political accusations it can make.
