The foreign designations that do carry a criminal statute

Two State Department notices published 20 November 2025 designate four organizations as Foreign Terrorist Organizations and as Specially Designated Global Terrorists.¹² The named groups are Antifa Ost — “also known as Antifa-Ost; Antifa-East; Hammerbande; Hammer Gang” — the Informal Anarchist Federation/International Revolutionary Front, Armed Proletarian Justice, and Revolutionary Class Self-Defense, each with a long list of aliases.¹ Both determinations are dated 10 November 2025 and signed by Secretary of State Marco Rubio; the foreign-terrorist designations “go into effect upon publication.”¹²

1. These use the statutory route the September designation could not. The first notice records that, “in consultation with the Attorney General and the Secretary of the Treasury,” the Secretary found “a sufficient factual basis to find that the relevant circumstances described in section 219 of the Immigration and Nationality Act, as amended … (8 U.S.C. Sec. 1189), exist,” and designates the organizations “pursuant to section 219 of the INA.”¹³ That is the designation 18 U.S.C. 2339B turns on: knowingly providing material support to a designated foreign terrorist organization, punishable by up to twenty years.⁴ The presidential order of 22 September designated a domestic entity, for which no comparable statute exists (see Antifa is designated a ‘domestic terrorist organization’).⁵

2. The organizations designated are foreign, and that is a statutory requirement rather than a description. Section 219’s first condition is that “the organization is a foreign organization.”³ Antifa Ost, also called the Hammerbande, is a German group; the Informal Anarchist Federation/International Revolutionary Front appears under its Italian name, Federazione Anarchica Informale/Fronte Rivoluzionario Internazionale.¹ The second notice states the same premise in its own terms: the designated entities “are foreign persons who have committed or have attempted to commit, pose a significant risk of committing, or have participated in training to commit acts of terrorism that threaten the security of U.S. nationals or the national security, foreign policy, or economy of the United States.”² Sharing a name or a politics with a domestic movement is not what either notice addresses.

3. The second designation is a financial instrument. It is made “under the authority of and in accordance with section 1(a)(ii)(A) of Executive Order 13224, as amended,” the terrorist-financing order, which blocks property and interests in property.²⁶ The notice also dispenses with notice: consistent with section 10 of the order, that prior warning “would render ineffectual the blocking and other measures authorized in the Order because of the ability to transfer funds instantaneously,” the Secretary determines “that no prior notice needs to be provided to any persons subject to this determination who might have a constitutional presence in the United States.”²

4. Together the three documents make the shape of the arc visible. The September order designated a domestic movement and could attach no statutory consequence to doing it; the September memorandum built the investigative and financial machinery and a process for recommending further designations (see The designation process arrives three days after the designation); these November notices designate four named foreign organizations under the statute that does carry criminal liability.⁵⁷¹ What the record does not show is any link drawn in these documents between the foreign organizations named here and the domestic entity named in September. Neither notice mentions the September order, and neither asserts a connection.¹²