Opinion for the Court filed by Circuit Judge SENTELLE.
SENTELLE, Circuit Judge:
In December 2001, the Office of Foreign Asset Control ("OFAC") designated Holy Land Foundation ("HLF") as a "Specially Designated Global Terrorist" ("SDGT") pursuant to an Executive Order issued under the International Emergency Economic Powers Act, 50 U.S.C. § 1701 et seq. ("IEEPA"). This designation was accompanied by an order blocking all of the organization's assets...
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