Through increased collaboration, countries can deploy their sanctions and designations authorities to strategically target transnational violent extremism.
In May 2025, federal authorities extradited Georgian national Michail Chkhikvishvili (aka “The Butcher”) on charges including soliciting hate crimes and acts of mass violence in New York City. According to the FBI, Chkhikvishvili is the leader of the Maniac Murder Cult (MKY), a transnational violent extremist group that “adheres to a neo-Nazi accelerationist ideology and promotes violence against racial minorities, the Jewish community and other groups it deems ‘undesirables.’” The charged offenses relate to a plot to conduct a mass casualty attack on New Year’s Eve involving, in part, a fake Santa Claus handing out candy laced with poison to Jewish children. To date, the United States has not designated MKY under any of its various counterterrorism sanctions programs. Yet on July 1, 2025, the United Kingdom’s Home Office announced plans to ban MKY under its proscription regime for providing instructional material on terrorist attack planning.
Although MKY poses a clear national security threat to both countries, each has chosen a different response. These divergent methods can be attributed, in part, to distinctions in the structure and criteria associated with each country’s designation authorities. But if the United States and the United Kingdom, along with other foreign partners similarly afflicted by the scourge of transnational violent extremism, could strategically deploy their respective counterterrorism proscription programs to deliberately target a common enemy, all would mutually benefit.
U.S. Counterterrorism Sanctions Programs
The United States uses two main sanctioning efforts against terrorists: the Foreign Terrorist Organization (FTO) list and the designation of groups and individuals as Specially Designated Global Terrorists (SDGTs) under the authority granted by Executive Order 13224. Although both methods can be applied to transnational violent extremist groups and individuals, only the SDGT option has been used to counter transnational far-right violent extremism.
Several peculiarities distinguish domestic terrorism from its international counterpart. Whereas the Secretary of State, pursuant to section 219 of the Immigration and Nationality Act, as amended under the Antiterrorism and Effective Death Penalty Act of 1996, may designate certain groups as “foreign terrorist organizations,” no authority presently exists for a similar designation of domestic terrorist organizations. Likewise, although federal law criminalizes the provision of material support to designated foreign terrorist organizations, no comparable sanction outlaws material support to domestic terrorist organizations. First Amendment jurisprudence largely necessitates this result. A line of case law in which the Supreme Court has taken pains to observe the “marked difference [in Executive authority] between foreign … and domestic affairs” also contributes to the pronounced distinction between domestic and international terrorism.
The FTO List
As noted above, the Secretary of State is vested with the authority to designate a group as an FTO. The Secretary makes this determination based on three criteria: (1) the organization is a foreign organization; (2) the organization engages in terrorist activity, or terrorism, or “retain the capability and intent to engage in terrorist activity or terrorism”; and (3) the terrorist activity or terrorism of the organization threatens the security of the U.S. nationals or the national security of the United States. International Islamic extremist organizations currently make up the bulk of groups designated under the FTO sanctions regime. The United States has yet to proscribe any transnational far right violent extremist groups as FTOs.
SDGT Designations
Although the SDGT process has broader application, it is primarily a counterterrorism finance tool designed to deny designated individuals and groups access to the U.S. financial system. Although the Secretary of the Treasury shares the authority to designate groups and individuals under Executive Order 13224, it is the Secretary of State who is charged with listing groups and individuals 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 United States nationals or the national security, foreign policy, or economy of the United States; or … to be a leader of an entity.”
In April 2020, the State Department designated the Russian Imperial Movement (RIM) and several of its members of as SDGTs, marking the first time in history that the Department designated a transnational far right violent extremist group. Since then, the State Department has added two additional transnational far right violent extremist organizations to the SDGT list: the Nordic Resistance Movement (NRM) and the Terrorgram Collective.
Although a few foreign governments similarly have banned RIM, NRM and the Terrorgram Collective, the United States has conspicuously declined to list several of the most prominent domestic violent extremist organizations – such as The Base, Atomwaffen Division or the Proud Boys – even though all have considerable international dimensions. In addition, as the legal distinction between domestic and international terrorism begins to collapse, the number of transnational far right violent extremist groups operating in the United States with transnational links continues to grow exponentially.
Foreign Partners Step into the Breach
The Base, Atomwaffen Division and the Proud Boys have all enthusiastically embraced violence to advance their respective ideologies. Although each group originated in the United States, all have global aspirations and each currently has significant international dimensions. Unfortunately, the U.S. government has been reluctant to list these organizations, likely concluding that their respective activity does not squarely fit either the FTO or SDGT criteria. In addition, sanctioning far right groups raises political, constitutional and practical issues unique to the United States.
Luckily, America’s foreign partners have been far less reticent to employ their respective proscription regimes to target these malign actors. For example, Canada and the U.K. have listed Atomwaffen Division. Canada also has proscribed the Proud Boys as a terrorist group. The Base has attracted the most attention and is currently designated as a terrorist organization by Canada, the U.K., Australia, New Zealand and the Netherlands. The European Union (EU) also recently listed the Base, marking the first time it has designated a far right group as a terrorist entity.
Other foreign partners also have been very aggressive in listing far-right transnational violent extremist groups. Germany has banned over 50 far-right violent extremist organizations, including Combat 18 and Hammerskins Deutschland. Australia just recently listed the Terrorgram Collective, characterizing the online terror network as a “giant chat group dedicated to evil.” France has dissolved Generation Identitaire, a far-right “paramilitary” group linked to Brenton Tarrant, the gunman in the Christchurch mosque attack.
Although these individual efforts by other countries should be applauded, there are important distinctions in the criteria each uses to make designation determinations. Germany’s association ban framework, for example, is grounded in its Basic Law and operates under the principle of “militant democracy,” a standard unique to Germany that permits restrictions on associations whose activities contravene criminal law or are directed against the constitutional order or peaceful international relations (Völkerverständigung). Conversely, France does not have any formal, public list of designated terror groups but instead uses specific legislation on a case-by-case basis to dissolve groups or associations representing a significant security threat.
All this activity clearly reflects the growing international recognition of the threat posed by far-right transnational violent extremist groups and the increasing use of legal proscription as a counterterrorism tool. Designation regimes work. Coordinated designation regimes, strategically deployed by like-minded partners targeting a common enemy, might work even better.
Single Walls, Shared Fortress: The Value of Collective Action
Much of the scaffolding for closer collaboration is already in place. In addition to standard bilateral cooperation and intelligence-sharing in ongoing investigations, many countries have contributed to a variety of international efforts on issues related to transnational violent extremism.
The International Institute for Justice and the Rule of Law (IIJ), the United Nations Office on Drugs and Crime (UNODC), the Global Counterterrorism Forum (GCTF), the Council of Europe and other multilateral institutions all have brought countries together to develop a shared understanding of the ever-evolving threat and to foster dialogue on how to contend with it. These initiatives have produced several best practices guidelines and manuals, toolkits and other valuable resources. At the operational level, entities like Europol have coordinated measures like Referral Action Days (RAD), designed to tackle online violent extremist propaganda and terrorist content targeting minors. Europol also operates several Analysis Projects, one of which (AP Dolphin) serves as a kind of clearinghouse for intelligence on far-right violent extremist networks operating in the EU.
Despite the inevitable obstacles – such as lack of political will, institutional resistance between and among departments and agencies, and differing opinions on issues like free expression and association – the benefits of strategic collaboration on sanctions and proscription regimes clearly outweigh the costs. Coordinated, sequenced action using these systems allows for political signaling (acknowledging transnational violent extremism as threat vector worthy of attention); it freezes assets and curbs violent extremist financing; it isolates designated terrorist organizations internationally; it heightens public awareness of proscribed organizations and aids content moderation efforts. Most importantly, it denies transnational violent extremist groups safe harbor.
The foundation for future cooperation is in place. The next step is to build a durable framework to strategically leverage the full weight of each country’s individual authorities, including – crucially – proscription and sanctions regimes. The common target of this collective action are those transnational violent extremist groups whose violence extends across borders and impacts the lives of people all over the world. As with most things in life, working together is almost always better than going it alone.
