DHS Terms Would Turn Houses of Worship into Immigration Enforcement Outposts and Punish Constitutionally Protected Boycotts
(WASHINGTON, D.C., 8/7/2025) – The Council on American-Islamic Relations (CAIR), the nation’s largest Muslim civil rights and advocacy organization, today issued a nationwide call urging all mosques, churches, synagogues, schools, and nonprofit organizations to immediately pause or withdraw applications to all grants administered by the Department of Homeland Security (DHS) and the Federal Emergency Management Agency (FEMA) – including the Nonprofit Security Grant Program (NSGP) – until the agency removes two dangerous and unconstitutional conditions from its DHS FY 2025 Grant Terms and Conditions.
[CAIR NOTE: After quietly updating its Terms and Conditions document in early August, DHS removed the link to the original April version from its main Terms and Conditions webpage. That version explicitly required grantees to certify they do not boycott Israeli companies, effectively erasing the original language from public view. To make matters worse, both the original and revised documents remain live on the DHS website, despite sharing the same version number and April 18, 2025, date – creating ongoing confusion about which version is operative.]
DHS’s current August updated 2025 Grant Terms and Conditions provisions – Section 9, mandates immigration enforcement cooperation with ICE, and Section 17, implicitly imposes a political test targeting supporters of Palestinian rights and constitutionally protected boycotts of Israel – pose an unprecedented threat to religious freedom, free speech, and the moral independence of civil society groups and houses of worship.
In a public statement, the Council on American-Islamic Relations (CAIR) warned:
“The devil is in the details, and DHS’s grant terms amount to an authoritarian loyalty test disguised as public safety. The message is clear: If you want protection from hate crimes, first pledge loyalty to ICE and Israel. Renounce your values, open your doors to raids, and keep your politics to yourself. No faith community should be forced to choose between securing its buildings and betraying its principles.
“Churches, mosques, synagogues, and other sensitive community spaces were never meant to serve as surveillance hubs for federal immigration or law enforcement, let alone as censors of peaceful advocacy for Palestinian human rights. These DHS conditions cross a moral and constitutional red line. Nonprofits and houses of worship should refrain from applying for these grants until DHS restores prior terms that do not contain these coercive requirements.
“No similar political conditions exist in grants administered by the Departments of Justice, State, or Education. DHS stands alone in this ideological overreach.
“This is not about safety, it is about political obedience. If DHS insists on these terms, we have a duty to resist, and to protect one another through justice, not submission.”
CAIR’s Call to Action for All U.S. Nonprofits:
CAIR urges all faith-based institutions and nonprofit organizations to:
- Immediately pause or withdraw any FY 2025 applications to DHS and FEMA grants until these conditions are changed;
- Contact members of Congress to demand the removal of Sections 9 and 17 from all federal grant conditions.
- Invest in community-based safety strategies, including mutual aid, private fundraising, and local/state grants that do not require political surrender.
What Applicants Are Forced to Accept: Political Conditions Hidden in DHS Grant Terms
The FY 2025 DHS Grant Terms and Conditions include politically charged mandates that violate First Amendment freedoms, undermine religious neutrality, and force institutions to betray core values. These provisions effectively weaponize public safety funding to enforce political loyalty tests.
New DHS TOC Section 9: Collaborate with ICE. Under this section, grant recipients must:
- Share immigration status information with DHS and other government agencies;
- Not restrict any employee or official from cooperating with federal immigration enforcement;
- Participate in DHS-requested operations, including:
- Comply with short-term detention requests,
- Providing access to sought-after individuals,
- Sharing information and participating in joint operations;
- Remain silent, recipients are barred from publicizing or warning communities about immigration enforcement actions;
- Certify compliance under penalty of perjury, and require all subgrantees and contractors to do the same.
In January 2025, DHS issued a directive authorizing ICE raids on sensitive locations, including churches, mosques, hospitals, and public protests, reversing longstanding federal protections. The directive expands enforcement authority even at peaceful demonstrations and religious gatherings. DHS justified this by citing “criminal aliens,” but the directive applies to all undocumented immigrants.
CAIR condemned the policy, warning it would deter vulnerable communities from seeking religious services and chill constitutionally protected worship and protest. The new FY 2025 grant terms now codify that same strategy by coercing nonprofits and religious organizations into immigration enforcement roles through Section 9.
⚠️Bottom Line: Section 9 effectively deputizes houses of worship and nonprofits as extensions of ICE, violating their religious mission and community trust.
New DHS TOC Section 17: Avoid Any Boycott DHS Deems “Discriminatory.” Under this section, grant recipients must:
- Certify they do not participate in any so-called “discriminatory prohibited boycott.” This vague clause, inserted after DHS quietly removed explicit anti-BDS language, can be interpreted to disqualify organizations that:
- Support the Boycott, Divestment, and Sanctions (BDS) movement;
- Refuse to engage with companies complicit in Israeli occupation, apartheid, or war crimes;
- Participate in any peaceful human rights-based boycott.
- DHS Secretary Kristi Noem confirmed this interpretation in recent public remarks: “DHS will enforce all anti-discrimination laws and policies, including as it relates to the BDS movement, which is expressly grounded in antisemitism. Those who engage in racial discrimination should not receive a single dollar of federal funding.”
In April 2025, DHS inserted explicit anti-BDS language into its grant terms, requiring applicants to certify they do not boycott Israeli companies. As noted above, after public backlash, DHS removed the word “Israel” from the terms and conditions clause, but replaced it with a vague new ban on “discriminatory prohibited boycotts.” CAIR called this a “sham” designed to allow the agency to continue punishing critics of Israel while avoiding legal scrutiny.
⚠️Bottom Line: Section 17 imposes a political litmus test that targets advocacy for Palestinian rights and punishes constitutionally protected political expression.
This Is Not Standard Federal Practice!
CAIR has reviewed multiple federal grant programs and found that the Department of Justice, Department of Education, and Department of State do not impose similar conditions. DHS’s growing pattern of coercive policymaking, such as its recent attempt to deny FEMA disaster aid to governments that boycott Israel, which CAIR previously condemned, reveals a troubling escalation of politicized grant enforcement.
CAIR will continue to monitor DHS enforcement of these provisions and is prepared to pursue all legal, legislative, and advocacy avenues to defend the rights of nonprofits and faith-based institutions. If DHS refuses to amend its policies, CAIR will escalate its response in coordination with allies across civil society. In the meantime, impacted organizations are encouraged to seek alternative sources of support that do not require political compliance or participation in immigration enforcement. The right to worship freely, serve communities with integrity, and advocate for human rights must never be conditioned on government approval.
CAIR’s mission is to protect civil rights, enhance understanding of Islam, promote justice, and empower American Muslims.
La misión de CAIR es proteger las libertades civiles, mejorar la comprensión del Islam, promover la justicia, y empoderar a los musulmanes en los Estados Unidos.
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CONTACT: CAIR National Deputy Director Edward Ahmed Mitchell, 404-285-9530, e-Mitchell@cair.com; CAIR Government Affairs Director Robert McCaw, 202-742-6448, rmccaw@cair.com; CAIR National Communications Director Ibrahim Hooper, 202-744-7726, ihooper@cair.com; CAIR National Communications Manager Ismail Allison, 202-770-6280, iallison@cair.com