ZOA promised to reconstitute to avoid regulation under the 1938 Foreign Agent Registration Act

Contents

9/16/1949 Washington Post letter to the editor, "I have just read the latest press release made by Daniel Frisch, president of the Zionist Organization of America.  It has never been possible to take Mr. Frish, his predecessors, or the ZOA lightly, but this latest message to the American Jewish community makes rather grave statements and accusations which bear remarking by legislative and judicial bodies in this country.  Mr. Frisch makes the following statement:

'The Arabs in the Middle East, their friends in London and Washington, are poised for a powerful two-pronged drive against Israel in an offensive to force Israel's hand in the Arab refugee question...At this grave hour, Israel turns once again to American Jewry for moral and political aid in the battle against the sinister and powerful forces that would wreck the new state...As the active conscience of American Jewish identification with Israel, the ZOA has its destined role and task.'

"Close examination of these statements plus investigation of ZOA activities, present and past, easily leads to the conclusion that the ZOA is the agent of a foreign state, acting in its interests, and as such should be registered with the Justice Department or under the legislation affecting lobbies in the United States." 

FBI memo concludes, "The Bureau desires to refer this matter to the Criminal Division of the Department of Justice for an opinion concerning the obligations of the ZOA to register as an agent of a foreign principal."

9/22/1951 FBI Director memo, "The Washington Field checked the records of the Foreign Agents Registration Section, Department of Justice, on April 6, 1948, in connection with the above investigation and ascertained that the ZOA was not registered.  The Department file reflected, however, that under date of February 25, 1948, a letter together with the necessary forms were directed...to the ZOA by the Department advising him that pursuant to an agreement reached with Rabbi Schulson of the ZOA, the organization was requested to comply with the requirements of the Registration Act and to submit registration statements.  Reports, which included the above information regarding the agreement of the ZOA to register, were sent to the Department on May 3, 1948, with a request that the Bureau be advised what further investigation should be undertaken and whether the facts developed indicated a violation of any Federal Statute.  The Department replied on May 12, 1948, that no violation of any Federal Statute was indicated by the reports and that no further investigation of this specific matter would appear to be warranted...On October 28, 1949, a memorandum was sent to the Criminal Division...In reply dated November 8, 1949, the Department advised in part as follows:

'As you know, the obligations of the subject organization under the terms of the Foreign Agents Registration Act have been a subject of study and consideration by the Foreign Agents Registration Section for the past several years.  In April of 1947 a comprehensive memorandum was prepared by that Section outlining in considerable detail the activities and relationships of the subject in connection with the World Zionist Organization.  As a result of this memorandum, a letter was transmitted to the subject again soliciting its registration under the Act.  This letter resulted in a series of conferences being held between representatives of the Attorney General's office and representatives of the subject.  As a result of these conferences the subject organization materially changed its constitution and at the same time effected a change in the constitution of the World Zionist Organization in an effort to remove itself from its agency status.  As a result, all attempts to procure registration of the subject organization were dropped.'

The Department further concluded that the activities of the ZOA and its officers were not in contravention of the Foreign Agents Registration Act and stated that no specific investigation was being requested at that time.

You will recall that Mr. Nathan B. Lenvin of the Department advised our Washington Field Office Agent in confidence that the ZOA brought about a minor change in its constitution so that it might state it was no longer the agent of a foreign principal.  As noted above, the Department stated the ZOA materially changed its constitution and at the same time affected a change in the constitution of the World Zionist Organization.  The Department has not advised the Bureau of the nature of the changes made in the constitution of these Zionist groups."

Citizen letters to FBI about the ZOA.

Memos about investigations to determine whether ZOA actions are directed by State of Israel.

FBI file on reorganization and interrelationships of the Jewish Agency, World Zionist Executive, Israeli government and the ZOA.

May 3, 1954 Memo to FBI Director from LA SAC that evidence of ZOA activities could not be publicly divulged since it would burn sources and methods.  "Inasmuch as the information contained herein does not show such control or direction and insamuch as the information could never be divulged in any legal action in view of the delicate source of this material, it is suggest that the Bureau may not wish to disseminate the report..."

10/2/1970 memo from J. Walter Yeagley memo to FBI director, "We have no further requests of your Bureau at this time with respect to the ZOA."

1/21/1976 ZOA letter to FBI Director Clarence M. Kelly congratulating him on statements against terrorism and requesting reprint rights for 3,500 copies Kelly's  "Terrorism - The Ultimate Evil."

The Jewish Agency's reconstitution into a subsidiary of the WZO, an offshore organization under enough ZOA control for ZOA to effect constitutional changes in 1948, reveals the "Rubik's cube" nature of major Israel lobbying organizations.  Paper transactions and shifting corporate shells are effected to avoid US Department of Justice FARA regulation while the activities and control relationships continue unabated.