Reconsidering Secular Support of the Wolf Act: The Example of Cuba,Nicole Scott,Free Inquiry

In 2016, Congress passed the Frank R. Wolf International Religious Freedom Act, a.k.a. Public Law 114-281. Section 2 of the Act—an amendment to the International Religious Freedom Act (IRFA) of 1998—conveyed Congress’s “revised” view that “freedom of thought, conscience and religion is understood to protect theistic and non-theistic beliefs, and the right not to profess or practice any religion.” With the passage of the Wolf Act, the U.S. government’s official definition of religious persecution now included “the specific targeting of non-theists, atheists and humanists because of their beliefs.”

In December 2016, when President Barack Obama signed the Wolf Act into law, the event was widely celebrated. In a press release, American Humanist Association Executive Director Roy Speckhardt stated:

Legislators are finally recognizing the human dignity of humanists and granting the same protections and respect that have been given to religious communities. With the increasing global persecution of humanists and atheists at the hands of religious authoritarians, we’re proud that Congress and the U.S. Department of State are standing for the liberty of all people, both religious and non-religious.

Applauding Speckhardt’s words, Michael Stone of Progressive Secular Humanist wrote that the act is “good news for international liberty.” Likewise, a blogger for URGE (Unite for Reproductive and Gender Equity) thanked Obama for the “Christmas present” and stated, “It does mean a lot that a president would take the time to acknowledge that there is an unlevel playing field and an inherent bias in regards to atheism.” The Center for Inquiry (CFI) also released a positive announcement, though it noted the “unfortunate” “controversial language which states that prohibitions on ritual animal slaughter and male infant circumcision would count as examples of violations of religious freedom.”

1988: The International Freedom of Religion Act

The Wolf Act did more than “protect” secularists from religious persecution. The Act was intended to address deficiencies in the International Freedom of Religion Act (IRFA), passed by Congress in 1998 in response to agitation from American—mostly Christian—religious groups.1  These groups argued that Christians were being persecuted around the world, especially in Islamic countries such as Sudan, Pakistan, and Saudi Arabia, as well as in communist countries such as China, Cuba, and Vietnam. Their call for congressional action especially appealed to conservative Cold Warrior types such as Jesse Helms, who believed that the  IRFA would benefit U.S. foreign policy by spreading Western ideals—such as freedom of religion—across the Third World. In the end, then, the International Freedom of Religion Act of 1998 was intended to protect the religiously persecuted and promote U.S. interests abroad.

How did Congress think the United States could regulate religious freedom in other nations? Through the  IRFA, Congress created—within the State Department—an Office of International Religious Freedom, with a new ambassador-at-large responsible for issuing an annual country-by-country report on religious freedom. His annual report defines the status of religious freedom in every foreign country, assesses the nature and extent of violations of religious freedom, describes U.S. actions and policies supporting religious freedom in each country, and describes any binding agreements the United States has established with foreign countries.

The IRFA also created an independent government agency with its own budget: the U.S. Commission on International Religious Freedom, responsible for writing its own report and making policy recommendations to Congress, the president, and the State Department. Why a new State Department office and a new independent agency? They were the result of a compromise between those who favored using quiet diplomacy to promote religious freedom—i.e., from within the State Department—and those who favored more overt, direct action from a group not tied to elected officials. In addition, within the National Security Council,  the IRFA established a special adviser on international religious freedom. Finally,  the IRFA provided the president with fifteen responses, one of which he is required to take against nations that “violate” religious freedom, reported as “countries of particular concern” (CPC).

But when it comes to taking action against violators, the president has significant leeway. While the law says a “presidential action must be taken against each state identified as a ‘violator,’” a confidential communication between governments called a “private demarche” satisfies the requirement. This “loophole” mitigates the fears of those who oppose “automatic sanctions,” especially economic sanctions that might offend a country whose friendship is in our national interest.

On October 27, 1998, President Bill Clinton signed the  IRFA into law. Clinton himself had woven religion into the ordinary actions of the president by publicly requesting forgiveness of sins, opening cabinet meetings with a prayer, and regularly consulting Protestant ministers on a wide array of issues. His actions initiated a firestorm of criticisms, both theoretical and practical.

First, critics raised some theoretical/philosophical questions.[2] Given that the nation’s Founding Fathers, such as James Madison, had warned against the dangers of organized religion in the political sphere, why should the U.S. government become a religious stronghold fighting for freedom of religion? In fact, given their inherent irrationality, how do religious values really promote our national interest and advance our foreign policy? If we impose Western ideals on hostile countries—and especially if the United States withholds aid from alleged violators of religious freedom—what is to prevent foreign governments from taking out their anger through future persecution? Won’t the international community perceive that U.S. promotion of religious freedom abroad is merely a facade for a new postwar American imperialism?

Then there were the practical questions regarding the United States’ authority to regulate religious freedom. The United States’ right to police and punish violators of religious freedom is grounded in international law and covenants guaranteeing the rights of all individuals to worship freely, such as the United Nations’ Universal Declaration of Human Rights (Article 18) and International Covenant on Civil and Political Rights (Article 18). But it’s a “right” easily scoffed at, given the number of times the U.S. government has itself flouted or refused to endorse international covenants. As one critic stated:

It is curious that the U.S. is so protective of its own sovereignty that it refuses to ratify an almost universally ratified treaty like the Rights of the Child Convention, and yet it expects other countries to share its own particular concern with freedom of religion. [The] U.S. has consistently refused to be part of the process of developing and implementing international rights, whether on freedom of religion or any other human right, and yet here comes this “Lone Ranger” effort on this particular freedom.3

In the November/December 2020 issue of Free Inquiry, Shadia B. Drury noted that to the United States, the “rule-based international order” is “intended for others, not for the United States.”

Another challenge to U.S. authority: Why would other nations take U.S. enforcement seriously, given that it does not practice what it preaches? For example, overseas, many American missionaries offer foreigners “information about religion.” Under “international covenants,” their work is not legally subject to limitations even though their “religious” views often include political, economic, and social concepts and implications inimical to the government, and even the society, in which they “preach.” But the United States has no tolerance for Muslim clerics preaching sharia law here. In fact, the United States seems to have no tolerance for Muslims whatsoever, given the U.S. Supreme Court’s recent refusal to grant a Muslim’s simple request for an imam before he was executed and the well-known fact that—as Asma T. Uddin has written—SCOTUS is pursuing an ideological agenda in which “minorities like Muslims lose and conservative Christians win.”

Law enforcement is respected when officers treat violators equally. But in the  IRFA, nothing prevents presidents—motivated by political and economic considerations—from enforcing sanctions unevenly. This uneven enforcement has in fact been the reality. As Lee Marsden has written, “The US has used CPC status and records on religious freedom to castigate political opponents and rivals, including North Korea, China and Iran.”4 On the other hand, sanctions against Saudi Arabia—a blatant violator of religious freedom—have been waived in “the important national interest of the United States.” In fact, since  the IRFA’s inception, the only sanction leveled against otherwise unsanctioned nations has been against hapless Eritrea in 2005 (and religious freedom has since decreased there).

The Biden administration has done nothing to improve enforcement. On its recently announced 2021 list of “countries of concern” for having violated religious freedom, only U.S. “enemies” were included. India’s Prime Minister Modi and his party have recently imposed laws aimed at marginalizing Muslims, but as part of Biden’s strategy to “counter China,” his administration has been “courting” Modi; thus, India was not included on the administration’s “concerned” list. The State Department also recently removed Nigeria from the list, a move that drew sharp criticism from the Independent Commission, which cited “violence by militant Islamists and other state-armed actors, as well as discrimination, arbitrary detentions, and capital blasphemy sentences by state authorities”5 in Nigeria. With the State Department’s political agenda clashing with the judgments of the Independent Commission, how will the United States ever enforce the law fairly? As Johan Van der Vyver has written, “Jurisprudentially, religious persecution ought not to escape punitive action … at the pleasure of the agency of enforcement.”6

Finally, U.S. authority is weakened by its definition of “religious freedom.” The American model of separation of church and state does not conform to the stories, traditions, and cultures of other societies. Unlike the United States, where religion is considered a matter of personal choice, “in most countries of the world, a dominant religious tradition [plays] a disproportionately influential role in shaping the modern histories of those countries [and helps] form their cultures, traditions and institutions.”7 For example, in “dominant religion” countries—those in Europe included—it is common for larger or more traditional religions to receive state benefits. Understanding these differences and making balanced judgments about religious freedom require U.S. officials to understand not only other nations’ religious traditions but also their histories and cultures.

But as the Iraq invasion in 2003 sorely proved, U.S officials have little in-depth knowledge of other nations. One analyst has said that “it would be appropriate for foreign observers to examine how their traditions of dominant religions and state-approved religions can lead to discrimination against newer and minority religions. …”8 But such improved understanding and observations are not provided for in  the IRFA. Would it not be “appropriate” for the United States to obtain such an understanding before commencing to criticize and take action against a nation? This is not simply a matter of logic or protocol; rather, this ignorance badly distorts U.S. perceptions of so-called violations of religious freedom, as I will show with the example of Cuba.

Finally, after it became law in 1998,  the IRFA’s effectiveness was called into question. Thomas Farr, former director of the State Department’s Office of International Religious Freedom, stated that since its inception, Republican and Democratic administrations have relegated  the IRFA “to nothing more ‘than a narrow humanitarian measure unrelated to broader U.S. interests.”9 In 2013, Farr also wrote, “I know of no evidence that either the listing or the sanctions have improved the status of religious freedom in any country”10 (his emphasis). The State Department admitted that the  IRFA’s effectiveness continues “to be undermined by the inability to move beyond ‘naming and shaming’ to the ‘much larger effort to connect religious freedom with the mainstream of our foreign policy.”11

2016: The Wolf Act

In 2016, to address criticisms of  IRFA and “to improve the ability of the U.S. to advance religious freedom globally,” the Wolf Act was passed. The Act includes numerous “amendments” aimed to correct the 1998 Act’s shortcomings. As noted, when Barack Obama signed the Wolf Act in December 2016, the event was celebrated by atheists.

But as Robert C. Blitt has shown,12 in passing the Wolf Act, Congress failed to adopt “key reforms” that would have addressed critics of  the IRFA. He noted that failure of these reforms—such as scaling back presidential discretion over implementation or relocating the CRF Office and ambassador to the Office of the Secretary of State so that they could work better together—“signals a continuing unease with fully integrating religious freedom promotion into U.S. foreign policy.”

On the positive side, Blitt pointed out that the Wolf Act requires “mandatory ‘training on religious freedom for all Foreign Service officers, including all entry level officers.’” It empowers the ambassador-at-large “to make recommendations to the Secretary of State regarding the nature of the curriculum, including ‘how United States international religious freedom policy should be carried out in practice by United States diplomats and other Foreign Service officers.’” But this training is aimed to heighten civil servants’ awareness of how religious freedom serves U.S. strategic interests; it does not address their ignorance of foreign traditions, history, and culture. Amid American ignorance, the Wolf Act ironically adds a new “Special Watch List” of foreign governments that can now be “put on notice” that they must improve their religious freedom or face future designation as a “CPC” worthy of sanctions.

Today, anyone reading the U.S. Religious Commission’s annual reports will understand critics of  the IRFA and its successor, the Wolf Act. American hypocrisy permeates these reports. For example, in its twentieth annual report, the Commission trumpets its support of the Universal Declaration of Human Rights despite—in Jimmy Carter’s words13 the United States’ “cruel and unusual record” on human rights. Likewise, in its 2020 report on Cuba, the Commission—seemingly oblivious to numerous UN votes condemning the U.S. economic embargo on Cuba, never mind U.S. travel restrictions aimed to “starve” its tourist dependent economy—condemned Cuba’s own restrictions on religious leaders traveling to and from the United States. Apparently, the Commission believes struggling Cubans can survive on the “body and blood of Christ” alone.

But among all criticisms mentioned above, anyone reading the U.S Commission’s reports will be most stunned by its ignorance of other nation’s histories. Consider its 2020 report on Cuba, which since 2004 has been on the Commission’s “tier 2” watch list. The Commission uncritically accepts the Catholic Church’s estimate that 60 percent of the population is Catholic. Yet Australian academic John Hearn has reported that Catholic masses are attended primarily by Santerians, who, with other Afro-Cuban religions, constitute 70 percent of the Cuban population, particularly in poor urban communities.14 Indeed, the Commission’s breakdown on all religious denominations is almost meaningless, given—as I have reported15 and as Hearn has said—Cubans’ religious beliefs are a “cocktail” of African and Christian superstition, and that “Cuban religious life remains characterized by a high incidence of home worship and informal practices.”

Much more egregious is the Commission’s 2020 report on the Cuban government’s so-called “violations” of religious freedom. Highly critical of the government’s close monitoring of religious activity and especially of its legal requirement that churches register with government authorities and comply with Cuban laws, the Commission’s reports on Cuba conveniently ignore the nation’s history: a history during which the U.S. government and the Catholic Church repeatedly attempted to thwart the revolutionary government’s efforts to meet the Cuban population’s basic needs (see sidebar).

None of this history has been forgotten in Cuba, still the object of U.S. hostility. It is hardly surprising that, as Hearn notes, religious freedom in Cuba requires “adherence to sometimes restrictive legal conditions” consistent with the aims of the revolution. The monitoring and restricting of foreign clergy must especially be expected, given their history of subversion in Cuba.

But—contrary to the U.S. Commission’s criticisms—these restrictions can also have their positive side. For example, Hearn tells of one religious woman, Felicia, whose family’s weekly community public performances of Afro-Cuban folkloric music began attracting tourists to their home. Cuban law required that she secure a license to generate income. But in consultation with community groups who had observed the performances, Cuba’s Office of the Historian required Felicia to eliminate jinteros (unlicensed—often unscrupulous—tour guides), women “fishing” for foreign men, drug use, the unlicensed selling of mojitos, and selling telephone calls to foreign tourists. She was also required to eliminate a type of dancing that had a “reputation for encouraging machismo, pride, and generally hot-blooded behavior (or guaperia.)”

The U.S. Religious Commission has criticized Cuba for “violating” the religious freedom of many religious practitioners, such as Felicia. But by complying with the law, Felicia mitigated some of the social ills spawned by her performances and observed by her neighbors. Moreover, she received not only her license but also material support from the government. Has the Commission ever noticed that unrestricted religious liberty can damage the public’s welfare?

The U.S. Religious Commission also seems to think religious freedom is the only important human right in Cuba. In its 2020 report, the Commission omitted mentioning that the original draft of Cuba’s new constitution (approved in 2019) allowed for “marriage” to include same-sex partners, but evangelical churches—and some Cuban Catholics—organized a campaign opposing that provision. And as the Washington Office on Latin America (WOLA) has reported, “Despite Cuba’s image as a state that suppressed religious freedom, prevented organized political campaigns, and been unwilling to listen to citizens’ views, the government responded and … withdrew the proposed language.”16 As alleged advocates of internationally recognized human rights, shouldn’t the Commission criticize Cuban theists who themselves disrespect “international standards” by opposing gay marriage and reproductive freedom (the latter, by the way, was enshrined in the new Constitution)? And shouldn’t the Commission credit the government—right or wrong—for its flexible response to religious opinion?

As Hearn has stated, numerous policy and research reports have concluded that forty years of U.S. hostility—especially the trade embargo —“has strengthened rather than weakened the position of hard-line elements with the Cuban administration and made peaceful reconciliation with the United States less likely.” The same may be true of the U.S. Religious Commission’s hardline position on religious freedom in Cuba: by recommending, for example, that the United States deny visas and freeze assets of Cuban government officials who “suppress” religion, it does nothing to make religious freedom in Cuba more likely.

In the end, perhaps the Wolf Act’s most noteworthy amendment to  the IRFA is, as noted, Section 2’s addition of nonbelievers to the list of the religiously persecuted. Does this mean that, despite all its flaws, atheists should support the Wolf Act and work to have it reauthorized in December 2022? Should they even advocate more amendments to improve its efficacy? Even if the Act is essentially ineffective in changing world behavior, why not just let it stay on the books for its official recognition of persecuted nonbelievers? Or, as Canada did in 2016,17 should the United States abandon the Religious Freedom Commission and fold it into an office that seriously advocates for all human rights abroad? Or, with the more enlightened Biden administration in office, should atheists accept that—in Mark Silk’s words—“the time has come to let [the Act] expire”18 and redirect U.S. energies toward bolstering international organizations working to improve religious freedom?

While one could argue for any of these approaches, atheists must recognize that—at best—the IRFA and its successor, the Wolf Act, have serious flaws, do little to improve worldwide religious freedom, and may nominally serve only our own self-interest to the detriment of others.

Why Cuba Places Restrictions on Religious Freedom

Here is some easily accessible Cuban history,1 which the U.S. Religious Commission “forgets” in its annual reports on Cuba:

When Fidel Castro and his fellow revolutionaries seized power in January 1959, they wanted far-reaching socioeconomic reforms to address problems especially prevalent in Cuba’s rural areas. According to Margaret E. Crahan, the 1957 annual income of Cuban agricultural workers was $220. Close to half (43.4 percent) lived in substandard housing lacking indoor water, electricity, and indoor sanitation. Serious diseases—typhus, malaria, and tuberculosis—were common. Nearly half (44.1 percent) never attended school; among those who did, only 1.18 percent completed seventh grade. The new government thus sought the eradication of poverty, free universal health care, universal education, affordable rent and telephone rates, as well as the elimination of prostitution, gambling, racism, and other social ills prevalent under the Batista regime.
In a primarily agricultural economy, the revolutionary government’s program required radical agrarian reform, effected in May 1959. The new law placed a 1,000-acre limit on all estates, though highly productive owners could own as much as 3,333 acres. Expropriated landowners were to be compensated with twenty-year bonds paying 4.5 percent interest. As Kirk notes, this radical reform came “largely at the expense of the bourgeoisie and the small upper class. … Most Cubans soon appreciated the important changes [that] had been obtained for their benefit.” The middle class immediately resisted this attack on “the sanctity of private property,” and many—though not all—fled to Florida.
Agrarian Reform—in particular, the expropriation of private property—threatened American hegemony, especially during the postwar Cold War climate. U.S. landholding companies—“used to government bribery and unfettered control of their vast properties” (Kirk)—demanded compensation. As early as June 1959, the Central Intelligence Agency (CIA) initiated assassination attempts on Castro’s life; in an attempt to destroy the economy, planes flying from Florida dropped incendiary bombs on sugar plantations, with one bombing in Pinar del Rio resulting in the capture of two American pilots. In fall 1960, the United States placed an embargo on trade with Cuba. And of course, in April 1961, the CIA sponsored the Bay of Pigs invasion, led by Cuban exile Jose Miro Cardona. According to Kirk, “this campaign of subversion, which helped create a climate of concern and fear, left the government with two alternatives—to relax radicalization or to harden fidelista resolve. It chose the latter.”
Although the Catholic Church celebrated Castro’s victory in 1959, and although Vatican II and the papal encyclical Rerum Novarum “acknowledge[d] the suffering of workers” and “advocated for just wages,” Cuba’s Catholic hierarchy—mostly of Spanish origin—could not accept the Agrarian Reform Law. Echoing the cries of exiled landowners and the American media, the hierarchy argued that God’s “divine order” made sacred the right to private property, and (in Kuivala’s words) “the transcendent, eternal authority of the Church—and of Christ as the founder of the Church—surpassed all temporal and secular authorities.” The Church’s class interests were also threatened: during its history, the hierarchy had represented (in Kuivala’s words) “the interest of the owning class. … The driving force[s] of the Church were the primarily urban, white and economically privileged lay people … [and] the [land] redistribution constituted a loss of political power and stability for the elite, which brought many of them to strongly criticize the revolution.”
The Catholic hierarchy did issue statements approving of the government’s reforms—agrarian reform included—while stating that the reforms had to respect the right to private property. But in Margaret E. Crahan’s oft-quoted words, “How this was to be accomplished was not explained.” It should be added, as Kirk has noted, that some Church representatives—most notably, the Franciscans—tried unsuccessfully to dissuade the hierarchy from having “greater concern for rights to property … than for its just distribution.”
Like some churches, the Catholic schools, which were taught mostly by Spaniards with “reactionary, right-wing, Spanish-nationalist—even pro-Franco ideas,” became (in Castro’s words) “hotbeds of revolutionary activity … linked to sabotage, bombs and other CIA activities.” In fact, as early as November 1959, the Church challenged the government at the First National Catholic Congress in Havana, a three-day event drawing a million people. It was a show of strength that, according to John C. Super, “made Castro realize that the Church did have the power to stand up against the revolution.” Although he appeared and spoke there, Castro was jeered; meanwhile, according to Kuivala, Congress speakers again “emphasized a just distribution of wealth … while fiercely defending individual rights to private property.”
The Catholic Congress was only the first reaction. From 1959–1969, the Church resisted the government’s reforms in many ways. Three Spanish-born priests were among the 1,400 Cuban exiles who participated in the Bay of Pigs invasion. The Church hierarchy facilitated the covert exodus of 14,000 unaccompanied children to the United States (“Operation Peter Pan”). It issued pastoral letters demanding that lay members choose between the Church and Cuba’s “communist” government. It also repressed priests who supported the revolution; one well known supporter—Father German Lence—was suspended and relieved of all his priestly duties. The hierarchy even conducted masses celebrating Franco’s 1939 victory over “communism” in Spain’s civil war. All this counterrevolutionary activity was promoted by Rome’s hard “anti-communist stance,” Cuban exiles in Miami, and, of course, U.S. terrorism and attempts to overthrow the government. These attempts accelerated with “Operation Mongoose”—authorized by President Kennedy in 1961—and involved the dispatching of three six-man terrorist teams to Cuba. U.S. terrorism included CIA-planted bomb attacks on crowds; CIA firebombing of sugar and tobacco plantations; the hijacking of airplanes by Cuban exiles linked to the CIA, and the CIA’s destruction of the express train that ferried Soviet imported goods between the port of Santiago and Havana. In response, “As in Batista’s time, the Church hierarchy remained conspicuously silent” (Kirk). Ultimately, the Church not only rejected dialogue in favor of a “frontal attack” (Kirk) but also “failed to offer clear alternatives to the revolution’s socio-economic program” (Crahan).
In 1962, after the Church had reached its nadir in Cuba, the Vatican appointed Msr. Cesare Zacchi to repair relations with the Cuban government. He recognized that “a redistribution of wealth” had effected “social justice” in Cuba and that unlike Eastern European governments’ persecution of the Church, “The Castro government has been very tolerant.” Over time—especially since 1969—relations between the Church and government have slowly improved.
Unlike Catholicism, “Santeria has always adapted to its socioeconomic surroundings,”2 an adaptability the government has recognized. In fact, to attract the hard currency it increasingly needs, the government has worked to make Santerian practices appealing to tourists, which has created some tension with practitioners who think tourist-oriented Santeria has reduced its “spiritual nature” to a collection of folkloric traditions. But in his fascinating account of this tension, Hearn clearly showed in 2005 that “religious organizations, particularly those that are able to establish connections with official institutions, currently enjoy a capacity for civil action unknown in Cuba for over four decades, or, in the case of Afro-Cuban religions, ever.”
Finally, since 1976, freedom of religious belief has been part of the Cuban constitution. As Kirk has demonstrated, although Castro was himself an atheist, he consistently advocated people’s right to have their own religious beliefs. In Fidel and Religion, Castro even said that American leftists made a “most serious mistake” in preaching atheism to the masses because they were “foreclosing the possibility between their political outlook and the masses.” When, in 2016, I asked random Cubans if they could worship freely, most looked at me as if I were living in a time warp.

[1] See John M. Kirk, Between God and Party (University of South Florida Press, 1989); any of Margaret E. Crahan’s works, especially “Cuba: Religion and Revolutionary Institutionalization” online at And, more recently, see Petra Kuivala’s 2019 PhD dissertation, online at



[2] Ibid.

[3] T. Jeremy Gunn.  “A Preliminary Response … .” Online at

[4] Lee Marsden, “International Religious Freedom and U.S. Foreign Policy,” May 21, 2020. Online at


[6] “Sphere Sovereignty of Religious Institutions: A Contemporary Calvinistic Theory of Church-State Relations,” Church Autonomy: A Comparative Survey (Gerhard Robbers, ed., Frankfurt am Main: Peter Lang, 2001).

[7] Gunn, Ibid.

[8] Ibid.

[9] Robert C. Blitt, “The Wolf Act Amendments …” University of Pennsylvania Journal of Law and Public Affairs January 2019, Vol 4, no. 2.

[10] Ibid.

[11] Ibid.

[12] Ibid.

[13] “A Cruel and Unusual Record,” New York Times, June 24, 2012. Online at

[14] Adrian H. Hearn, Cuba: Religion, Social Capital and Development (Duke University Press, 2008).

[15] American Atheist Magazine, Second Quarter, 2016.


[17] For a look at how other nations’ religious commissions have functioned, see Toft and Green, “Progress on Freedom of Religion or Belief? … .” Online at


In 2016, Congress passed the Frank R. Wolf International Religious Freedom Act, a.k.a. Public Law 114-281. Section 2 of the Act—an amendment to the International Religious Freedom Act (IRFA) of 1998—conveyed Congress’s “revised” view that “freedom of thought, conscience and religion is understood to protect theistic and non-theistic beliefs, and the right not to profess …