We calculate the E1 breakup of the 2n halo nucleus 11Li in halo effective field theory (Halo EFT) at leading order. In Halo EFT, 11Li is treated as a three-body system of a 9Li core and two neutrons. We present a detailed investigation of final-state interactions (FSIs) in the neutron-neutron (nn) and neutron-core (nc) channels. We employ Møller operators to formulate an expansion scheme that satisfies the non-energy-weighted cluster sum rule and successively includes higher-order terms in the multiple-scattering series for the FSI. Computing the E1 strength up to third order in this scheme, we observe apparent convergence and good agreement with experiment. The neutron-neutron FSI is by far the most important contribution and largely determines the maximum value of the E1 distribution. However, inclusion of nc FSI does shift the peak position to slightly lower energies. Moreover, we investigate the sensitivity of the E1 response to the spin structure of the neutron-9Li interaction. We contrast results for an interaction that is the same in the spin-1 and spin-2 channels with one that is only operative in the spin-2 channel, and find that good agreement with experimental data is only obtained if the interaction is present in both spin channels. The latter case is shown to be equivalent to a calculation in which the spin of 9Li is neglected.