Washington’s Brotherhood designations have moved seven times since November; Congress has not moved once

Executive Order 14362, signed 24 November 2025 and published at Federal Register Vol. 90, No. 227, p. 55033, is titled “Designation of Certain Muslim Brotherhood Chapters as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” The drafting matters: it designates chapters, not the organisation. On 13 January 2026 the State Department listed the Lebanese Muslim Brotherhood as an FTO and SDGT along with its secretary general, Muhammad Fawzi Taqqosh, describing the action as “a first step”; the same day Treasury designated the Egyptian and Jordanian branches as SDGTs under E.O. 13224, calling these “the first actions of an ongoing, sustained effort.” State designated the Sudanese Muslim Brotherhood on 9 March. Treasury followed on 19 May against flotilla organisers and Brotherhood networks, and again on 23 July, when OFAC designated one senior Egyptian Brotherhood official, three further individuals and three entities — two of them described as sham charities funnelling money to Hamas’s military wing.

The legislative track has produced nothing comparable. S.2293, the Muslim Brotherhood Terrorist Designation Act of 2025, and H.R.3883, the Muslim Brotherhood Is a Terrorist Organization Act of 2025, would require the Secretary of State to designate the Brotherhood as a whole. H.R.4397, introduced by Rep. Mario Díaz-Balart on 15 July 2025, was referred to the House Foreign Affairs Committee and its status record was last updated 7 May 2026 — still in committee, thirteen months on. Treasury Secretary Scott Bessent framed the July action in terms that make no distinction between branches: “Whether operating under the guise of charities, businesses, or underground financial networks, those who enable Hamas will be exposed, sanctioned, and held accountable.” The Foundation for Defense of Democracies, a think tank that advocates designation, updated its Brotherhood page on 12 August to say Washington is “now taking the fight to the group’s support infrastructure.”

Assessment: The chapter-by-chapter design is not a compromise, it is the point. Designating branches lets the executive act at the speed of an OFAC memo while leaving the legal question of what the Brotherhood is unresolved — and unresolved is useful, because each new tranche can extend the category without ever defining it. Congress’s paralysis is the tell: a blanket designation would face litigation and allied resistance, so nobody forces the vote. Watch for the July tranche’s named senior official, reported as UK-resident. If that holds up against the OFAC entry itself, Washington has put a designated Brotherhood financier inside a jurisdiction that has never designated the organisation, and the next fight is over Britain, not Cairo.