Eight months into the US designation campaign, the test now sits with a British bank

Executive Order 14362, signed 24 November 2025, directed the designation of Muslim Brotherhood chapters in Lebanon, Jordan and Egypt as Foreign Terrorist Organizations and Specially Designated Global Terrorists. State and Treasury executed those three on 13 January 2026, listing the Egyptian Brotherhood as an SDGT under Executive Order 13224 and the Global Terrorism Sanctions Regulations for material support to Hamas, with the blocking reaching any entity the organisation owns 50 percent or more. The Sudanese Muslim Brotherhood followed on 9 March. On 23 July Treasury designated Mahmoud al-Abyari, a UK-based figure it described as Secretary General of the Muslim Brotherhood General Secretariat, alongside further individuals and entities resident outside Egypt. Treasury said the action “exposes a multi-layered typology in which Muslim Brotherhood affiliates and Hamas-directed front organizations operate transnational fundraising channels, using charitable facades and underground banking networks,” and that al-Abyari “supported the fundraising for” Filistin Vakfi and Hayat Yolu, both previously sanctioned over Hamas ties.

The architecture is now larger than the reporting on it. Treasury’s July release says the action builds on earlier Brotherhood and Hamas measures of 21 January and 12 March, which puts at least five distinct OFAC touchpoints on this file in 2026. The headcount for July itself does not reconcile: the State Department release counts a senior UK-based Egyptian Brotherhood official plus three individuals and three entities; The National, reporting the same action from Abu Dhabi, counts an official, three other people and two companies. The only OFAC document falling inside the past week is an action of 24 August published in the Federal Register on 28 August as FR Doc 2026-17613 at printed page 55672, which blocks property, identifies vessels as blocked property and updates one existing listing. Vessels point to shipping-linked programmes rather than this file. The Files has not read the names and is not calling it a Brotherhood action.

The American domestic track has run ahead of the federal one in places. Texas Governor Greg Abbott has designated both the Muslim Brotherhood and the Council on American-Islamic Relations as foreign terrorist organizations and transnational criminal organizations, barring them from purchasing or acquiring land in the state; the two groups have “long made their goals clear,” his office said, and their actions “to support terrorism across the globe and subvert our laws through violence, intimidation, and harassment are unacceptable.” Foreign terrorist designation is a federal power under section 219 of the Immigration and Nationality Act, and we have found no litigation reporting testing the state measure either way. Three designation bills remain pending in the 119th Congress: S.2293, H.R.3883 and H.R.4397. A Senate Judiciary subcommittee proceeding on Brotherhood networks in America, noticed for 20 May, was postponed and its subsequent status is unclear.

Assessment: Designation is cheap; enforcement is expensive and it happens in other people’s jurisdictions. A US listing has no direct legal force in Britain, and the interesting question about al-Abyari is not what Treasury said in July but whether OFSI, the Home Office, the Charity Commission or a compliance officer at a British bank has done anything since. That is unanswered. The count discrepancy between State and The National on a single action is the tell: this architecture is being built faster than it is being read, and much of the secondary coverage repeats totals nobody has checked against the SDN list. Treat the vessels notice as unrelated until someone opens the file.