Ten months after Trump’s order, the Brotherhood designation file is still mostly paper

President Trump signed Executive Order 14362, “Designation of Certain Muslim Brotherhood Chapters as Foreign Terrorist Organizations and Specially Designated Global Terrorists,” on 24 November 2025; it was published in the Federal Register four days later. The order directs Secretary of State Marco Rubio and Treasury Secretary Scott Bessent to determine whether any chapters warrant designation. As the Charity & Security Network, an NGO critical of the measure, points out, “despite the title, the Executive Order does not designate any person or group” — a reading of the text that is legally correct. On 13 January 2026 State designated the Lebanese, Jordanian and Egyptian chapters, calling it “a first step in support of President Trump’s commitment to eliminate the capabilities and operations of Muslim Brotherhood chapters that pose a threat to the United States as described in Executive Order 14362.” On 9 March the Sudanese Muslim Brotherhood was designated SDGT, with FTO designation intended to take effect on 16 March.

The Sudan release carries the file’s only large number: State says the Sudanese Muslim Brotherhood, which it describes as the Sudanese Islamic Movement and its armed wing, the al-Baraa Bin Malik Brigade, “has contributed upwards of 20,000 fighters to the war in Sudan, many receiving training and other support from Iran’s Islamic Revolutionary Guard Corps.” That is a government assertion, not an independently verified count. On 23 July, Treasury designated a senior Egyptian Muslim Brotherhood official alongside three individuals and three entities providing material support to Hamas, two of them described as sham charities that funnelled money to Hamas’s military wing. On 5 August the Senate Judiciary Committee heard testimony under the title “Hidden in Plain Sight: Confronting the Muslim Brotherhood Network in America.” The two designation bills before Congress, S.2293 and H.R.3883, have not been shown to have moved.

Assessment: The distinction that matters is between the SDGT listings, which block property under Executive Order 13224, and the FTO designations, which State’s January language hedged and which we have not confirmed took legal effect. Until the Federal Register says otherwise, part of this architecture remains an intent to designate. Treat State’s 20,000-fighter estimate as a claim by an interested party. The more consequential point is downstream: European and American state-level campaigners now cite Washington’s designations as settled precedent, at a moment when the precedent’s own legal foundation has not been publicly audited. We could not audit it either. That gap is the story.