Executive Order 14362 and the Expanding Front of Terrorism Designations

Executive Order 14362, issued on November 24, 2025, represents a significant escalation in the United States’ efforts to counter terrorism networks operating across the Middle East. While the Muslim Brotherhood is not being designated wholesale as a terrorist organization, the order initiates an accelerated process to identify and potentially designate specific chapters in Lebanon, Egypt, and Jordan as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The order cites the involvement of certain Brotherhood-linked groups in violence following the October 7, 2023 attacks on Israel and longstanding ties between Brotherhood leaders and militant wings of Hamas. This shift carries major implications for U.S. counterterrorism strategy, regional diplomacy, immigration enforcement, and transnational financial networks.

The Muslim Brotherhood has functioned for nearly a century as a decentralized movement with both political and militant offshoots. Founded in Egypt in 1928, it inspired chapters across the Middle East, some of which became integral parts of local political systems. Others developed military wings or clandestine operations that have intersected with global jihadist movements. The U.S. government has periodically evaluated the Brotherhood’s activities since the early 2000s, but has historically distinguished between political factions and groups actively engaged in terrorism. Recent intelligence assessments, however, indicate increasing collaboration between certain Brotherhood-linked entities and designated terrorist organizations, especially during periods of regional conflict. Public reporting has documented the participation of Brotherhood-aligned fighters in rocket attacks launched from Lebanon following the October 7 attacks in Israel, as well as leaders in Egypt and Jordan calling for support to Hamas.

Executive Order 14362 sets a strict timeline requiring the Departments of State and Treasury, along with the Attorney General and the Director of National Intelligence, to provide a formal designation report within 30 days. Within 45 days after that report is delivered, the government must take appropriate action consistent with U.S. terrorism laws. This structure signals a near certainty that at least some Brotherhood chapters will be designated. Historically, when similar orders have been issued—such as Executive Order 13224, used after the September 11 attacks—designation processes have moved quickly once interagency reviews conclude.

Designation would have immediate operational consequences. Under 8 U.S.C. 1189 and the International Emergency Economic Powers Act, all assets of designated groups under U.S. jurisdiction would be frozen, and U.S. persons would be prohibited from engaging in financial dealings with them. The material support statute, 18 U.S.C. 2339B, would expose individuals or organizations to criminal liability for providing funds, services, training, or any tangible assistance. Past designations of groups such as Hamas and Hezbollah dramatically constrained their international fundraising and disrupted support networks abroad. A similar effect would be expected here, particularly for Brotherhood chapters accused of facilitating Hamas financing.

Law enforcement and intelligence agencies would also gain expanded tools. An FTO or SDGT designation enables broader surveillance authorities, tighter monitoring of financial institutions, enhanced subpoena powers, and expanded information-sharing with foreign partners. Historically, these tools have allowed the FBI, Treasury Department, and Department of Homeland Security to map transnational networks more effectively, particularly those that operate through charitable fronts or diaspora communities. With many Muslim Brotherhood-affiliated organizations operating across borders, enhanced investigative capacity could reshape counterterrorism enforcement domestically.

The immigration consequences would be equally significant. Members of designated groups would be inadmissible to the United States, and those already residing in the U.S. could face removal proceedings. Prior cases involving Hezbollah, Islamic Jihad, and other designated groups show that DHS frequently reopens immigration files and conducts additional vetting when new designations occur. Asylum claims involving Brotherhood-affiliated applicants would also be reevaluated, and the federal courts have historically upheld the government’s authority to deny immigration benefits on terrorism-related grounds.

Regional implications may be substantial. Egypt has long designated the Muslim Brotherhood as a terrorist organization and is likely to welcome U.S. alignment with its stance. Jordan, however, maintains a sensitive political balance with its Brotherhood-affiliated political party, and U.S. action could complicate domestic dynamics in Amman. Lebanon’s security environment is already volatile, and designating Brotherhood-linked militants there may intersect with broader counter-Hezbollah policy. Additionally, the order reinforces U.S. counterterrorism coordination with Israel, particularly following the heightened security concerns after October 7.

Critics warn that the designations could increase anti-American sentiment, fuel regional instability, or drive Brotherhood factions underground. Academic experts have noted that in some countries, Brotherhood parties function within parliamentary systems, and lumping political activity together with militant activity could complicate diplomatic relationships. Civil liberties organizations in the United States may also raise concerns about overbreadth or potential chilling effects on domestic Muslim communities, although the EO explicitly targets foreign chapters, not U.S.-based organizations.

In a counterterrorism context, however, the order reflects growing bipartisan concern over transnational networks that support Hamas and other militant entities. U.S. strategy in recent years has increasingly emphasized disrupting financial conduits, diaspora-linked networks, and ideological organizations that serve as force multipliers for designated groups. Executive Order 14362 positions the United States to widen the scope of its counterterrorism posture in a region already undergoing dramatic shifts.

Executive Order 14362 marks a decisive moment in U.S. counterterrorism policy. By initiating the designation process for select Muslim Brotherhood chapters, the U.S. is signaling a willingness to expand its terrorism framework to target supporters of Hamas and other militant groups more aggressively. The effects will be far-reaching, touching international finance, domestic law enforcement, regional diplomacy, and immigration. Whether the order will stabilize or further complicate Middle East dynamics remains to be seen, but its impact on U.S. counterterrorism operations will be immediate and significant.

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References

Byman, D. (2015). Al Qaeda, the Islamic State, and the global jihadist movement. Oxford University Press.

Gambhir, H. (2014). The Islamic State’s global propaganda strategy. Institute for the Study of War.

International Crisis Group. (2019). How the Muslim Brotherhood operates in the Middle East.

Levitt, M. (2006). Hamas: Politics, charity, and terrorism in the service of jihad. Yale University Press.

U.S. Congress. (1996). Antiterrorism and Effective Death Penalty Act, 18 U.S.C. § 2339B.

U.S. Department of State. (2023). Country Reports on Terrorism.

U.S. Government. (2025). Executive Order 14362, Designation of Certain Muslim Brotherhood Chapters as Foreign Terrorist Organizations and Specially Designated Global Terrorists.

Source: http://terrorism-online.blogspot.com/2025/11/executive-order-14362-and-expanding.html