Peloni: The attempt to take on the Muslim Brotherhood in a piece-wise fashion defies the need to recognize that the ideological intent of this Jihadist movement is intended to consume the West, and not just those chapters which the US administration has deemed unacceptable.
Mark Dubowitz & Matiam Wahba | Nov 24, 2025
After weeks of hinting that a major policy shift was imminent, President Donald Trump signed an Executive Order (EO) on November 24 directing the State and Treasury Departments to begin the process of designating components of the Muslim Brotherhood as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs).
In doing so, the Trump administration has settled a long debate about how to best tackle the ever-growing Islamist movement, avoiding the structural mistakes that derailed previous U.S. efforts to target the Brotherhood.
For years, Washington has been divided over how to confront it. One side has pushed for a sweeping, movement-wide designation, treating the organization as a single, monolithic entity. The other has argued for a targeted, branch-based strategy, blacklisting individual arms of the Brotherhood that cross the line from extremism into terrorism. The EO embraces the latter strategy, focusing on a designation framework that can withstand judicial scrutiny and streamline enforcement.
For decades, the Brotherhood has portrayed itself as a unified global movement. That narrative has always overstated the degree of central authority, but it is particularly outdated today. The modern Brotherhood is a sprawling network of national branches, ideological allies, and autonomous affiliates that share a historical lineage but not a unified chain of command. Some branches engage in domestic politics, others maintain armed wings, and many operate in the gray zone between activism and militancy.
This fragmentation is neither incidental nor recent. It is a defining feature of the Brotherhood, and grasping it is essential for U.S. policymakers seeking to confront the threats the movement poses.
Under U.S. law, an FTO designation requires meeting three clear standards: the organization must be foreign; it must engage in or retain the capability and intent to engage in terrorism; and its activities must threaten U.S. nationals or the national security of the United States. These statutory criteria, set out in Section 219 of the Immigration and Nationality Act, are intentionally rigorous. They exist to ensure that designations target actual threats rather than broad, loosely affiliated ideological networks.
This legal and organizational reality explains why previous attempts to designate the Brotherhood failed. Washington could not point to a central headquarters, a single leadership structure, or an unbroken chain of operational control. Attempts in 2015 and during the first Trump administration stalled for exactly these reasons.
The case of Hamas, the Brotherhood’s Gaza branch, illustrates the logic of a branch-based strategy. The United States designated Hamas in 1997 following a sustained campaign of terrorist attacks. That designation focused on the branch that met the legal threshold while leaving other parts of the network to be assessed individually. The new EO establishes a permanent interagency process to extend this framework to additional Brotherhood branches that independently meet the criteria for FTO or SDGT status.
This framework offers several advantages. First, it enables immediate action against the most dangerous Brotherhood branches, including those directly engaged in terrorism or armed conflict and the media and financial ecosystems that enable them. Second, it allows for disciplined sequencing. Designations would build outward from the clearest cases, insulating the process from the evidentiary vulnerabilities that have undermined past attempts. Third, it preserves the integrity of U.S. counterterrorism authorities by ensuring that FTO and SDGT tools are applied to organizations that genuinely meet the legal standard rather than to an amorphous ideological movement. Fourth, it avoids sweeping in political actors whose activities, while objectionable or illiberal, do not rise to the level of terrorism and the designation of which would not withstand judicial review. Finally, it facilitates coordination with allies, many of whom have already designated specific Brotherhood-linked groups but have avoided movement-wide bans for the same legal reasons that constrain the United States.
While the EO formally identifies the first three branches targeted — those in Egypt, Jordan, and Lebanon — other branches of the Brotherhood could also meet the criteria for future review. Yemen’s Al-Islah Party, long presented as a political organization, includes senior figures with deep ties to al-Qaeda and maintains armed elements accused of collaborating with a U.S.-designated FTO, the Houthis. In addition to these, other Brotherhood-linked entities, like its many media outlets, may also warrant attention as evidence accumulates. By starting with the three named chapters, the administration establishes a framework that can expand methodically to include additional branches and affiliates that independently satisfy the statutory thresholds for FTO or SDGT designation.
These examples underscore why the United States must abandon the fiction of a unified Muslim Brotherhood and adopt a structure that reflects operational reality. A movement-wide designation would collapse dozens of disparate actors into a single entity that does not exist in practice and cannot be demonstrated in court. A branch-based approach allows Washington to apply pressure methodically, build cases sequentially, and pursue a long-term counterterrorism campaign focused on enforcement.
The central task is now execution. State and Treasury must compile evidentiary records, pursue designations sequentially, and maintain the discipline that has eluded previous efforts. A sustainable U.S. strategy requires recognizing that the Brotherhood is not one organization but a network of branches, some of which unquestionably meet the statutory thresholds for FTO or SDGT status. The challenge is to target those branches directly and systematically, without collapsing the entire ecosystem into an unworkable abstraction.
That is the strategy the administration has now embraced, and it is the strategy that can succeed where earlier efforts failed.
Mark Dubowitz is the chief executive of the Foundation for Defense of Democracies (FDD), where Mariam Wahba is a research analyst. Follow Mark on X @mdubowitz and Mariam on X @themariamwahba.
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