The bill amends the Anti‑Terrorism Act of 1987 to treat the Muslim Brotherhood as a terrorist organization, expands statutory findings linking Hamas to the Brotherhood, and extends existing prohibitions that formerly targeted the PLO to the Muslim Brotherhood. It adds mandatory immigration bars—including immediate revocation of visas—for people the President determines are Muslim Brotherhood members, and creates statutory definitions for “Muslim Brotherhood,” its branches, and members.
Separately, the bill requires the Secretary of State to deliver an annual, unclassified report (with a classified annex option) identifying Muslim Brotherhood branches worldwide and assessing whether each meets the criteria for designation under the Immigration and Nationality Act (INA) or Executive Order 13224. The President must impose FTO and SDGT sanctions on the Brotherhood and on branches identified in those reports within set deadlines, and may not lift sanctions on the Brotherhood for at least four years after a positive report determination.
The measures reallocate enforcement tools across State, Treasury/OFAC, DHS/consular, and the Executive Office, and create significant compliance and diplomatic consequences for organizations and individuals tied—even indirectly—to the Brotherhood.
At a Glance
What It Does
The bill amends existing anti‑terrorism law to add the Muslim Brotherhood to statutory findings, creates mandatory visa ineligibility and immediate visa‑revocation authorities for persons the President deems Muslim Brotherhood members, mandates annual State Department reporting on Brotherhood branches, and directs the President to impose FTO and Executive Order 13224 sanctions within specified timeframes.
Who It Affects
Federal agencies with counterterrorism, sanctions, and immigration responsibilities (State, Treasury/OFAC, DHS/consular services, DOJ) must implement new obligations; foreign entities and individuals identified as Brotherhood branches or members face visa bans and asset blocking; U.S. entities with foreign branches or partnerships in the listed jurisdictions face heightened compliance risk.
Why It Matters
It ties administrative designation, immigration, and sanctions authorities together in statute and sets calendarized deadlines and minimum sanction durations, reducing executive discretion. That makes this a structural change to how the U.S. would treat a transnational political‑religious movement and any entity the State Department lists as a branch.
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What This Bill Actually Does
The bill inserts the Muslim Brotherhood into the United States’ anti‑terrorism statutory framework by amending the Anti‑Terrorism Act of 1987. It expands the Act’s findings to assert organizational links between the Brotherhood and Hamas, and declares that the Brotherhood and its affiliates are terrorist organizations for purposes of the statute.
The amendments also expand the text of existing prohibitions that previously targeted the PLO to apply to the Brotherhood and its affiliates.
On immigration, the bill requires the Secretary of State to apply the sanctioning authorities set out in the Robert Levinson Hostage Recovery and Hostage‑Taking Accountability Act against any foreign person the President determines—on the basis of credible evidence—to be a Muslim Brotherhood member. Those measures include statutory inadmissibility and instructions for immediate visa revocation for affected individuals, creating a compulsory immigration bar rather than a discretionary tool.The bill defines key terms the statute will use going forward: “Muslim Brotherhood,” “Muslim Brotherhood branch,” and “Muslim Brotherhood member.” It names Hamas and Lajnat al‑Daawa al‑Islamiya as example branches and provides a long list of jurisdictions where such branches may operate, while also authorizing the Secretary of State to identify others.
It explicitly treats entities organized under U.S. law and foreign branches of U.S. entities as “United States person[s]” for purposes of the Act’s coverage.Finally, the bill imposes an operational cadence: within 90 days of enactment and annually thereafter, the Secretary of State must submit an unclassified report identifying Brotherhood branches and assessing whether each meets designation criteria under the INA or Executive Order 13224. The President must impose an FTO designation and SDGT (EO 13224) sanctions on the Brotherhood within 90 days of enactment, and must impose the same sanctions on any branch that the report identifies as meeting designation criteria within 30 days of that report.
For any branch finding, the President may not remove sanctions on the Brotherhood for at least four years after the report that produced the positive determination.
The Five Things You Need to Know
The bill amends the Anti‑Terrorism Act of 1987 to add the Muslim Brotherhood and its affiliates to the statute’s findings and to extend prohibitions previously limited to the PLO to the Brotherhood and its affiliates.
It creates a mandatory visa ineligibility and immediate visa‑revocation regime, requiring application of the Robert Levinson Act sanctions where the President determines, on credible evidence, an individual is a Muslim Brotherhood member.
The bill statutorily defines “Muslim Brotherhood branch,” explicitly names Hamas and Lajnat al‑Daawa al‑Islamiya as examples, and lists over two dozen countries where branches may operate while allowing the Secretary of State to add others.
The Secretary of State must submit an initial report within 90 days of enactment and then annually identifying Brotherhood branches and stating whether each meets the criteria for designation under INA section 219(a) or EO 13224; the President must impose sanctions on identified branches within 30 days of each report.
The President must impose FTO and EO 13224 sanctions on the Muslim Brotherhood within 90 days of enactment and may not remove sanctions from the Brotherhood for at least four years after a report produces a positive determination regarding a branch.
Section-by-Section Breakdown
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Short title
Gives the bill the official name “Muslim Brotherhood Terrorist Designation Act of 2025.” This is purely nominal but signals congressional intent to treat subsequent provisions as a focused, comprehensive effort to change statutory treatment of the Brotherhood.
Adds findings linking Brotherhood to Hamas and expands terrorist designations
This subsection inserts new enumerated findings into the Anti‑Terrorism Act of 1987 establishing that Hamas is a branch of the Muslim Brotherhood, cites National Counterterrorism Center language, and records past FTO/SDGT designations of Hamas and related violence. By embedding these findings in statute, the bill hardens the factual predicates that agencies and courts may reference when implementing later prohibitions and sanctions; it also creates a congressional record that can be cited in administrative determinations or litigation challenging designations.
Extends existing PLO prohibitions to the Muslim Brotherhood and adjusts termination language
The bill systematically replaces references to the PLO in the statute’s prohibition provisions with language that encompasses the PLO, the Muslim Brotherhood, and their affiliates. It also edits termination language to clarify that certain earlier termination provisions apply specifically to the PLO. These are drafting changes with operational impact: any statutory prohibitions, reporting requirements, or criminal consequences previously triggered for the PLO now similarly attach to the Brotherhood unless otherwise limited elsewhere in law.
Creates mandatory inadmissibility/visa‑revocation rules and defines covered terms
This provision requires the Secretary of State to apply the Robert Levinson Act’s sanctions framework to any foreign person the President finds is a Muslim Brotherhood member, including the statutory inadmissibility grounds and immediate visa revocation. It furnishes definitions for “Muslim Brotherhood,” “branch,” “member,” “foreign person,” and “United States person,” notably including explicit examples of branches and an extensive country list. Those definitions shape the statute’s reach—especially the broad “branch” and “member” formulations that can encompass indirect affiliation, control, or representation and that include entities with U.S. organization or foreign branches under the definition of U.S. persons.
Requires annual State Department branch inventory and forces FTO/EO13224 sanctions on identified entities
Section 3 mandates an initial State Department report within 90 days and annual reports thereafter that inventory Brotherhood branches and evaluate whether each meets INA FTO or EO 13224 criteria. It binds the President to impose FTO and SDGT sanctions on the Brotherhood within 90 days of enactment and to impose corresponding sanctions on branches that the reports identify—within 30 days of each report. The section also establishes a statutory four‑year minimum for keeping sanctions in place after a positive branch determination, and allows reports to include a classified annex. Operationally, this creates a recurring, calendarized duty for State and a fast‑moving compliance timeline for Treasury, DHS, and the Executive.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- U.S. national security and counterterrorism agencies (State, DOJ, intelligence community): the bill creates clearer statutory findings, recurring reporting, and mandated sanctioning timelines that streamline interagency authority and create a firmer legal basis for designations and investigations.
- Treasury/OFAC and sanctions enforcement units: the law compels use of existing blocking authorities (EO 13224) and ties those actions to statutory duties, giving OFAC firmer ground to freeze assets and impose transactional prohibitions.
- Allied governments that already outlaw the Brotherhood: countries that have banned the Brotherhood gain a U.S. statutory partner that formalizes similar policy and potentially eases intelligence sharing and coordinated enforcement efforts.
Who Bears the Cost
- Religious, political, and charitable organizations with historical or indirect ties to Brotherhood networks: the bill’s broad definitions of “branch” and “member” and the inclusion of entities operating in many jurisdictions raise risk of mistaken or collateral designations, increased compliance costs, and loss of banking or grant relationships.
- U.S. consular and DHS immigration operations: consular officers and DHS adjudicators will face heavier workloads and legal complexity applying the “credible evidence” standard and executing immediate visa revocations, with attendant litigation and administrative appeal spikes.
- U.S. universities, NGOs, and businesses with foreign affiliates: organizations with partnerships or research ties in the listed countries or with individuals named in a State Department report must reassess relationships, perform enhanced due diligence, and potentially sever connections to avoid secondary sanctions or asset blocks.
Key Issues
The Core Tension
The bill forces a trade‑off between maximizing security tools and preserving precision, due process, and diplomatic flexibility: it gives agencies mandatory, calendarized authorities to brand and sanction a broad, ideologically defined movement, but that same breadth creates legal uncertainty, risks collateral harm to lawful civil society and humanitarian activity, and reduces the executive branch’s ability to tailor responses as facts evolve.
The bill collapses multiple legal regimes—INA FTO designations, Executive‑order SDGT designations, and immigration inadmissibility—into a single statutory strategy targeted at a widely defined transnational movement. That approach raises legal and operational questions: FTO designation criteria under INA require showing an organization engages in terrorist activity and poses a threat to U.S. nationals; the Brotherhood, however, is a broad social‑political movement with civil‑society wings.
The statutory insertion of findings and the bill’s definitional sweep risk blurring the line between political or charitable activity and terrorist conduct, creating uncertainty for agencies tasked with making individualized determinations.
The immigration measures rest on a “credible evidence” standard for determining membership and require immediate visa revocation. That lowers the bar for administratively excluding or removing individuals relative to criminal conviction standards and could trigger litigation on due‑process, evidentiary, and overbreadth grounds.
The compelled timelines (90 days for initial sanctions, 30 days after reports for branches) and the four‑year minimum non‑removal period limit executive flexibility to calibrate sanctions in response to changing facts, potentially freezing U.S. policy options and complicating diplomatic engagement. Finally, the bill’s operational demands—annual global inventories, near‑automatic sanctions, and the option for a classified annex—will significantly increase workload and interagency coordination costs without specifying funding or procedural safeguards against wrongful designation or humanitarian disruption.
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