US Sanctions on Mahmoud El-Ebiary: A Compliance Wake-Up Call for European Business

On July 22, 2026, the US Treasury Department's Office of Foreign Assets Control (OFAC) imposed US sanctions on Mahmoud El-Ebiary, a UK-based senior Muslim Brotherhood leader who serves as Secretary General of the organization's General Secretariat . These sanctions target not just one individual but three individuals and three entities — including a company in Indonesia, a charity in Gaza, and a commercial firm in Turkey — accused of providing material support to Hamas . The question arises: What do these sanctions mean for European companies, banks, and law firms, and how can they protect themselves from financial and legal risks?

Background: Understanding the Sanctions

According to the US Treasury Department, El-Ebiary has a "long history of senior leadership roles" within the Muslim Brotherhood and allegedly supported fundraising for institutions already sanctioned for ties to Hamas . The sanctions were imposed under Executive Order 13224, the US government's primary counterterrorism authority .

Analysis: Compliance Challenges for European Companies

How do US sanctions on Mahmoud El-Ebiary affect European companies? The answer lies in OFAC's regulatory framework. All assets of designated individuals within US jurisdiction are frozen, and US citizens and companies are prohibited from any transactions with them.

But European companies that conduct transactions in US dollars or use the US financial system also fall within OFAC's reach. OFAC's "50 Percent Rule" states that any entity owned 50% or more by one or more designated persons is automatically blocked — even if not named on the SDN List .

What is OFAC's 50 Percent Rule and how does it affect European entities? This rule forces European companies to examine the ownership structures of their business partners. If a company does business with an entity that is indirectly 50% or more owned by a designated person, it could itself be violating sanctions .

Secondary Sanctions: The Greatest Risk

What is the impact of secondary sanctions on European businesses? OFAC has explicitly warned that foreign financial institutions that facilitate significant transactions for designated individuals or entities may face secondary sanctions.

This means a European bank that processes transactions for Mahmoud El-Ebiary or his affiliated entities could lose access to the US financial system — a potentially devastating blow. This risk is so significant that many European banks now apply US sanctions standards to their entire international operations, even when EU law doesn't require it.

As one analysis noted, "A European institution cannot safely assume that lack of U.S. incorporation protects it from sanctions consequences when it knowingly conducts significant transactions with sanctioned terrorist actors".

The UK and Austria Connection: A Special Case

El-Ebiary's UK residence and Austrian citizenship add complexity to this case. What are the implications of US sanctions for the Muslim Brotherhood network in the UK? This question is critical because Washington has targeted a person operating from British soil, putting pressure on UK authorities to examine Muslim Brotherhood-linked activities within their jurisdiction .

Similarly, El-Ebiary's Austrian citizenship means Austrian and other European financial institutions must examine whether they hold any accounts, assets, or business relationships connected to him .

Compliance Strategies for European Firms

How can European firms avoid doing business with designated individuals? The first step is regular screening against the SDN List. But this isn't enough — companies must also examine the ownership structures of their business partners, including beneficial ownership, directors, and banking relationships .

Key compliance measures include:

Regular SDN List screening of all customers, partners, and counterparties

Enhanced due diligence on complex ownership structures

Review of existing business relationships for indirect sanctions exposure

Implementation of secondary sanctions risk assessments

Clear contractual provisions requiring partners to disclose sanctions exposure

Conclusion: The New Reality of Sanctions Compliance

This is why European companies must now reassess their compliance strategies. SDN List screening, examination of international partner ownership structures, and understanding secondary sanctions risks are no longer optional. If this trend continues, additional sanctions may be imposed in the future, potentially causing severe financial and legal damage to European businesses.

Frequently Asked Questions

How do US sanctions on Mahmoud El-Ebiary affect European companies?

European companies that transact in US dollars or use the US financial system must avoid any dealings with designated individuals or affiliated entities. Secondary sanctions risks also apply to financial institutions facilitating transactions for sanctioned parties.

What is OFAC's 50 Percent Rule and how does it affect European entities?

The rule states that any entity owned 50% or more by one or more designated persons is automatically considered blocked, even if not named on the SDN List. European companies must examine the ownership structures of their business partners to ensure compliance .

What is the impact of secondary sanctions on European businesses?

Secondary sanctions allow the US to target foreign financial institutions that facilitate significant transactions for designated individuals. Penalties can include loss of access to the US financial system, which can be devastating for European banks and businesses .

Will the EU designate the Muslim Brotherhood as a terrorist organization?

The French National Assembly passed a resolution in January 2026 calling on the EU to list the Muslim Brotherhood as a terrorist organization. The European Parliament has also seen motions on this issue. If approved, European companies would face additional compliance requirements.