Less than three weeks after the group’s initial addition to the list of Foreign Terrorist Organizations, the Biden administration removed Ansarallah (the Houthis in Yemen) from the list on February 16, 2021.  As a result, Ansarallah is no longer blocked pursuant to OFAC’s Global Terrorism Sanctions Regulations and U.S. persons do not require authorization from OFAC to engage in activities or transactions with Ansarallah. Simultaneously, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) removed five general licenses and three frequently asked questions from its website, given that they are no longer necessary.

The reversal comes shortly after the initial designation of the group on the last full day of the Trump Administration.  Ansarallah, a political movement and militia group in Yemen, have controlled the government in Yemen since 2015.  A protracted civil war has been ongoing since that time.  The designation was met with concern from the United Nations and other international aid organizations that were concerned it would greatly reduce the supply of Yemen’s food and other essential goods, which is nearly all imported, at a time when Yemen is facing imminent danger of famine.  The State Department noted that the lifting of the designation was not acceptance of the group’s conduct but a recognition of the dire humanitarian needs facing Yemen.

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Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice…

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice covers compliance with U.S. economic sanctions, export controls and antiboycott regimes, and anti-money laundering (AML) laws and regulations. He is experienced in providing day-to-day compliance guidance, developing compliance programs including through on-site compliance trainings, responding to government inquiries, conducting internal investigations, representing them during civil and criminal enforcement proceedings, and, in collaboration with colleagues, managing the potential conflict of laws that can arise from the interaction between extraterritorial impacts of U.S. regulations and third country “blocking” laws or data privacy regulations. Dj splits his time between Washington and London, working regularly with European clients and colleagues to provide coordinated guidance on U.S., U.K., and EU sanctions compliance and enforcement. Dj also has extensive experience in international mergers and acquisitions, advising both buyers and sellers regarding the international trade implications of a potential deal.