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 the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a “DC Rising Star” (2019), by Who’s Who Legal: Investigations as a “Future Leader” (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the “40 under 40” in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).