On January 17, 2024, the US Department of the Treasury (“Treasury”) Office of Foreign Assets Control (“OFAC”) announced the re-addition of Ansarallah, better known as the Houthis, to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) as a Specially Designated Global Terrorist, just shy of three years after delisting the group to alleviate the ongoing humanitarian crisis in Yemen.
Additionally, OFAC announced the issuance of Counter Terrorism General Licenses (“GLs”) 22-26 related to the designation. The re-addition of Ansarallah to the SDN List follows months of attacks on US military forces and international maritime vessels in the Gulf of Aden. As a result of the designation, transactions by U.S. persons or within (or transiting) the United States involving Ansarallah will be blocked, unless they are otherwise authorized, including by way of General License.
OFAC specifically issued the following General Licenses to allow for:
- General License 22 regarding “Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates Involving Ansarallah;”
- General License 23, regarding “Authorizing Transactions Related to Telecommunications Mail, and Certain Internet-Based Communications Involving Ansarallah;”
- General License 24, regarding “Authorizing Noncommercial, Personal Remittances Involving Ansarallah;”
- General License 25, regarding “Authorizing Transactions Related to Refined Petroleum Products in Yemen Involving Ansarallah;”
- and General License 26, regarding “Authorizing Certain Transactions Necessary to Port and Airport Operations Involving Ansarallah.”
These GLs and the reclassification of Ansarallah as a Specially Designated Global Terrorist will enter into force on February 16, 2024. In the meantime, US Secretary of State Antony Blinken has announced that the US government will be conducting significant stakeholder outreach efforts to ensure the ability of humanitarian assistance and the commercial import of critical commodities to reach Yemeni civilians. OFAC has also issued guidance in the form of an FAQ to clarify that Yemen is not subject to jurisdiction-based sanctions, nor will it become subject to jurisdiction-based sanctions on February 16. OFAC will also continue to provide updated guidance regarding its Ansarallah designation before February 16.
Crowell & Moring, LLP will continue to monitor for U.S. sanctions updates.