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.

The full text of today’s announcement can be found here, and National Security Advisor Jake Sullivan’s comments on the matter can be found here.

Crowell & Moring, LLP will continue to monitor for U.S. sanctions updates.

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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 C&M International, the firm’s trade policy affiliate.

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

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David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with C&M International, 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).

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Andrew J. Schlegel

Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

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Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Andrew also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Prior to joining Crowell & Moring, Andrew worked as an intern at SAP’s Government Affairs Business Development Team in Berlin, Germany. There, he analyzed the effects of regulatory changes on SAP business operations and expansion opportunities. Before this, he completed an internship at the International Trade Administration’s Office of Energy and Environmental Industries. While there, he developed the U.S. Energy Trade Dashboard, an interactive data visualization tool for use by professionals and researchers to analyze how energy supply chains have developed.

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