On January 17, 2024, the U.S. Department of State announced the redesignation of the Yemen-based Ansarallah (commonly referred to as the “Houthis”) as a Specially Designated Global Terrorist organization (SDGT). The decision to redesignate Ansarallah comes after several months of attacks by Houthi forces against international maritime vessels in both the Red Sea and Gulf of Aden.

The redesignation pursuant to Executive Order 13224 prohibits all transactions and services with the Houthi organization and its members and blocks their property and interests in property, including entities in which Ansarallah has 50 percent or more ownership. Yemen as country and Yemeni nationals are not sanctioned as a result of the U.S. action, but the Houthi control of and governmental role in large parts of Yemen will create sanctions compliance challenges in relation to business with Yemen.

On February 16, 2021, the Biden Administration revoked the Houthi’s designation as a Foreign Terrorist Organization (FTO) and a SDGT citing the “dire humanitarian situation in Yemen.” Announcing the relisting, the State Department explained that, since November 2023, the Houthis have endangered mariners, disrupted the free flow of commerce, and interfered with navigational rights and freedoms.

The designation includes several “robust humanitarian carveouts” to mitigate the impact on the Yemeni people. Specifically, the Office of Foreign Assets Control (“OFAC”) has issued:

• General License 22, authorizing the provision or sale of certain agricultural products (including food), medicines, and medical devices.
• General License 23, authorizing transactions for services, software, hardware or technology incident to certain internet- or cloud-based messaging or communications platforms and services.
• General License 24, authorizing transactions ordinarily incident and necessary to the transfer of personal, noncommercial funds to or from individuals in Yemen, provided the person is not otherwise blocked.
• General License 25, authorizing transactions ordinarily incident and necessary to the provision of refined petroleum products for personal, commercial, or humanitarian use in Yemen.
• General License 26, authorizing transactions ordinarily incident and necessary to the operation of, or import or export of goods or transit of passengers through, ports and airports in Yemen.

The renewed designation and associated general licenses will go into effect on February 16, 2024.

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