The United States and United Nations Issue Sanctions for Houthi (Ansarallah in Yemen) Leaders

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On March 2, 2021, the U.S. Department of the Treasury’s Office of Asset Controls (OFAC) imposed sanctions on two key militant leaders of the Iranian-backed Ansarallah, also known as the Houthis. OFAC sanctions target Mansur Al-Sa’adi, Houthi naval forces chief of staff, and Ahmad ‘Ali Ahsan al-Hamzi, commander of Houthi air force and air defense forces.

On February 16, 2021, the Biden administration revoked a former Trump administration designation of the Ansarallah (Houthis), but decided to keep three Ansarallah leaders, Abdul Malik al-Houthi, Abd al-Khaliq Badr al-Din al-Houthi and Abdullah Yahya al Hakim, as Specially Designated Global Terrorists (SDGTs). Secretary of State Anthony Blinkin said that the sanctions on the Ansarallah (Houthi) group were revoked “… to ensure that relevant U.S. policies do not impede assistance to those already suffering what has been called the world’s worst humanitarian crisis.”

U.N. Security Council Sanctions Houthi Leader
On February 25, 2021, the United Nations Security Council imposed sanctions on Sultan Saleh Aida Aida Zabin, a Houthi police director in Sanaa. The Security Council cited Sultan Saleh Aida Aida Zabin’s direct involvement in torture, sexual violence and rape.

Impact of the Sanctions
The designation of Al-Sa’adi and al-Hamzi are made under Executive Order 13611. As a result of the designations, their property and interests in property must be blocked where U.S. jurisdiction applies, including entities in which they have an ownership interest of 50 percent or more. The designation also bans them from entering into the United States.

U.S. law asserts jurisdiction for sanctions purposes (a) over U.S. persons anywhere they are located; (b) activity by any person taking place in the United States; (c) property in the United States; and (d) U.S. dollar transactions initiated anywhere in the world that clear through the U.S. financial system. In addition, facilitation by a U.S. person for from the United States of activity by non-U.S. persons that would be prohibited for a U.S. person would violate applicable sanctions laws. Finally, attempt and conspiracy to engage in any of the activities described above, evasion or avoidance of the law, and causing a violation by a U.S. person are prohibited.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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