OFAC: Yemen Trade Not Banned

Following the designation of Ansarallah (commonly referred to as “the Houthis”) under E.O. 13224, as amended, on February 16, 2024, OFAC will add the group to the List of Specially Designated Nationals and Blocked Persons (SDN List) as a Specially Designated Global Terrorist.  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.  

Note that Yemen is not subject to jurisdiction-based sanctions, nor will it become subject to jurisdiction-based sanctions on February 16, 2024. 

In order to ensure that the humanitarian aid community and commercial actors can continue providing humanitarian aid and commercial goods in Yemen, on January 17, 2024, OFAC issued five general licenses (GLs) to authorize certain categories of transactions, including:  (1) agriculture, medicine, and medical devices; (2) telecommunications mail, and certain internet communications;(3) personal remittances; (4) refined petroleum products (including fuel); and (5) operation and use of ports and airports for import of goods.  These GLs will take effect on February 16, 2024, the same date on which the designation will take effect. 

The above GLs supplement broad preexisting humanitarian GLs in the Global Terrorism Sanctions Regulations (GTSR) covering the United States government, certain international organizations and entities, nongovernmental organizations (NGOs), and for the provision of food, other agricultural commodities, medicine, and medical devices. 

For more information on these baseline humanitarian general licenses, please consult OFAC’s  Supplemental Guidance for the Provision of Humanitarian Assistance, and FAQs 1105, 1106, 1107, and 1108.  Other humanitarian-related guidance documents are available in the NGO section of OFAC’s Information for Industry Groups webpage.  OFAC also intends to issue further public guidance specifically related to the Ansarallah designation on or before February 16, 2024.

Non-U.S. persons may engage in or facilitate transactions for which a U.S. person would not require a specific license pursuant to the GTSR without exposure to sanctions under the GTSR or E.O. 13224, as amended.

[State Dept Statement]