On February 16, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) removed Ansarallah, a political movement and militia group in Yemen also known as the Houthis, from the Specially Designated Nationals and Blocked Persons List (“SDN List”). Ansarallah had been added to the SDN List on January 19, 2021, as a Foreign Terrorist Organization (“FTO”) and Specially Designated Global Terrorist (“SDGT”). As a result of the removal, US Persons no longer require authorization from OFAC to engage in transactions or activities with Ansarallah, which broadly controls the northern part of Yemen, provided such activities do not involve blocked persons or otherwise prohibited activities.

OFAC also revoked a series of general licenses that had been issued following Ansarallah’s designation on the SDN List on January 19, as they are no longer needed. Three Ansarallah leaders who were designated as SDGTs at the same time as Ansarallah also had their SDGT designations removed, but they remain designated on the SDN List under other sanctions programs.

Please see also our prior blog post on the Trump Administration’s designation of Ansarallah as an SDN, the prior general licenses and FAQs, and the Biden Administration’s issuance of a general license temporarily authorizing most transactions with Ansarallah.

Author

Janet Kim focuses on outbound trade compliance issues that arise under US economic sanctions, export control laws, investment restrictions, antiboycott regulations, anti-money laundering laws and the Foreign Corrupt Practices Act. She represents and advises US and non-US companies in criminal and regulatory proceedings, internal investigations, and compliance audits relating to these areas of law. She also advises on the extraterritorial application of these laws in cross-border transactions, including mergers and acquisitions, joint venture arrangements, and other international commercial activities. Her practice includes the development and implementation of workable, risk-based internal compliance programs and procedures for companies in a wide range of industries. Janet currently serves on the Steering Committee of the Firm’s International Commercial Practice Group and has been with the Washington, DC office since 1994.

Author

Author

Daniel Andreeff is an associate in the Firm’s International Trade practice group in Washington, DC. Prior to joining the Firm, he interned with the Department of the Treasury’s Office of Foreign Assets Control.