On January 19, 2021, the Department of the Treasury’s Office of Foreign Assets Control issued four Yemen-related general licenses (GLs 9-12) and three frequently asked questions to confirm the US commitment to provide humanitarian assistance to the Yemeni people, in response to the State Department’s designation of Ansarallah and three of its leaders pursuant to Executive Order 13224. Ansarallah was designated on January 19, 2021 by the State Department as a Foreign Terrorist Organization pursuant to section 219 of the Immigration and Nationality Act, as amended; as a Specially Designated Global Terrorist pursuant to Executive Order 13224, as amended; and added to the Specially Designated Nationals and Blocked Person List. The three Ansarallah leaders were added as the Specially Designated Global Terrorists pursuant to EO 13224.
GL 9 prohibits all official business by the US Government with Ansarallah or any entity that Ansarallah owns a direct or indirect 50 percent or greater interest, and GL 10 similarly prohibits all official activities between Ansarallah and certain international organizations, including the United Nations and the Red Cross. GL 10 also expressly prohibits transactions that involve the Iranian Red Crescent Society. The prohibitions in GL 9 and 10 are made pursuant to the Global Terrorism Sanctions Regulations, 31 CFR (GTSR), the Foreign Terrorist Organization Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order 13224 as amended.
GL 11 authorizes certain humanitarian activities by nongovernmental organizations, including activities that support democracy building, education and basic human needs in Yemen; as well as non-commercial projects aimed at preventing disease, sustaining agriculture and supporting environmental protection performed for the benefit of the Yemeni people; as long as the transactions do not involve Ansarallah or entities in which it owns a 50 percent or higher interest. Similarly, GL 12 authorizes activities that are ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, and medical devices that are specifically intended for use by the Yemeni people, as long as the activities do not involve Ansarallah or related entities.
OFAC also issued FAQ 875 that provides an overview of the four general licenses and reiterates that humanitarian assistance to Yemen is allowed as long as the transaction does not involve Ansarallah. According to FAQ 876, Non-US persons may engage in transactions with Ansarallah or a related entity without exposure to sanctions under EO 13224, as amended, as long as the activity was authorized for US persons under GLs 9-12; this includes foreign financial institutions who knowingly facilitate transactions involving Ansarallah. Finally, FAQ 877 specifically addresses humanitarian assistance sent in response to the COVID-19, and makes clear that US and non-US persons are able to send goods and medicines to Yemen in a way that is consistent with US sanctions.