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.
Janet K. Kim
Ms. Kim focuses on outbound trade compliance issues that arise under US economic sanctions, export control laws, investment restrictions, anti-boycott 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.
Inessa Owens is an associate in the Washington, D.C. office and member of the Firm’s International Trade practice group. She focuses on outbound trade compliance issues, including compliance with the Export Administration Regulations, anti-boycott rules, and economic sanctions administered by the US Treasury Department’s Office of Foreign Assets Control, including those targeting Cuba, Iran, North Korea, Syria, and Russia. She has worked with clients in diverse industries that include finance, pharmaceuticals, and energy.
Daniel’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO.