U.S. Takes Post-Designation Action Regarding Transactions with Yemen

Washington, D.C. (March 26, 2025) - On March 5, 2025, the U.S. Department of Treasury’s Office of Foreign Assets Control issued six general licenses, all relating to the Ansarallah Organization present in Yemen. This follows President Trump’s March 4 designation of Ansarallah as a Foreign Terrorist Organization. The six general licenses permit transactions that concern food, medicine, diplomatic missions, telecommunications, petroleum, ports, and airports. Most of these transactions would otherwise be prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), or the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR).

General License No. 22A permits transactions concerning the provision (including sale) of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to Yemen, or to persons in third countries purchasing specifically for provision to Yemen.

General License No. 23A permits the receipt or transmission of telecommunications within Yemen, but does not authorize transactions relating to telecommunications equipment or technology or transmissions facilities. It does permit some software that allows for communication.

General License No. 24A permits noncommercial and personal financial remittances to and from Yemen, with the exclusion of charitable donations and even supporting a family-owned business.

General License No. 25A permits transactions that are ordinarily incident and necessary to the delivery and offloading of refined petroleum products for personal, commercial, or humanitarian use in Yemen, but does not authorize the commercial transactions for the commercial resale, transfer, exportation, or reexporation of refined petroleum products from Yemen.

General License No. 26A permits transactions necessary to the operation of ports and airports.

General License No. 28A permits transactions for third-country diplomatic and consular missions making payments that are ordinarily incident and necessary to the official business of a third-county diplomatic consular mission to Yemen.

Key Takeaway: The March 4, 2025 designation of Ansarallah will have considerable implications for all transactions that concern Yemen, and businesses must be proactive when entering any transaction that relates to Yemen.

Lewis Brisbois’s attorneys are actively engaged in the wide range of legal issues in this area and are advising clients on managing legal and business risk as events continue to develop at an accelerated pace. For more information, contact the author or editor of this alert. Visit our Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice page for additional alerts in this area.