ARTICLE
28 January 2021

OFAC Authorizes Certain Time-Limited Transactions Involving Houthi Militia

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
OFAC authorized certain transactions involving Ansarallah, an Iranian-backed armed militia fighting against the Yemeni Sunni government, through February 26, 2021.
United States International Law
To print this article, all you need is to be registered or login on Mondaq.com.

OFAC authorized certain transactions involving Ansarallah - an Iranian-backed armed militia fighting against the Yemeni Sunni government - through February 26, 2021. These transactions would be otherwise prohibited by the Global Terrorism Sanctions RegulationsForeign Terrorist Organizations Sanctions Regulations and Executive Order 13224 ("Executive Order Dated September 23, 2001").

OFAC specified in General License No. 13 that the authorization does not extend to the unblocking of funds that were blocked as of January 25, 2021 in the accounts of Ansarallah (or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest).

In amended FAQ 876, OFAC clarified that foreign financial institutions do not risk exposure to "correspondent and payable-through account" sanctions if they engage in transactions involving Ansarallah that would be authorized for a U.S. person under General License Nos. 9101112 and 13 (see previous coverage of the other General Licenses here).

Primary Sources

  1. OFAC General License No. 13: Authorizing Transactions Involving Ansarallah
  2. OFAC FAQ: Counter Terrorism Sanctions - 876

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More