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Financial Services Law Insights and Observations

OFAC sanctions Houthi military official

Financial Crimes Burma OFAC Department of Treasury Sanctions OFAC Designations Of Interest to Non-US Persons Yemen SDN List

Financial Crimes

On May 21, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13611 against a key senior military official connected to the Ansarallah, sometimes referred to as the Houthis, for allegedly arranging attacks impacting Yemeni civilians. According to OFAC, the sanctioned individual recently led the offense against Yemeni government-held territory in the Marib province, which “puts approximately one million already vulnerable internally displaced people (IDP) at risk, threatens to overwhelm an already stretched humanitarian response, and is triggering broader escalation.” As a result of the sanctions, all property and interests in property belonging to the sanctioned individual, and “any entities that are owned, directly or indirectly, 50 percent or more” by the individual that are subject to U.S. jurisdiction are blocked and must be reported to OFAC. OFAC’s announcement further noted that OFAC regulations “generally prohibit” U.S. persons from participating in transactions with designated persons unless exempt or otherwise authorized by a general or specific license, and warned foreign financial institutions that if they knowingly facilitate significant transactions for any of the designated persons, they may be subject to U.S. correspondent account or payable-through account sanctions.

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