On April 28, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on three vessels and their associated owners for providing material support to Ansarallah (the Houthis), a designated terrorist organization.
As informed, the sanctioned entities facilitated the delivery of petroleum products to Houthi-controlled ports even after the expiration of an OFAC general license that had temporarily allowed such activity. These imports, once discharged, are resold at inflated prices on Yemen’s black market, generating illicit revenue that funds the Houthis’ military campaigns.
Sanctions implication
As a result of today’s action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.
In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis.
In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities with designated entities or otherwise blocked persons.
The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
Furthermore, engaging in certain transactions with the entities designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended.
Pursuant to this authority, OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a Specially Designated Global Terrorist.
Exports, reexports, or transfers of items subject to U.S. export controls involving persons included on the Specially Designated Nationals and Blocked Persons (SDN) List pursuant to E.O. 13224, as amended, may be subject to additional restrictions administered by the Department of Commerce, Bureau of Industry and Security. See 15 C.F.R. section 744.8 for additional information
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law.
