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OFFICE OF FOREIGN ASSETS CONTROL
Global Terrorism Sanctions Regulations
31 CFR part 594
GENERAL LICENSE NO. 25
Authorizing Transactions Related to Refined Petroleum Products in Yemen Involving Ansarallah
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, that are ordinarily incident and necessary to the provision (including sale) of refined petroleum products for personal, commercial, or humanitarian use in Yemen are authorized.
(b) This general license does not authorize:
(1) Any commercial resale, transfer, exportation, or reexporation of refined petroleum products from Yemen;
(2) Financial transfers to any blocked person described in paragraph (a), other than for...
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1) For relevant background, refer generally to Temporary Note Concerning the Jan. 17, 2024 Redesignation of Ansarallah (the Houthis) as a SDGT Entity, for background concerning the Jan. 17, 2024 Redesignation of Ansarallah and related interpretive issues.
2) This GL is unique to this program (but compare e.g. 542.516(a)(4) (Syria) authorizing otherwise prohibited “purchase of refined petroleum products of Syrian origin for use in Syria”. Query: is the purchase of gas from Ansarallah covered by the GL? The “financial transfers” carveout has an exception for the payment of “fees”. Is the purchase price of gas a “fee”? With respect to the “financial transfers” carveout that is standard in this and other Jan. 2024 Ansarallah-related GLs, see section 6(v)