General License 25 - Authorizing Transactions Related to Refined Petroleum Products in Yemen Involving Ansarallah (January 17, 2024)

Date issued: Jan. 17 2024

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TURBOFAC Commentary (134 words)

Notes:

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)