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Can commercial actors, humanitarian groups, and other organizations continue to import commercial goods, including food and humanitarian supplies, into Yemen?
Yes. Yemen is not subject to broad, jurisdiction-based sanctions. As a result, NGOs, international organizations, and commercial businesses are not generally prohibited from importing humanitarian supplies into the country. As described above, the NGO general license at GTSR section 594.520 authorizes all transactions that may otherwise be prohibited in support of specified NGO non-commercial, humanitarian-related activities, subject to certain conditions. General License 26 authorizes certain transactions involving Ansarallah ordinarily incident and necessary to operations, import or export of goods, or transit of passengers through, ports and airports in Yemen. Additionally, General License 22 authorizes certain transactions involving Ansarallah that are ordinarily incident and necessary to the provision (including sale) of certain agricultural commodities, medicine, and medical devices to persons in Yemen, or to persons in third countries...
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[3-5-25 update - on 3-4-25, the State Department re-designated Ansarallah as an FTO. See FAQ # 1219. OFAC amended the Ansarallah-related GLs that existed as of the date of the publication of this document, narrowed the scope of some of them, and also removed Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People from the website (presumably because at least some of the contents were out of date in light of the narrowing of some of the GLs). The below has not been amended in light of the foregoing].
1) Note Common to All 2-16-24 "Humanitarian Assistance" (Yemen) Guidance Entries
On 2-16-24, OFAC issued its Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People.
Because OFAC...