Are organizations barred from making payments (e.g., cash incentives, per diems, and expenses) directly to healthcare workers, teachers, and other staff who may be associated with or formally employed by purported or actual administrative agencies or governing institutions controlled by Ansarallah?
No. As described above, a member of Ansarallah having a leadership role in an organization or entity does not mean, by itself, that the organization or entity itself is blocked. Organizations can make salary support or stipend payments directly to healthcare workers (e.g., doctors at public hospitals or healthcare workers at community clinics), teachers at public and private schools, and other staff who may be associated with or formally employed by purported or actual administrative agencies or governing institutions controlled by Ansarallah so long as the recipient themselves is not a blocked person. In addition, the NGO general license at GTSR section 594.520 authorizes NGOs to engage in...
Notes:
1) Read in conjunction with Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People - Q # 3, and query whether this guidance applies in an across-the-board fashion to entities headed or controlled by blocked persons (i.e. are these the sort of “routine interactions” contemplated in FAQ # 993 and FAQ # 1145?) Here, OFAC is effectively saying that Ansarallah, as a blocked entity that controls a governing institution, does not have an "interest" in a transaction involving payment to an employee of the institution " so long as the recipient themselves is not a blocked person". This is a relatively narrow conception of “interest” vis-à-vis, e.g., FAQ # 1145 (“receiving an invoice bearing the blocked individual’s signature for a commercial transaction, would be prohibited by the [blocking prohibition] unless authorized by OFAC or exempt.)”...