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...
[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and Critical Commodities to the Yemeni People from the website (presumably because at least some of the contents were out of date in light of the narrowing of some of the GLs).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) 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...