Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People

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TURBOFAC Commentary (246 words)

Notes:

1) Read in conjunction with Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People - Q # 3 (Ansarallah member leading an agency or governing institution of Yemen does not mean the entity is blocked).

Here, OFAC appears to answer a question it has long sought to avoid answering directly in either the Afghanistan or Yemen contexts, i.e. does a blocked SDGT with de facto control over an area have an “interest” in transactions of entities it controls (but doesn’t own). Here, OFAC raises the specific example of “the Central Bank of Yemen in Sana’a or other Yemeni banks that are or may appear to be controlled by Ansarallah”. In our reading, OFAC’s statement that “financial transfers to or through Yemeni financial institutions...

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Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People - Q # 5

TURBOFAC Commentary (246 words)