Treasury Designates 21 Individuals and Entities and Identifies Vessel for Supporting Houthi Oil Sales, Weapons Procurement, and Financial Networks

When OFAC “designates” someone and adds them to the Specially Designated Nationals and Blocked Persons (SDN) List:

• All of that person’s or company’s property and interests in property that are in the United States or held by U.S. persons must be “blocked” (frozen) and reported to OFAC.
• U.S. persons (citizens, permanent residents, U.S. companies, and anyone in the U.S.) are generally prohibited from doing business or other transactions with them unless OFAC specifically authorizes it.
• The block also applies to any entity that is 50% or more owned (directly or indirectly) by one or more blocked persons.
• The person or company effectively loses access to the U.S. financial system and risks being avoided by global banks and businesses that follow U.S. sanctions rules.

Executive Order (E.O.) 13224 is a U.S. counter‑terrorism order signed in 2001 that declares a national emergency related to foreign terrorism and terrorist financing. It authorizes:

• The Secretary of State (for terrorists) and the Secretary of the Treasury (for their supporters), in consultation with the Attorney General, to “designate” individuals, groups, and entities that commit or pose a significant risk of committing terrorism, or that provide financial, material, or technological support to them.
• The blocking (freezing) of all property and interests in property of those designated that are in the U.S. or in the possession or control of U.S. persons.
• A broad ban on U.S. persons engaging in transactions or dealings with those designated. The Houthis/Ansarallah and the 21 individuals and entities in this press release are being designated under this authority.

To seek removal (delisting) from the SDN List, a person or company must:

• Send a written petition (request for reconsideration) to OFAC explaining why they should be removed and providing supporting evidence (for example, mistaken identity, the original basis for designation no longer exists, or a demonstrated positive change in behavior).
• Include identifying information, details of the listing, and any documents that show the criteria for listing are no longer met. OFAC then:
• Reviews the petition, may send questionnaires asking for more information, and consults with other U.S. agencies.
• Decides whether to keep the listing or remove/amend it, applying the standards in 31 C.F.R. § 501.807. There is no fixed timeline; reviews can take many months or longer, and petitioners bear the burden of showing that delisting is appropriate.

“Secondary sanctions” are penalties the U.S. can impose on non‑U.S. persons—especially foreign financial institutions (FFIs)—that knowingly do significant business with SDNs or other sanctioned parties, even if there is no direct U.S. nexus. For foreign banks or companies, this can mean:

• Being cut off from, or heavily restricted in, access to U.S. correspondent or payable‑through bank accounts (practically, losing access to the U.S. dollar system), or
• Being themselves added to U.S. sanctions lists. Because access to U.S. markets and the dollar system is crucial for most banks, the risk of secondary sanctions often makes foreign institutions refuse transactions involving designated parties.

Formally, these designations are aimed at Houthi revenue and weapons networks and do not ban all fuel or aid going into northern Yemen. In practice, the impact is mixed:

• OFAC has issued multiple “general licenses” and specific guidance for Yemen allowing certain humanitarian‑related transactions, including for agricultural goods, medicine, some refined petroleum for civilian use, and activities by NGOs, U.N. agencies, and some commercial actors, even when Ansarallah/Houthis are involved.
• At the same time, the press release explicitly targets specific fuel shipments and shipping companies that OFAC says provided economic support to the Houthis after a limited humanitarian wind‑down for petroleum deliveries expired. That increases legal and reputational risk for shippers and banks, which can cause over‑compliance (companies refusing even authorized or exempt shipments to avoid any risk). So while U.S. policy says it seeks to preserve humanitarian fuel and aid flows, sanctions on fuel and financial channels in Houthi‑controlled areas can still slow, complicate, or deter deliveries to civilians, depending on how cautiously companies and banks respond.

OFAC connects the named companies and individuals to Iran and to Houthi financial or weapons networks based on its investigations and intelligence, summarized (in unclassified form) in the press release:

• Oil and revenue networks: Treasury states that UAE‑based firms like Al Sharafi Oil Companies Services, Adeema Oil FZC, Arkan Mars Petroleum DMCC, Alsaa Petroleum and Shipping FZC, and Janat Al Anhar are “Iran‑affiliated” or receive support from the Iranian government and are used to sell or move oil that generates over $2 billion annually for the Houthis. Money is routed via exchange houses in Sana’a and Dubai, and some entities (e.g., Janat Al Anhar/Abu Sumbol) were previously sanctioned for links to an Iran‑based Houthi financial facilitator.
• Weapons smuggling: Treasury describes specific smuggling operations, such as Wadi Kabir Co. for Logistics Services and Rabya for Trading FZC allegedly hiding 52 Kornet anti‑tank missiles in fake generators shipped from Oman into Yemen, and Al‑Ridhwan Exchange financing weapons purchases and smuggling operations “from Iran, Djibouti, and elsewhere in the Red Sea region.”
• Procurement and logistics: New Ocean Trading FZE is said to act as an agent for a Yemeni company procuring military equipment, and to have shipped technical systems and other equipment into Houthi‑controlled areas. Aviation companies and individuals (Barash Aviation, Sama Airline, Adil Al‑Muayyad, Muhammad Al‑Sunaydar) are described as helping the Houthis obtain aircraft and dual‑use equipment and as working with known arms dealers. The detailed basis for these findings (classified intelligence, law‑enforcement information, etc.) is not public; OFAC publishes only these summary allegations and applies the “material support” and related criteria in E.O. 13224 when designating.

Sanctions enforcement is shared across several U.S. agencies:

• OFAC (U.S. Treasury) is the primary civil enforcement agency: it investigates most sanctions violations and can impose administrative (civil) penalties on a strict‑liability basis—often hundreds of thousands or millions of dollars per case, depending on factors like willfulness and harm.
• The U.S. Department of Justice (DOJ) handles criminal enforcement: prosecutors can bring criminal charges (often under the International Emergency Economic Powers Act and related laws) that may carry large fines and potential prison terms (commonly described as up to 20 years’ imprisonment and up to $1 million per violation, subject to statutory updates).
• Other agencies (e.g., the Department of Homeland Security through Homeland Security Investigations and Customs and Border Protection; financial regulators such as the OCC or Federal Reserve for banks) may investigate, refer cases, or take parallel regulatory actions. The press release also notes that foreign persons can face civil or criminal penalties for U.S. sanctions violations and that foreign financial institutions risk secondary sanctions if they knowingly conduct significant transactions involving designated parties.