Against the backdrop of heightened tensions across the Middle East, on January 17, 2024, the Biden administration designated the Iranian-backed Houthi rebels in Yemen as a specially designated global terrorist organization.  The designation will be effective on February 16, 2024.  This move follows dozens of attacks in recent months by the Houthis on commercial vessels in the Red Sea, causing significant disruptions to shipping routes and global trade.

With the designation, U.S. persons, including U.S. financial institutions, will be required to freeze any property that comes into their possession and/or control that belongs to the Houthi rebels.  The restrictions also apply to any entity in which the Houthis own, directly or indirectly, a 50 percent or greater interest.  Notably, the U.S. government issued general licenses authorizing certain transactions related to (among other things) the provision of food, medicine, and refined petroleum products in Yemen.  The general licenses will also be effective on February 16, 2024.

Though not unexpected, the designation represents the latest escalation of geopolitical tensions across the region since Hamas’ October 7, 2023, attack on Israel.