Understanding U.S. Sanctions on Yemen

The United States imposes targeted financial sanctions related to Yemen. These aren’t a full embargo. Instead, the Office of Foreign Assets Control (OFAC) administers a program designed to block the property and financial assets of specific people and groups threatening Yemen’s peace, security, or stability. The primary legal authority is Executive Order 13611, signed on May 16, 2012, with the detailed rules found in 31 CFR Part 552.

Blocked Property – refers to any property or interests in property of a person designated by OFAC. U.S. persons are prohibited from transferring, paying, exporting, withdrawing, or otherwise dealing in such property unless authorised by OFAC.

What Are the U.S. Sanctions on Yemen?

The U.S. sanctions program against Yemen is direct: it prohibits U.S. persons from engaging in almost all transactions with individuals and entities designated by OFAC. The central mechanism is the freezing, or “blocking,” of any property these parties own or have an interest in. If that property is in the U.S. or touches the U.S. financial system, it’s frozen. Simple as that. This effectively cuts designated parties off from the American economy.

Who gets designated? OFAC targets those found to have engaged in actions that threaten Yemen’s peace, security, or stability, whether directly or indirectly. This includes obstructing the political transition, committing human rights abuses, or undermining the legitimate government. As the conflict has evolved, so has the scope of sanctions. Recent actions, for example, have targeted groups like Ansarallah (the Houthis) for disrupting maritime commerce, often using separate counter-terrorism authorities like Executive Order 13224.

What are U.S. sanctions on Yemen?

Many people assume U.S. sanctions on Yemen are a country-wide embargo. They are not. The regulations, specifically under 31 CFR § 552.201, are highly targeted. This means general trade and financial transactions with non-designated people or companies in Yemen are typically allowed. The restrictions only kick in when you’re dealing with the specific individuals and entities that OFAC has blacklisted for their destabilizing activities.

UN sanctions Yemen

Washington isn’t acting alone. The U.S. sanctions program aligns with broader international efforts, helping implement commitments under United Nations Security Council resolutions. UNSC Resolution 2216 (2015), for instance, established a UN sanctions regime that includes an arms embargo on specific groups, an asset freeze, and a travel ban on listed individuals. OFAC’s designations often mirror or directly support those made by the UN Yemen Sanctions Committee.

Who Is on the Yemen Sanctions List?

Individuals and entities targeted by Yemen-related sanctions land on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List). All their property and interests in property are blocked. U.S. persons are prohibited from dealing with them. For example, OFAC has designated high-level political and military figures from Ansarallah, as well as the financial facilitators and procurement networks that keep their operations running.

There is only one reliable way to know if a person or company is on this list. Use OFAC’s official, free online Sanctions List Search tool. This is a real-time database, not a static document, allowing you to check names against all of OFAC’s sanctions lists, not just those tied to Yemen.

What is the Yemen Sanctions list?

There isn’t a single, standalone document called the “Yemen Sanctions list.” It’s not a PDF you can download. Instead, designations made under the Yemen-related sanctions program are woven into the comprehensive SDN List. These specific entries are identifiable by the program tag `[YEMEN]`, which points to the legal authority behind the designation.

What is the OFAC sanctions List?

The phrase “OFAC sanctions List” almost always means the SDN List. That said, OFAC does maintain several other lists for different programs, like the Foreign Sanctions Evaders (FSE) List and the Sectoral Sanctions Identifications (SSI) List. For most compliance related to Yemen, however, the SDN List is your primary focus.

What is the Latest OFAC Sanctions List?

The SDN List is a moving target. It’s updated frequently, sometimes daily. Relying on a downloaded or printed list is a major compliance risk because it can become obsolete within hours. Before proceeding with any transaction, businesses must always consult the official, live Sanctions List Search tool on the U.S. Department of the Treasury’s website to ensure they have the most current information.

What Transactions Are Prohibited and What Is Allowed?

Any transaction by a U.S. person—or within the United States—involving any property of a person on the Yemen sanctions list is prohibited, unless OFAC authorises it. This ban is broad, covering financial transfers, providing goods or services, and any other dealings in blocked property. Even rejected transactions have rules; a wire transfer that’s rejected because it involves a listed person must be reported to OFAC within 10 business days.

Still, OFAC recognizes the severe humanitarian crisis in the country, including the ongoing yemen water crisis. To address this, it has issued several General Licenses (GLs). These GLs authorize certain activities that would otherwise be illegal. For example, amendments published in the Federal Register (like 87 FR 78470-22) explicitly allow transactions for humanitarian aid, agricultural commodities, medicine, and medical devices, as long as they don’t involve designated persons outside the license’s specific scope.

If your activity isn’t covered by a General License, you must apply for a specific license from OFAC’s Licensing Division. This is a written permit for a particular transaction, which OFAC reviews case-by-case. Getting expert guidance is crucial before you apply, as the process for navigating complex OFAC sanctions programs is notoriously detailed.

What Are the Penalties for Violating Yemen Sanctions?

Violating OFAC sanctions brings severe penalties under the International Emergency Economic Powers Act (IEEPA). Civil monetary penalties can be staggering, reaching hundreds of thousands of dollars for each violation. If a violation is found to be willful, criminal penalties can include massive fines and even prison time for the individuals involved.

An OFAC enforcement action often begins with a request for information or a formal Pre-Penalty Notice, which details the alleged violation. The recipient typically has 30 days to respond—a critical window to build a defense. When setting a penalty, OFAC considers factors like the egregiousness of the violation, the level of cooperation, and whether the company filed a voluntary self-disclosure, which can be a powerful mitigating factor.

OFAC’s enforcement strategy is also visible in its licensing actions. For example, in April 2025, after designating the International Bank of Yemen (IBY) for its links to Ansarallah, OFAC simultaneously issued Counter Terrorism General License 33. This license authorized certain wind-down transactions with IBY for a limited period, showing how OFAC uses licenses to manage the economic fallout of a designation while still hitting its policy targets.

How Can I Ensure Compliance with OFAC’s Yemen Sanctions?

For any business with international exposure, the best defense is a robust, risk-based Sanctions Compliance Program (SCP). An effective SCP has five key components: management commitment, risk assessment, internal controls, testing/auditing, and training.

Of these, internal controls are the most practical day-to-day element. This means consistently screening all customers, suppliers, and transaction counterparties against the SDN List. You can do this with OFAC’s free Sanctions List Search tool or with integrated third-party screening software. Pay special attention to transactions involving high-risk jurisdictions or industries.

What if you find a potential violation? Stop the transaction immediately. Investigate internally. Then, you should strongly consider making a voluntary self-disclosure to OFAC. Disclosing a violation before the government discovers it can dramatically reduce potential penalties and signals a serious commitment to compliance.

This article is published by an independent law firm for informational purposes only and does not represent or claim affiliation with any government body, international organization, or official authority.