Summary
This Order re-designates Ansar Allah (also known as the Houthis) a Foreign Terrorist Organization (“FTO”), to be effective within 45 days. The first Trump Administration had previously designated the Houthis as an FTO in January 2021, and the Biden Administration subsequently revoked the FTO designation, instead designating the Houthis as a Specially Designated Global Terrorist (“SDGT”) several years later. While implications of the FTO designation overlap with the SDGT designation in many ways, the FTO designation carries more significant consequences because, among other reasons, there will now be potential criminal liability for persons who knowingly provide “material support” to the Houthis. Under this new Order, the Secretary of State and USAID must provide a review of UN partners, NGOs and contractors that USAID works with in Yemen to identify payments made to Houthi members or entities controlled by them, and terminate projects, grants, or contracts as appropriate.