NGOs working in Houthi-controlled areas must follow strict prohibitions on providing any form of material support to the Houthi rebels, following U.S president’s Executive Order designating them as a Foreign Terrorist Organization (FTO), according to a recent report by SARI Global.
The report added that the U.S. Secretary of State now has 30 days to formally recommend re-designation, after which U.S. policy will prioritize denying the Houthis resources, material support and operational capabilities.
The report noticed that NGOs risk both civil and criminal penalties if deemed to have provided assistance to a designated terrorist organization, adding that this often complicates basic interactions in Houthi-controlled areas where administrative fees or taxes are a routine part of delivering humanitarian services.
SARI Global report found that U.S.-funded organizations may see additional scrutiny under the Executive Order, where the Secretary of State and the Administrator of USAID must review all UN partners, NGOs, and contractors operating in Yemen to identify if they have made payments to Houthi authorities, or have overtly opposed counterterrorism efforts while minimizing or overlooking Houthi abuses.
Entities found to be in violation could face suspension of funding and termination of U.S. government contracts.
Maintaining Compliance and Access
To minimize legal exposure, SARI Global suggest humanitarian organizations may need to develop more rigorous vetting of local partners, suppliers, and financial transactions.
They may also need to enhance documentation around each payment or collaboration, ensuring they can demonstrate good-faith efforts to avoid inadvertently supporting a designated entity.
Frequent consultations with legal experts, timely staff training on sanctions regulations, and meticulous record-keeping can help manage these challenges.