The executive order (EO) issued on January 22, 2025, by The United states President Donald Trump does not immediately designate the Houthi rebels as a Foreign Terrorist Organization (FTO) , but indicates that within 45 days, the Trump Administration intends to take such an action, According to a document prepared by the Congressional Research Service (CRS).
CRS document added that, specifically, the EO directs the Secretary of State, in consultation with the Director of National Intelligence and Secretary of the Treasury, to submit a report to the President within 30 days on the Houthis’ redesignation and “to take all appropriate action, consistent with U.S. laws,” within 15 days of submitting the report.
CRS noticed that an FTO designation authorizes the Secretary of the Treasury to impose asset freezing sanctions on the organization and triggers the application, which criminalizes the provision of material support to designated FTOs.
The order further outlines a process requiring a review of some U.S. assistance programs in Yemen and directs the termination “as appropriate” of certain projects, grants, and contracts with entities found to have made payments to Houthi entities or insufficiently documented Houthi abuses.
The EO and the Secretary of the Treasury’s statement say that U.S. policy is to cooperate with regional partners to “eliminate” Houthi capabilities and operations, as well as to deprive the Houthis of resources. It does not specify additional actions, resources, or authorities that may be used to achieve those ends.
Section 3(d) of the EO further requires: 1) a joint review of USAID partners in Yemen among UN entities, nongovernmental organizations (NGOs), and contractors. 2) the termination “as appropriate” of U.S. projects, grants, or contracts with entities that have made payments to Ansar Allah or affiliates, or that have “criticized international efforts to counter Ansar Allah while failing to document Ansar Allah’s abuses sufficiently.”
“Material Support” Risks, Commercial Transactions with Yemen, and Humanitarian Assistance
Under U.S laws, persons may face civil and criminal penalties if they knowingly provide “material support or resources” to an FTO. These penalties are in addition to those associated with violations of U.S. sanctions laws and regulations for FTO and SDGT programs.
While the definition of material support excludes medicine and religious materials, it covers “tangible or intangible” property, including currency, financial services, and training, among other assistance.
The law has extraterritorial application in that it may apply to activities conducted outside the United States, activities affecting foreign commerce, or support by foreign persons for activities initiated under U.S. jurisdiction.
The Department of Justice is responsible for prosecuting violations of the material support statute and has discretion in prioritizing its cases.
NGOs, commercial entities, and financial institutions can be risk-averse without substantial assurance that their operations will not result in sanctions liability or criminal prosecution.