Trump signs EO initiating Houthi FTO redesignation

On 22 January 2025 President Donald J. Trump signed Executive Order 14175, “Designation of Ansar Allah as a Foreign Terrorist Organization.”¹ Section 3(a) directs the Secretary of State, in consultation with the Secretary of the Treasury and the Director of National Intelligence, to “submit a report” within 30 days “with recommendation as to the designation of Ansar Allah” (the Houthis) as a Foreign Terrorist Organization under section 219 of the Immigration and Nationality Act, 8 U.S.C. § 1189; § 3(b) directs “all appropriate action” with respect to designation within 15 days after that report.¹² Section 3(c) directs the Secretary of State and the USAID Administrator to identify entities that “have made payments to Ansar Allah members or to entities controlled by Ansar Allah” or that have “opposed international efforts to counter Ansar Allah” without documenting abuses, and to terminate the identified projects and contracts.¹ The order revives a designation chain that ran from Secretary Pompeo’s 19 January 2021 FTO designation through Secretary Blinken’s revocation (announced 12 February 2021; effective 16 February 2021); a parallel Specially Designated Global Terrorist (SDGT) designation under Executive Order 13224 was announced 17 January 2024 and took effect 16 February 2024, and remains in force.³⁴⁵

1. Designation under section 219 follows the procedure at 8 U.S.C. § 1189(a)(2)(A), which requires the Secretary of State, in consultation with the Secretary of the Treasury and the Attorney General, to provide classified written notice to congressional leadership seven days before publishing the designation in the Federal Register; the designation takes effect on publication.⁶ Once the designation issues, 18 U.S.C. § 2339B(a)(1) provides that whoever “knowingly provides material support or resources to a foreign terrorist organization” is subject to fine and imprisonment for not more than 20 years, raised to any term of years or life if death results.⁷

2. The downstream OFAC blocking and licensing regime for FTO and SDGT designations operates under IEEPA, 50 U.S.C. § 1702(a)(1)(B), and its implementing regulations at 31 C.F.R. Part 597 (Foreign Terrorist Organizations Sanctions Regulations) and 31 C.F.R. Part 594 (Global Terrorism Sanctions Regulations).⁸⁹¹⁰ OFAC general licenses issued 16 February 2024 alongside the SDGT designation — including GL 22 (agricultural commodities, medicine and medical devices), GL 23 (telecommunications), GL 24 (noncommercial personal remittances), GL 25 (refined petroleum wind-down) and GL 28 (third-country diplomatic missions) — define the operative humanitarian carve-outs.⁵

3. The order’s USAID directive runs against identified counterparts only — those that paid Ansar Allah members or controlled entities, or that opposed counter-Ansar Allah efforts without documenting abuses — not against all UN, NGO and contractor partners through which USAID has operated in Yemen.¹ US contributions to UN humanitarian appeals for Yemen continue or terminate based on the outcome of those identifications.