The humanitarian crisis in Yemen continues to worsen. The UN Office for the Coordination of Humanitarian Affairs (UNOCHA) reported last fall that Yemen was experiencing the most severe humanitarian disaster the country had faced since 2022, when it was in the midst of a full-blown conflict. Seven out of 10 families could not meet their basic food needs, and ‘almost one in three families were going a whole 24-hour period without eating’. The food crisis was also gendered, with women and girls ‘often eating least and last and finding themselves increasingly exposed to protection risks’.

In addition to food insecurity, more than 22 million people – over two-thirds of the population – are in need of humanitarian assistance. These include over five million internally displaced people, as well as migrants and refugees. Water scarcity, 40% of health care facilities functioning at reduced capacity or not functioning at all, significant infrastructure damage – all this increases the risk of large-scale public health emergencies.

The crisis has been aggravated significantly by a US measure that appears, at first glance, unrelated: the designation of the Houthis as a Foreign Terrorist Organisation (FTO). The Houthis (Ansar Allah) took control of Yemen’s capital, Sana’a, in 2014. Since then, they have functioned as the government in much of the northern part of Yemen, where more than 70% of the population resides. 

In the context of Yemen, the FTO designation – a form of blacklisting – effectively operates to paralyse the seaports in the areas controlled by the Houthis. Yet access to Yemen’s seaports is critical: after years of conflict, as well as floods, drought and pests, Yemeni agriculture has suffered considerably. As a result, about 85% of Yemen’s food is imported. Yemen also depends heavily on fuel imports. The Houthis control the region of Hodeidah, which includes three major seaports on the Red Sea: Hodeidah, Ras Issa, and al-Salif. About 70% of Yemen’s commercial imports come through the Hodeidah port, as well as 80% of humanitarian aid.

It is obvious, of course, that interrupting food imports into Yemen directly contributes to a humanitarian crisis. It is less obvious that fuel should be considered as an essential humanitarian good. But gasoline and diesel fuel are necessary for trucks to deliver food within the country. Various forms of refined petroleum products are used in agriculture, cooking and generating electricity. The interruption of these supplies will disrupt food crops; flour milling and other industrial food production; and household cooking. Despite this, the US has targeted fuel imports to Yemen, on the grounds that revenues from port fees and fuel sales support the Houthis. 

Maritime shipping to Yemen was significantly disrupted by bombing strikes on Yemen’s major seaports. In the aftermath of the Hamas assault on Israel in October 2023, and Israel’s massive attacks on Gaza in response, the Houthis launched missiles and drone strikes against Israel, as well as attacking international shipping in the Red Sea. In retaliation, Israel conducted airstrikes against Yemen’s infrastructure and ports, including its 2025 bombings of the port of Hodeidah. In addition, in April 2025, the US military bombed the Ras Issa oil terminal, destroying it, killing over 70 people and wounding 171 more, in order ‘to eliminate this source of fuel for the Iran-backed Houthi terrorists and deprive them of illegal revenue’.

The interruption of food and fuel imports is also due in significant measure to the sanctions that have been imposed. There are many types of sanctions. Some are country programs, in which the sanctions regime explicitly applies to the country as a whole. This was the case, for example, when the UN Security Council imposed comprehensive sanctions on Iraq in the 1900s. Security Council Resolution 661 prohibited all imports, exports and financial transactions involving Iraq; and every member state of the UN was then required to implement these provisions. Then there are blacklists – sanctions that are imposed on individual persons or companies. The individual is subject to travel restrictions, asset freezes, or other measures by the sanctioner. But these measures may also affect many others besides the listed individuals: any person or company that does business with them, or provides goods or services, may themselves face significant penalties by the sanctioner. 

In the last five years, the US government has imposed a number of sanctions measures against the Houthis. In January 2021, shortly before the end of President Donald Trump’s first term, the Trump Administration listed the Houthis under the Specially Designated Global Terrorist (SDGT) program, and also as an FTO. Nearly two dozen international NGOs providing humanitarian aid in Yemen issued a public call to reverse these measures: ‘This designation comes at a time when famine is a very real threat to a country devastated by six years of conflict, and it must be revoked immediately. Any disruption to lifesaving aid operations and commercial imports of food, fuel, medicine and other essential goods will put millions of lives at risk.’ Shortly after, President Biden revoked both designations on the grounds that they would undermine the delivery of humanitarian assistance, as well as efforts toward dialogue. 

In February 2024, in response to Houthi attacks on ships in vessels in the Red Sea and Gulf of Aden, President Joe Biden re-designated the Houthis as an SDGT. The international NGO community again responded with deep concern, noting that ‘The addition of a further FTO designation could be devastating. It would effectively criminalise certain transactions necessary to facilitate life-saving humanitarian aid and almost certainly exacerbate the chilling effect on commercial imports, remittances, and financial services. Our organisations are committed to Yemen, but we are already struggling to keep pace with humanitarian needs amid declining global resources. Further disruption to our ability to operate would only increase suffering for the most vulnerable.’

In March 2025, the Trump Administration once again designated the Houthis as an FTO. Both SDGT and FTO designations impose penalties not only on the Houthis, but also on third parties who engage with them. Anyone who commits or aids or abets in the commission of a sanctions violation related to an SDGT or an FTO is subject to criminal penalties of up to $1m and 20 years of imprisonment. However, the FTO designation is potentially more serious. In this case, there are criminal penalties that may include imprisonment of 20 years for a person who provides ‘material support or resources’ to a an entity designated as an FTO. ‘Material support or resources,’ in turn, is defined very broadly: ‘any property, tangible or intangible, or service, including currency or monetary instruments or financial securities, financial services, … communications equipment, … [or] transportation’.

So it seems that anyone who provides a member of the Houthi government with a bank account, a car or a telephone, could be prosecuted and incarcerated for 20 years. Not only that – a third party who provides ‘material support’ to an FTO may themselves be backlisted. In that case, presumably, anyone who provides them with material support or resources – including a bank account, a car or a telephone – could be prosecuted criminally and imprisoned for twenty years. The US designation could therefore be expected to cause enormous disruption to not only the Houthis’ governmental operations, but also to every commercial or private transaction in the country that may involve the Houthis – for example through the country’s infrastructure – in any way.

In themselves, the erratic changes in US policy have created considerable uncertainty for commercial and humanitarian actors engaged with Yemen in any capacity, and an understandable reluctance to have further dealings with Yemen. In May 2025, a newsletter in the shipping industry warned that ‘Sanctions are coming in swiftly and compliance is paramount to avoid losses; this is the new normal in maritime compliance.’ All those involved in maritime shipping are affected by the constantly changing sanctions regimes, including shipowners, freight brokers, fuel suppliers and port agents. 

Humanitarian aid organisations working in Yemen have been equally affected. ‘Even before the designations took effect, donors and banks scaled back their activities due to fear of non-compliance,’ one reports. A USAID respondent noted that ‘everyone was very concerned and constantly tracking’ the possibility of a renewed designation. A sanctions lawyer described the “chilling effect” of rules that came and went, leaving organisations unsure of what was permitted.’

The severity of the risk to the shipping industry became clear when the US Treasury Department, took the position on April 9 2025 that any ship that delivered goods to the ports in the Houthi-controlled areas of Yemen was deemed to be providing ‘material support’ to the Houthis: ‘The United States will not tolerate any country or commercial entity providing support to foreign terrorist organisations, such as the Houthis, including offloading ships and provisioning oil at Houthi-controlled ports. Such actions risk violating U.S. law.’

This was not an empty threat. On April 28 2025, the US Treasury Department announced that it was blacklisting several vessels that had transported various petroleum products to Yemen. One vessel had delivered a cargo of liquid petroleum gas (LPG), which is used for household cooking and home heating, among other things. Others had delivered gas oil, which is used as diesel fuel for tractors and to fuel electrical generators. 

None of these vessels were based in the US, nor were the shipping companies that owned them. The vessels were registered in San Marino and Panama, and the shipping companies that owned them were registered in Mauritius and the Marshall Islands. Consequently, the US measures were extraterritorial – that is, they extend well beyond the legitimate scope of US authority, and intervene in transactions that take place entirely among foreign nationals.

US extraterritorial measures have long been denounced by the international community as violations of international law, notably in annual resolutions introduced by Cuba and adopted by the UN General Assembly. However there is no venue, in the US courts or elsewhere, where such measures can be effectively challenged and invalidated. So commercial actors, such as shipping companies, have little choice but to comply if they do not want to be excluded from the US market, or possibly be subjected to criminal prosecution.

By August 2025, food and fuel imports through the ports of Hodeidah, Al-Salif and Ras Issa declined by 22%, worsening food shortages and access to critical services, due in large measure to the damage to the ports from the bombing strikes and the aggressive sanctions policy. It was estimated that these three ports had more than $1.3 billion in direct and indirect losses in that time. Fuel shipments were at their lowest level in three years, affecting everything from transportation to health care to the capacity to mill flour. An aid worker in Hodeidah reported: ‘We’re seeing families skip meals and hospitals ration electricity. The situation is deteriorating fast.’

In principle, the US Treasury Department had exemptions in place that ostensibly mitigated the humanitarian impact of blacklisting the Houthis as FTOs or SDGTs: there was a general license under which companies are permitted to deliver agricultural goods, medicine and medical devices to Yemen. However, a license to ship food and medicine was of little value, given the damage to the seaports from US and Israeli bombing strikes. The prohibition on fuel shipments meant that even if wheat shipments arrived, flour mills could not operate due to the lack of electricity; and medicines could not be delivered due to the lack of gasoline. 

Under the statute that authorises the designation of FTOs, terrorism is defined as ‘premeditated, politically motivated violence perpetrated against noncombatant targets’. Designating the Houthis as a Foreign Terrorist Organisation is not without its own humanitarian consequences on noncombatants. It hardly seems defensible to bring about hunger, water scarcity and sickness for the 22 million Yemenis in urgent need of humanitarian aid in the name of stopping terrorism.