[THREAD] 1/20 Yemen, Middle East, and NatSec pros: Tomorrow, January 19 2021, the Houthi FTO Designation comes into effect. Here is the latest as I understand it.
2/20 The Treasury language regarding exemptions for material support is not yet public as of this morning; this gap is causing immense concern among the private sector, including commercial traders of basic commodities, the NGO community, the UN, and other major donors to Yemen.
3/20 There are no OFAC licenses issued.
4/20 Today is a federal holiday, tomorrow the law precluding any material support to the Houthis goes into effect. I’m doubtful that we will see the Treasury language today or tomorrow as the career staff know that the incoming Biden admin will have a view on this language.
5/20 This FTO designation prohibits any transaction that goes through the international banking system - practical all trade, payments, commercial transactions - in short, nearly everything.
6/20 The Central Bank of Yemen has no hard currency reserves left, there will be likely a massive devaluation of the Yemeni riyal.
7/20 The FTO designation is complicated by the fact that the Houthis are indeed bad actors, and are substantially (but not wholly) responsible for the massive humanitarian crises of the population in their area of control (70-80% of the entire population of Yemen).
8/20 The Houthi leadership - and perhaps its mid level rank and file - need to be held accountable for their atrocities.

The Saudis, who have strongly advocated for the FTO designation, have simply not done the analysis to mitigate the humanitarian and economic consequences.
9/20 In their rush to judgment to push this agenda on the last day of the Trump admin, they threaten millions of lives and put the entire Arabian peninsula at tremendous risk. They also have tried to box in the Biden team; not a good first move and one that deserves a response.
10/20 I have heard, and this needs to be confirmed, that an absolute reversal of Pompeo’s FTO designation may trigger a 7 day congressional notification. If that is true, those 7 days could be catastrophic.
11/20 I’m not convinced that a reversal requires notification. State/L would have to opine. But when?
12/20 Given the bumpiness of the transition, I’m not sure the Biden team has had adequate time and coordination with career staff to understand all of the logistics and implications of a very complicated policy issue in the first minutes of the administration.
13/20 Maybe they do have the depth, team, and career staff on board - but maybe they don’t. Let’s assume they don’t for purposes of this discussion.
14/20 The Biden administration has massive challenges to confront including on the foreign policy front. Yemen would have never been a top, Day One, issue.
15/20 But, because of Pompeo’s push at the 11th hour to designate the entire Houthi movement, he may have ironically pushed Yemen to the top of the foreign policy agenda.
16/20 Section 1295 of the NDAA requires a Yemen policy review as a matter of law by May 3.
17/20 Given the complexity, risk to the private sector and humanitarian community, and the likelihood of a complete collapse in Yemen, the prudent course still seems to undertake a full pause pending a Yemen policy review by May 3rd
18/20 - and signal that pause to banking institutions, donors, implementing agencies, commercial traders so they can manage transaction risk for a defined period.
19/20 During this time, the Biden interagency can undertake a much more thoughtful interagency process that would hold Houthi leadership accountable but not cause harm to millions of people.
20/20 The first hours of Biden’s presidency will be extraordinarily consequential for millions in the Middle East come Wednesday. [END]
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