The London P&I Club is the trading name of The London Steam-Ship Owners' Mutual Insurance Association Limited and its subsidiary The London P&I Insurance Company (Europe) Limited. The London Steam-Ship Owners' Mutual Insurance Association Limited. Registered in England No 10341. Registered Office: 50 Leman Street, London, E1 8HQ. The London P&I Insurance Company (Europe) Limited, a private limited liability company registered in Cyprus, No HE410091. Registered Office: Esperidon 5, 4th Floor, Strovolos, 2001, Nicosia. 28 April 2025 TO ALL MEMBERS AND ASSUREDS Dear Sir or Madam Sanctions Update – Yemen trading and support for the Houthi Terrorist Network This Circular provides information in conjunction with U.S. State Department spokesperson Mrs. Tammy Bruce’s recent press statement on the United States’ position regarding support to terrorist organizations, such as the Houthis. According to Mrs. Bruce on 9 April 2025, “The United States will not tolerate any country or commercial entity providing support to foreign terrorist organizations, such as the Houthis, including offloading ships and provisioning oil at Houthi-controlled ports”. In early March 2025, the Office of Foreign Assets (OFAC) designated Ansarallah (i.e., "the Houthis" group in Yemen) as a Foreign Terrorist Organization (FTO) pursuant to Executive Order 13224, by updating the existing Ansarallah entry on the Specially Designated Nationals and Blocked Persons List (SDN List). Ansarallah was already listed on the SDN List as a result of the State Department's February 16, 2024, designation of the group as a Specially Designated Global Terrorist (SDGT) organisation. Pursuant to the Executive Order 13224, U.S.- and nonU.S. persons using U.S. dollars are prohibited from engaging in virtually any transaction with Ansarallah or any entity owned 50 percent or more by Ansarallah. Furthermore, non-U.S. persons risk secondary sanctions exposure under Section 1(d)(1) of Executive Order 13224, if the US determines that a non-U.S. person has provided material support or assistance to a person designated pursuant to that same order. Simultaneous with the E.O.’s designation of Ansarallah as a FTO, OFAC issued General License 25A which permitted the delivery and offloading of refined petroleum products for personal, commercial, or humanitarian use in Yemen through 12:01 a.m. eastern daylight time April 4, 2025, provided such products were loaded on a vessel prior to March 5, 2025. This General License expired on April 4, 2025, and has not been renewed. Although pursuant to OFAC GL 26A transactions “necessary to port and airport operations involving Ansarallah” are generally authorized, GL 26A expressly excludes “transactions involving imports or exports of refined petroleum product.”. Please note that GL 26A also does not authorize any payments to Ansarallah or an entity controlled by it unless “for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services.” Based on these developments, if the cargo, including refined petroleum products, is going to be delivered to an Ansarallah controlled entity (or there is another Ansarallah involvement which is not required for the ordinary use of the port) then that transaction is prohibited, unless there is an exemption granted, i.e. under another GL, such - 2 as GL 22A (for agricultural commodities, medicines or medical devices). As a result, vessels dischargin