Since 2015, the US has provided over $5.5 billion in humanitarian assistance in Yemen, including $1 billion in 2022 alone. Existing US policies and partnerships with irresponsible NGOs raise concerns that this aid is susceptible to diversion by terrorist groups – primarily by the Houthis.

On January 17, 2024, the State Department designated the Iranian-backed group Ansar Allah (the Houthis formal name) as a Specially Designated Global Terrorist group (SDGT). Since October 2023, Houthi attacks on maritime shipping in the Red Sea have intensified, resulting in the deaths of sailors manning vessels traversing the area and two US Navy Seals.

Yet, the US sanctions regime features broad exemptions for humanitarian NGOs that render these measures ineffective. On February 16, 2024 the Treasury Department’s Office of Foreign Asset Control (OFAC) published a guide to the reinstituted restrictions and their impact on NGO activity. According to the document, NGOs can make payments to Houthi officials and institutions – as well as institutions controlled by Houthi officials – as long as this is done in the ostensible context of humanitarian assistance. According to OFAC, “These six general licenses do not authorize financial transfers to any blocked person, other than 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, unless separately authorized” (emphasis added).

As the Houthis set the payment policy in the territory under their control, OFAC is essentially authorizing a “pay- to-play” paradigm, under which NGO payments to the Houthis can be labeled as “taxes” or other fees.

Additionally, the document’s FAQ section presents a number of expansive permitted scenarios:

  • NGOs can “coordinate with Ansarallah [the Houthis] regarding the transfer or distribution of humanitarian goods.”
  • “An Ansarallah member [in] a leadership role at an administrative agency or governing institution in Yemen” does not prohibit transferring funds to that agency or institution.”
  • NGOs can “fund the construction or rehabilitation of…non-commercial development projects…if they could be used by a purported or actual government institution under apparent Ansarallah control.”
  • NGOs can make “payments (e.g., cash incentives, per diems, and expenses) directly to healthcare workers, teachers, and other staff who may be associated with or formally employed by purported or actual administrative agencies or governing institutions controlled by Ansarallah.”

Norwegian Refugee Council (NRC) influence on US policy

With an annual budget of over $600 million, the Norwegian Refugee Council (NRC) is one of the most influential humanitarian organizations in the world. According to NRC-Yemen, its activities are supported by USAID’s Bureau of Humanitarian Assistance (BHA).

Moreover, USAID is funding multiple NRC projects designed to influence US development policy. This includes a $1.6 million 2022-2024 grant for “Humanitarian coordination expertise,” and a $310,000 2023-2025 grant for “Building a sustainable, localized analysis structure to guide global humanitarian decision making.”

NRC leads a multi-year, global campaign to reduce anti-terror restrictions on humanitarian operations, lobbying the US and others to water down vetting standards and other anti-terror mechanisms. For instance, at a December 2020 conference organized by the French Ministry for Europe and Foreign Affairs, NRC Secretary-General Jan Egeland demanded “Exemptions from counter-terrorism laws and sanctions regimes…We need blanket humanitarian exemptions.” He added, “We need you to champion that there will be no vetting of the ultimate beneficiaries of humanitarian relief.”

NRC was also instrumental in lobbying USAID to narrow anti-terror vetting of secondary partners, as well as shortening a grantee’s “lookback” period – the amount of time an NGO must wait to apply for US funding after it has cooperated with a US-designated state sponsor of terrorism or foreign terrorist organization.

In this context, it condemned the 2021 US designation of the Houthis as a Foreign Terrorist Organization (FTO), lobbied for their de-designation, and denounced the 2024 decision to apply the SDGT label.

The aforementioned broad humanitarian exemptions to US sanctions on the Houthis are reflective of NRC’s agenda, and suggests that US support for the NGO has led to substantial shifts in US policy.

Norwegian People’s Aid (NPA)

Concerns over aid diversion manifest in other US-funded NGOs operating in Yemen.

According to usaspending.gov, the State Department is providing Norwegian People’s Aid (NPA) with $1.1 million from August 2023-September 2024 for operations in Yemen.

In April 2018, NPA settled a civil fraud case with the Justice Department and USAID. The suit charged NPA with a violation of the US False Claims Act related to its providing material support to Iran and Palestinian terror groups – including Hamas.

Highlighting these concerns, during a February 27, 2024 Senate Foreign Relations Committee hearing, Senator Bill Hagerty (R-TN) questioned this funding, stating, “I think about what Hamas has done with the aid we’ve sent to Gaza, and I’m deeply concerned that the Houthis may, as well, divert the aid that we’re sending – the US taxpayer- funded humanitarian aid that we’re sending into Yemen….We shouldn’t send a penny to an organization like this.”