Yemen is a targeted regime rather than a comprehensive one, and the Panel of Experts’ latest report says plainly that its financial measures have been hard to make bite.
Two regimes
The UN regime was established by resolution 2140 (2014). The Panel’s final report of October 2025, S/2025/650, describes it as consisting of a travel ban and an asset freeze applying to individuals and entities the committee designates as engaging in or supporting acts that threaten the peace, security or stability of Yemen, with a targeted arms embargo added by resolution 2216 (2015). In resolution 2758 (2024) the Council renewed the asset freeze and travel ban until 15 November 2025 and the Panel’s mandate until 15 December 2025.
The US programme is older. E.O. 13611 (2012) underlies 31 CFR Part 552, which blocks any person the Secretary of the Treasury determines, in consultation with the Secretary of State, to have engaged in acts that threaten Yemen’s peace, security or stability, to have materially assisted such acts, or to be owned or controlled by, or acting for, a blocked person. Section 552.201(b) extends the prohibition to any contribution or provision of funds, goods or services to or for the benefit of a blocked person, and to receiving them.
What the Panel says about implementation
The most useful sentence for anyone thinking about screening is a limitation. The Panel writes that “given the definition and scope of the assets freeze, the implementation of the financial sanctions has been limited”, and that the Houthis have several revenue sources through taxes and illegal measures, including seizure of companies, illegal levies, extortion and smuggling, and control of the telecommunications sector (S/2025/650). A regime designed around designated individuals and entities meets a revenue model that runs through control of ordinary businesses and state-like functions, not through accounts in a designated person’s name.
The report also records that the Panel could not establish official contact with the Houthi authorities or reach areas under their control, that 63 per cent of its correspondence was still unanswered at the reporting cut-off, and that no arms expert had yet been appointed, so the report omits a detailed arms analysis. Those constraints are part of the evidence base this site relies on: they limit what can be said, and what any screening programme can know.