STEAMSHIP MUTUAL UNDERWRITING ASSOCIATION LIMITED Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (Registered in England and Wales – Registration number 105461. PRA and FCA registration number 202548) MANAGERS: STEAMSHIP P&I MANAGEMENT LLP SPIM is an appointed representative of Steamship Insurance Management Services Limited which is authorised and regulated by the Financial Conduct Authority (Registered in England and Wales – Registration Number OC376859. FCA registration number 597046) Club Circular Sanctions Update – Yemen Trading and Support for the Houthi Terrorist Network April 2025 Dear Members 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 April 9, 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” here 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 non-U.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 here 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. STEAMSHIP MUTUAL UNDERWRITING ASSOCIATION LIMITED Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (Registered in England and Wales – Registration number 105461. PRA and FCA registration number 202548) MANAGERS: STEAMSHIP P&I MANAGEMENT LLP SPIM is an appointed representative of Steamship Insurance Management Services Limited which is authorised and regulated by the Financial Conduct Authority (Registered in England and Wales – Registration Number OC376859. FCA registration number 597046) 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.” here. Please note that GL 26A also does not authorize any payments to Ansarallah or an entit