On April 28, 2026, the U.S. Office of Foreign Assets Control (“OFAC”) published FAQ 1249 regarding sanctions risks associated with “toll” payments to Iran for safe passage through the strait of Hormuz. Additionally, on April 28, 2026, OFAC published a sanctions Alert titled “Sanctions Risk of Dealing with Teapot Oil Refineries.” OFAC FAQ 1249 The FAQ makes clear that payments to the Government of Iran or the Islamic Revolutionary Guard Corps (IRGC), directly or indirectly, for safe passage through the Strait of Hormuz would not be authorized for U.S. persons, including financial institutions, or for U.S.-owned or controlled foreign entities. Such payments would also create significant sanctions exposure for non-U.S. persons.
Specifically, foreign financial institutions and other non-U.S. person’s risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons.
This includes the Government of Iran and the IRGC, which is sanctioned pursuant to several authorities, including non-proliferation and counterterrorism sanctions authorities, and is designated as a Foreign Terrorist Organization.
Full advisory at the following link.