On August 24, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated alert concerning the sanctions risks associated with Iranian demands for “toll” payments or other requirements for safe passage through the Strait of Hormuz. On the same date, OFAC issued a determination expanding the application of Executive Order 13902 to the shipping, aviation, digital asset, gold and technology sectors of the Iranian economy.
Key Takeaways for Members: • Strait of Hormuz passage: U.S. and non-U.S. persons face significant sanctions exposure if they deal with the Persian Gulf Strait Authority (PGSA), Persian Gulf Marine Insurance Company (PGMIC), or HormuzSafe Marine Services Authority (Hormuz Safe).
- Safe Passage payments: OFAC warns that sanctions exposure may arise from payments or other forms of value provided in connection with safe passage, including currency, digital assets, offsets, government-to-government arrangements, informal swaps and certain in-kind or purported charitable payments, especially in relation to any one of the above entities. • Insurance and Services: The sanctions risks are not limited to payments. Accepting insurance, other services, or responding to information requests or guarantees concerning safe passage from designated Iranian entities may also result in sanctions exposure. • Enhanced due diligence: Maritime service providers continue to be strongly encouraged to conduct enhanced due diligence on vessels transiting the Strait of Hormuz, including reviewing voyage arrangements, Iranian territorial-water transits, counterparties, safe passage fees and any services or insurance obtained from Iran.
Full advisory at the following link.