U.S. warns shippers of sanctions for paying Iran Hormuz tolls

The U.S. Treasury Department’s Office of Foreign Assets Control published guidance on May 1 warning U.S. and foreign shipping companies that payments to Iran for safe passage through the Strait of Hormuz could trigger sanctions. Related FAQs were posted April 28 and May 1.

The guidance states payments to the Iranian government, the Islamic Revolutionary Guard Corps or entities linked to them are not authorized for U.S. persons, U.S. financial institutions, or U.S.-owned or -controlled foreign entities. The agency warned non-U.S. persons also face significant sanctions exposure for transactions involving designated Iranian actors.

The guidance lists payment methods that could pose a risk, including fiat currency, cryptocurrency, informal swaps, offsets and nominal donations routed to groups such as the Iranian Red Crescent Society, Bonyad Mostazafan or Iranian embassy accounts. The guidance clarifies that Iranian digital-asset exchanges qualify as Iranian financial institutions, and that U.S.-connected property and interests in those platforms are blocked under Executive Order 13599.

OFAC cited Executive Order 13902, which authorizes sanctions on persons who engage in significant transactions with specified sectors of the Iranian economy. The guidance warns foreign banks that facilitate prohibited transactions may lose access to U.S. correspondent banking and dollar-clearing services.

The Strait of Hormuz, a narrow channel between Iran and Oman, carries roughly one-fifth of global petroleum flows. The guidance was issued amid a standoff over control of the waterway and Iran’s nuclear program; the agency noted it is aware of demands by Iranian authorities for fees or guarantees of safe passage.

OFAC did not grant a general license or safe harbor for toll payments. Shipowners, insurers and banks must choose between refusing payments and risking operational disruption in the strait, or making payments and risking U.S. sanctions enforcement. The U.K. Navy estimates traffic through the strait has fallen about 90% and that roughly 20,000 sailors remain aboard vessels in the Gulf.

Shipping companies, insurers and correspondent banks will need to update sanctions screening and compliance processes to reflect the guidance. The agency warned payments to entities connected to the Iranian state or the IRGC, regardless of form, could be treated as transactions with blocked persons and lead to enforcement action.