Iran sanctions – Increased Secondary Sanctions Risk for Operating in the Iranian Shipping Sector
On 24 August 2026, the U.S. Department of the Treasury launched Operation Economic Outcast, a new U.S. campaign targeting the Iranian regime and those facilitating its activities globally.
Five new sectoral determinations – shipping sector now covered
OFAC has issued five new sectoral determinations under Executive Order 13902, materially expanding the scope of potential secondary sanctions exposure.
Any person, regardless of location, who operates in or provides services in support of the following sectors of the Iranian economy may now be subject to designation:
- Digital assets
- Technology
- Gold
- Aviation
- Shipping
These new sectoral determinations represent the latest stage in a progressive expansion of US sectoral sanctions against Iran that has been underway since 2018. The full chronology of sectors now covered is as follows:
Date | Sectors |
August 2018 | Petroleum, petrochemicals |
November 2018 | Automotive |
May 2019 | Iron, steel, aluminium, copper |
January 2020 | Construction, mining, manufacturing, textiles |
October 2020 | Financial |
24 August 2026 | Aviation, digital assets, gold, shipping, technology |
The expanded secondary sanctions risk means that non-U.S. persons, including those with no U.S. operational footprint, face potential designation for operating in, or facilitating activity within, any of the determined sectors.
OFAC sector definitions
When E.O. 13902 was first issued in January 2020, OFAC published detailed FAQs defining each of the baseline sectors named in that order. OFAC can be expected to publish equivalent definitions for the five new sectors in due course, particularly for shipping, where the boundary between operating in Iran's shipping sector and merely providing incidental services to a vessel with an Iranian nexus will need to be clearly drawn
What’s prohibited?
Persons who knowingly engage in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with the above-named sectors of the Iranian economy risk exposure to blocking sanctions pursuant to E.O. 13902.
In addition, persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, persons designated pursuant to E.O. 13902 could themselves be designated.
Furthermore, foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for such designated persons risk exposure to U.S. correspondent account or payable-through account sanctions.
OFAC Alert: Strait of Hormuz passage
As reported in our 25 August 2026 news item, OFAC has separately issued an updated May 2026 Alert on the sanctions risks arising from Iranian demands for payments or other benefits in connection with passage through the Strait of Hormuz.
Members are reminded that engaging with the designated Persian Gulf Strait Authority (PGSA), Persian Gulf Marine Insurance Company (PGMIC), or HormuzSafe Marine Services Authority, including accepting insurance or responding to demands for guarantees of safe passage, carries sanctions exposure for both US and non-US persons.
Cover position
Members are therefore strongly advised not to engage in any such arrangements for a potential transit of the Strait of Hormuz. They are also reminded that cover is not available under the Club's Rules for any trade, voyage, or transaction that risks the Club being in breach of sanctions or other enforcement measures. Those with any questions on this or any other sanctions issue are asked to contact the Managers.