Iran sanctions – OFAC warning on Strait of Hormuz passage
OFAC have issued a warning of the sanctions risks for both US and non-US persons in the payment of “tolls” or other forms of benefit to Iran in return for safe passage through the Strait of Hormuz.
They note that:
“U.S. and non-U.S. persons risk sanctions or penalties by engaging with the designated so-called Persian Gulf Strait Authority (PGSA), Persian Gulf Marine Insurance Company (PGMIC), and HormuzSafe Marine Services Authority (Hormuz Safe), including by accepting insurance or other services or responding to information demands for guarantees of safe passage, even if there is no associated payment or other exchange of value for these services.”
A wide variety of potential payment mechanisms are listed as being within scope, including supposed charitable donations. OFAC warn of the sanctions exposure of making any such payments or soliciting guarantees of safe passage from Iran, regardless of the payment structure.
In addition to describing primary sanctions applicable to US persons, OFAC also detail wide-ranging potential secondary sanctions exposure for non-US persons, including potential civil and criminal enforcement in certain scenarios.
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.