The U.S. Treasury Department has issued new sanctions guidance warning that any payments linked to “safe passage” through the Strait of Hormuz involving Iran or the Islamic Revolutionary Guard Corps (IRGC) could expose shipowners, banks, and insurers to sanctions risks.
In Frequently Asked Question released by the Office of Foreign Assets Control (OFAC), the Treasury clarified that payments made directly or indirectly to the Government of Iran or the IRGC are not authorized for U.S. persons, including financial institutions and U.S.-controlled entities. The guidance further warns that non-U.S. companies could also face secondary sanctions exposure depending on the nature of the transactions.
The advisory specifically addresses growing international concern over reported “toll,” facilitation, or permission-based payment structures linked to transit through the Strait of Hormuz. While OFAC did not confirm that such payments are currently being collected, it emphasized that any arrangement involving designated Iranian entities would fall under existing sanctions restrictions.
At the United Nations Security Council, International Maritime Organization (IMO) Secretary-General Arsenio Dominguez has already rejected any notion of discriminatory transit arrangements, stating there is “no legal basis” for imposing payments or tolls for passage through an international strait. He reiterated that freedom of navigation is a fundamental principle of international maritime law and cannot be conditioned by ad hoc financial demands.
Shipping association BIMCO has warned that commercial confidence cannot be restored through informal or politically driven transit arrangements, stressing that operators require predictable safety conditions and clear shipping lanes rather than negotiated access frameworks.
The U.S. guidance effectively elevates the issue from political debate to formal compliance risk. It signals that even indirect financial transactions related to transit through Hormuz could fall under sanctions scrutiny.
