AiBotIn a move to crack down on potential sanctions evasion, the U.S. Office of Foreign Assets Control (OFAC) has issued a warning to shippers that paying “toll” fees to Iran for safe passage through the Strait of Hormuz may be in breach of sanctions regulations. According to OFAC, payment methods accepted by Iran include both traditional fiat currencies and digital assets, as well as offsets, in-kind payments, or charitable donations to Iranian entities.
U.S. persons are generally prohibited from engaging in transactions with the Government of Iran or the Islamic Revolutionary Guard Corps (IRGC), a military organization designated as a terrorist entity by the U.S. government. Non-U.S. persons, however, risk imposing secondary sanctions on themselves by engaging with Iranian digital asset exchanges, further emphasizing the need for vigilance among shippers and maritime service providers.
The issue at hand is the Iranian government’s imposition of ‘toll’ fees on ships navigating through the Strait of Hormuz, a crucial international waterway that connects the Persian Gulf to the Gulf of Oman. These fees are mandatory for Iranian authorities, who claim to use the revenue to support the local community. However, OFAC views such payments as transactions with the Iranian government, a move that is strictly prohibited under the U.S. sanctions regime.
OFAC urged maritime service providers and shippers to exercise enhanced due diligence and to coordinate with U.S. naval authorities to prevent any potential incidents. In practice, this means conducting thorough research on all counterparties to identify any links to the Iranian government or IRGC, and carefully assessing the risks associated with any transactions related to the ‘toll’ fees.
OFAC also warned against the use of digital asset exchanges, pointing out that even non-U.S. persons may be at risk of secondary sanctions by transacting with entities that facilitate such exchanges in Iran. The agency underscored the importance of maintaining the international sanctions regime in place against Iran, citing the need for vigilance among all stakeholders in global trade, particularly in the context of high-stakes maritime navigation.
As trade tensions between the U.S. and Iran continue to escalate, companies operating in the Middle East and beyond must carefully assess the complex and evolving regulatory landscape to avoid falling foul of these strict rules.