US Treasury Clarifies Ban on Key Waterway Payments
The US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued interpretive guidance on April 28th, formally prohibiting payments for transit through the Strait of Hormuz to Iranian authorities. The move aims to block a revenue stream for Iran from this strategically vital maritime chokepoint.
Scope of the Prohibition
The ban explicitly applies to:
- All US persons
- US financial institutions
- Foreign entities owned or controlled by US interests
These parties are barred from making direct or indirect payments for "safe passage" fees to the Government of Iran or Iran's Islamic Revolutionary Guard Corps (IRGC).
Significant Risk for Non-US Parties
OFAC emphasized that non-US persons and entities, including foreign financial institutions, also face "significant sanctions risk" for engaging in such payments. This stems from existing US sanctions against Iran and the IRGC related to non-proliferation and counter-terrorism. Conducting certain transactions with sanctioned parties could lead to secondary sanctions.
Expansion of Sanctions Lists
Concurrent with this guidance, OFAC designated 17 foreign individuals and 18 foreign entities to its Iran-related sanctions lists. This expansion underscores the ongoing pressure campaign against Iran's economic activities.
This directive places a new compliance burden on global shipping and trade entities operating near the Strait of Hormuz, requiring careful legal assessment to avoid severe penalties.