May 29, 2026: OFAC Update, Part 2: Amended Iran-related Frequently Asked Questions


FAQ 1249 has been updated:

1249. Are “toll” payments to Iran for safe passage through the Strait of Hormuz authorized? Is receiving guarantees or services from Iran for or related to safe passage authorized, even when no payment is made?

Answer

No. Payments to and guarantees from the Government of Iran or the Islamic Revolutionary Guard Corps (IRGC), directly or indirectly, for safe passage through the Strait of Hormuz would not be authorized for U.S. persons, including U.S. financial institutions, or for U.S.-owned or -controlled foreign entities. Regardless of whether a payment is made, U.S. persons are prohibited from receiving services from the Government of Iran, including services related to a guarantee of safe passage. For additional guidance, please see “OFAC Alert: Sanctions Risks of Iranian Demands for Strait of Hormuz Passage.”

Iran created a new entity, the so-called Persian Gulf Strait Authority (PGSA), to collect tolls and extort vessels transiting the Strait of Hormuz. On May 27, OFAC designated PGSA pursuant to our counterterrorism authorities, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC. Cooperating with or engaging in direct or indirect transactions or dealings, including the receipt of services from the PGSA, carries sanctions risk.

Payments or services for or related to safe passage also create significant sanctions exposure for non-U.S. persons. Specifically, foreign financial institutions and other non-U.S. persons risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. This includes the Government of Iran and the IRGC, which is designated as a Foreign Terrorist Organization and sanctioned pursuant to several authorities, including nonproliferation and counterterrorism sanctions authorities.

Foreign persons that are engaged in certain transactions could also risk sanctions exposure under authorities such as Executive Order 13902, which authorizes sanctions on, among others, persons who have knowingly engaged in certain significant transactions involving determined sectors of the Iranian economy or who have been determined to operate in those sectors, including the financial and petroleum and petrochemical sectors.

Updated Date: May 29, 2026

Date Released

April 28, 2026


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