After Iran published a list of 45 “non-compliant vessels,” the United States issued an updated sanctions risk advisory concerning passage through the Strait of Hormuz. On August 24, local time, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) warned that both U.S. and non-U.S. persons could face U.S. sanctions risks from certain dealings with Iranian entities responsible for managing passage through the Strait. More importantly, such risks do not depend on whether a payment is made. Even without an actual payment, accepting related insurance or other services or responding to information requests from Iranian authorities to obtain safe passage could create sanctions exposure. Freight forwarders now need to consider not only whether routes through the Strait remain open but also compliance risks involving carrier arrangements, related services, and transactions.

Key Highlights 

• Updated U.S. advisory: The United States has updated its Strait of Hormuz sanctions risk advisory, which also requires attention from non-U.S. companies. 

• Risks beyond payment: Certain dealings with relevant Iranian entities could create sanctions exposure even when no payment is made. 

• Overlapping risks: Iran’s list of 45 “non-compliant vessels” creates an overlap between transit and sanctions risks. 

• Freight forwarder considerations: Freight forwarders handling related shipments need to review routes, service providers, and compliance risks in related transactions.

Latest U.S. Advisory: Strait of Hormuz Transit Involves More Than Payments

On August 24, OFAC issued an updated advisory titled “Sanctions Risks Associated with Iranian Requirements for Passage Through the Strait of Hormuz.” It updates the related advisory issued on May 1 this year. OFAC specifically identified three Iranian entities connected with passage through the Strait of Hormuz: the Persian Gulf Strait Authority (PGSA), Persian Gulf Marine Insurance Company (PGMIC), and HormuzSafe Marine Services Authority (Hormuz Safe). PGSA was designated under U.S. sanctions on May 27, while PGMIC and Hormuz Safe were designated on July 29.

The main issue for freight forwarders is that the risk is not limited to payments. According to OFAC, both U.S. and non-U.S. persons could face sanctions exposure from certain dealings with these entities. Such dealings may include accepting insurance or other services provided by Iranian entities, responding to information requests concerning safe passage, or seeking related assurances to obtain safe passage, even when no payment is made. Freight forwarders handling shipments through the Strait of Hormuz should therefore consider not only Freight Charges and the Paying Party but also the service providers involved in the voyage and the related business arrangements.

Iran Lists 45 “Non-Compliant Vessels,” Further Complicating Transit Risks

One day before the United States updated its advisory, Iran published a list of 45 “non-compliant vessels” and said the vessels could face fines, detention, or cargo confiscation. Iran also warned that other vessels engaged in Ship-to-Ship Transfers (STS) or similar operations with listed vessels could be added to the list.

For freight forwarders, this means that uncertainty surrounding Strait of Hormuz shipments is increasing. Iran is tightening its transit requirements, while the United States is warning of broader sanctions risks, and the two sets of requirements do not fully align. However, this does not mean that cargo transiting the Strait of Hormuz will automatically trigger U.S. sanctions. The specific risk depends on the counterparties, services involved, flow of funds, and whether sanctioned entities are involved.

Freight Forwarders Should Look Beyond Schedules and Freight Rates

When cargo is expected to transit the Strait of Hormuz, freight forwarders should determine the actual route before arranging transportation, whether it involves Iranian waters, and whether the carrier or related service arrangements involve Iranian entities or services. If a customer requests a specific route, the carrier’s actual routing should also be reviewed, as routing arrangements may vary from one sailing to another during the same period.

Insurance, transit services, Ship-to-Ship Transfers (STS), and other voyage-related arrangements also require attention. Particularly when conditions are changing quickly, freight forwarders need to avoid discovering problems with the carrier’s route or related service arrangements only after space has already been booked and costs have been incurred. The route, carrier arrangements, and compliance status of the relevant counterparties should therefore be clarified before shipment.

Future Risks Will Also Depend on Carrier Routing Decisions

From Iran’s publication of a list of 45 “non-compliant vessels” to the U.S. update of its Strait of Hormuz sanctions risk advisory, risks surrounding this major global shipping route have expanded beyond traditional navigational safety to sanctions and supply chain operations. Freight forwarders handling Middle East, Gulf, and related transshipment business should continue to monitor carrier route adjustments and any impact on insurance, transit services, and other arrangements.

The situation in the Strait of Hormuz cannot currently be reduced to whether vessels can or cannot transit. For freight forwarders, the more practical questions are which route a shipment will take, which carrier will carry it, which services will be involved, and whether the overall transportation arrangement can be executed reliably. As Iranian and U.S. policies continue to change, further adjustments to routes, schedules, and business arrangements remain possible.

Sources and Disclaimer 

This article is based on information from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), publicly available information from Iranian authorities, and other public sources. It is provided solely for industry reference and does not constitute legal, sanctions compliance, or shipping operations advice.