On 24 August 2026 the United States Treasury announced a campaign of Iran measures under the name Operation Economic Outcast. The operative instrument for shipping is a determination made by the Director of OFAC under section 1(a)(i) of Executive Order 13902, effective 24 August 2026 and published in the Federal Register on 27 August 2026, applying that section to the aviation, digital asset, gold, shipping and technology sectors of the Iranian economy. These join the construction, mining, manufacturing, textiles, financial, petroleum and petrochemical sectors already covered. OFAC has not defined what it means to operate in the new sectors.

Approximately sixty individuals, entities and vessels were designated the same day across Treasury and the State Department. OFAC separately reissued its alert of 1 May 2026 on Iranian demands for Strait of Hormuz passage, and suspended five Iran related general licenses, with wind down of previously authorised transactions permitted under General License BB only until 8 September 2026.

The sector determination blocks no one by itself. What it does is widen the authority under which OFAC may designate, and it does so irrespective of whether the person concerned has United States operations, United States person employees or dollar touchpoints. The more immediate exposure sits in the reissued Hormuz alert. OFAC states that United States and non United States persons risk sanctions or penalties by engaging with the so called Persian Gulf Strait Authority, the Persian Gulf Marine Insurance Company and HormuzSafe Marine Services Authority, including by accepting insurance or other services from them, or by responding to their information demands for guarantees of safe passage, even where no payment or other exchange of value follows.

Payment is read broadly and is stated to extend to digital assets, offsets, government to government arrangements, informal swaps and payments in kind, including nominally charitable donations. For P&I and Hull cover the acceptance of Iranian marine insurance for passage is a distinct problem, because it is the receipt of a service from a designated entity rather than a payment, and it is likely to engage the sanctions provisions in the underlying cover. OFAC further warns that non United States persons could face civil and criminal enforcement liability where such payments cause United States persons, including insurers and reinsurers, to violate sanctions, which brings the reinsurance chain into the analysis.

Before any Strait of Hormuz transit, members should treat the Strait as operationally unavailable. Establish and record how passage is being coordinated, by whom, and whether any fee, guarantee, information response or service, including insurance, has been sought from or provided by an Iranian body. Do not respond to demands from the three named entities without first taking advice.

Separately, members should rescreen counterparties, vessels, managers, beneficial owners and payment chains against the SDN List, including ownership links under OFAC’s 50% rule, rather than relying on press summaries of the designation count. Review charterparty sanctions and war risks provisions to establish who carries the cost and who takes the transit decision. Confirm notification requirements and additional premium terms for the region with your usual broker before the vessel enters the listed area. Anything relying on the suspended general licenses must be wound down by 8 September 2026. Members should also anticipate enhanced due diligence questions from insurers, brokers, banks and bunker suppliers, since OFAC expressly encourages maritime service providers to ask counterparties who they coordinated with to transit and whether fees were paid or services accepted from Iran.

The Club is assessing its own exposure in its capacity as an EU operator providing services.  Members remain responsible for conducting their own screening and for satisfying themselves as to their own position.

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The information in this Member Alert is provided for guidance only. Members should seek specific advice regarding their individual circumstances. While the Club has taken reasonable care in preparing this publication, it accepts no responsibility for any errors or omissions, or for any consequences arising from reliance on the information contained herein.