On 28 April 2026, OFAC issued FAQ 1249 confirming that payments to the Government of Iran or the Islamic Revolutionary Guard Corps (IRGC), whether made directly or indirectly, for safe passage through the Strait of Hormuz are not authorised under US sanctions. This applies to US persons, US financial institutions, and US-owned or US-controlled foreign entities.

OFAC has also made clear that non-US persons face significant sanctions exposure for making such payments. The IRGC is designated under multiple US authorities, including as a Foreign Terrorist Organisation and under counterterrorism executive orders, which broadens the basis on which enforcement action could be taken against any party facilitating or processing such payments.

Members with vessels transiting the Strait of Hormuz should be aware that any payment made to Iran or the IRGC in connection with transit may give rise to sanctions exposure, which could in turn affect the Club’s ability to provide cover or process claims in respect of the relevant voyage.

Members who receive demands for payment in connection with Strait of Hormuz transit, or who have questions about their exposure, should contact the Club for guidance.

The full FAQ is available here: OFAC FAQ 1249