OFAC Issues Warning: Strait of Hormuz Transit Compliance Alone May Trigger Iran Sanctions Violations

## OFAC Warns Maritime Industry on Iran Sanctions Risk in Hormuz Transits The US Treasury Department's Office of Foreign Assets Control (OFAC) has issued a stark warning to maritime operators, cautioning that engaging with sanctioned Iranian bodies in connection with Strait of Hormuz passage — even for the purpose of ensuring compliance with transit requirements — could itself constitute a breach of Iran sanctions, according to Seatrade Maritime. The guidance underscores a complex legal challenge facing shipowners, operators, and charterers whose vessels transit one of the world's most strategically critical waterways. The Strait of Hormuz, through which an estimated 20% of global oil trade passes, is subject to Iranian oversight claims that can require maritime companies to interact with Iranian authorities or entities that may appear on OFAC's Specially Designated Nationals (SDN) list. ### Implications for Operators The warning places maritime companies in a difficult compliance position: the practical necessity of communicating with Iranian bodies to secure safe passage through the strait may, under US sanctions law, trigger the very violations operators are seeking to avoid. OFAC's guidance signals that the agency will not treat operational necessity as an automatic safe harbour. For international shipping companies — particularly those with US dollar transactions, US-person employees, or US nexus in their corporate structures — the consequences of a sanctions breach can be severe, including substantial civil penalties and potential criminal liability. Compliance and legal teams across the industry are advised to review their vessel routing procedures, counterparty screening protocols, and existing guidance from flag states and P&I clubs regarding Hormuz transits. Operators should seek qualified legal counsel before engaging with any Iranian governmental or quasi-governmental body in connection with strait passage. ### Broader Sanctions Environment The OFAC advisory comes amid continued geopolitical tension in the Persian Gulf region and reflects a broader pattern of US authorities tightening enforcement around Iran-related maritime activity, including sanctions on shadow fleet operators, ship-to-ship transfers, and flag-of-convenience registries linked to Iranian oil exports. Maritime companies are encouraged to monitor OFAC guidance closely and ensure their compliance frameworks are updated to reflect the evolving regulatory landscape in the region. *Source: Seatrade Maritime*