U.S. Treasury Expands Hormuz ‘Toll’ Warning, Puts Maritime Industry on Notice

The U.S. Treasury Department has widened its warning over reported Iranian “toll” demands in the Strait of Hormuz, issuing a new alert that lays out, in far more detail, the sanctions risks facing shipowners and the broader maritime supply chain.

The May 1 alert from the Office of Foreign Assets Control (OFAC) follows this week’s FAQ 1249 but moves beyond general guidance, spelling out how such payments could be structured and how easily they could trigger enforcement.

According to OFAC, Iranian demands for “safe passage” may not come in the form of straightforward fees. The agency said payments could take multiple forms, including cash, digital assets, offsets, informal swaps, or even in-kind transactions such as charitable donations routed through Iranian-linked organizations like the Iranian Red Crescent Society or Bonyad Mostazafan. 

The takeaway is that if value is transferred to the Iranian government or the Islamic Revolutionary Guard Corps in connection with passage, the sanctions risk is there.

For U.S. persons—and U.S.-controlled foreign entities—that risk is effectively a prohibition. Transactions involving Iran or the IRGC are broadly barred unless specifically authorized. But OFAC’s message is clearly aimed beyond U.S. companies.

Non-U.S. shipowners, insurers and financial institutions could also find themselves exposed through secondary sanctions, including the possibility of losing access to the U.S. financial system if they facilitate or participate in these arrangements. 

The alert also flags growing concern around digital payments, noting that Iranian crypto exchanges are considered blocked financial institutions, meaning even indirect involvement could create compliance problems.

One of the more notable elements in the alert is how directly it targets maritime service providers.

OFAC is urging companies to step up due diligence on vessels transiting Hormuz—looking closely at voyage plans, movements through Iranian waters, and any coordination with Iranian authorities. It also suggests asking counterparties directly whether any form of “safe passage” payment has been made or promised. 

For P&I clubs, brokers, port agents and others tied to vessel movements, it raises the bar on what “knowing your counterparty” actually means in practice.

“Service providers should ask counterparties for details on who they coordinated with to transit the Strait of Hormuz and if any safe passage fees were or will be paid to Iran,” OFAC’s alert reads.

The alert also makes clear that financial risk isn’t the only concern. OFAC notes that vessels operating near Iranian ports or coastline remain subject to the U.S. military’s blockade enforcement, and that Treasury guidance doesn’t override those authorities. 

Shipping through the strait is already under pressure from security threats, elevated insurance costs and uncertain transit conditions. The idea of informal or negotiated passage arrangements has been circulating in the market, even if never fully confirmed.

While OFAC’s alert doesn’t seem to validate those arrangements, it does make clear how Washington would treat them.

Combined with earlier guidance, OFAC latest alert makes clear that any system that conditions passage on payment to Iranian-linked entities is likely to be viewed as sanctionable, regardless of how it’s labeled or routed.

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