1249. Are "toll" payments to Iran for safe passage through the Strait of Hormuz authorized?
No. Payments to the Government of Iran or the Islamic Revolutionary Guard Corps (IRGC), directly or indirectly, for safe passage through the Strait of Hormuz would not be authorized for U.S. persons, including U.S. financial institutions, or for U.S.-owned or -controlled foreign entities.
Such payments also create significant sanctions exposure for non-U.S. persons. Specifically, foreign financial institutions and other non-U.S. persons risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. This includes the Government of Iran and the IRGC, which is sanctioned pursuant to several authorities, including nonproliferation and counterterrorism sanctions authorities, and is designated as a Foreign Terrorist Organization.
Foreign persons that are engaged in certain transactions could also risk sanctions exposure under authorities such as Executive Order 13902, which authorizes...
1) This FAQ comes several weeks after the Iranian government set up a “toll” system for transit through the Strait of Hormuz, which appears to involve vessels registering vessels with the IRGC Navy and paying a “toll” for safe passage. Here, OFAC confirms that such payments are prohibited for “U.S. persons, including U.S. financial institutions, or for U.S.-owned or -controlled foreign entities.” The basis for the “U.S.-owned or -controlled foreign entities” statement is 560.215 of the ITSR.
2) The reporting available as of April 28, 2026 indicates that the “toll” system involves transiting the Strait of Hormuz through islands very close to the Iranian cost, and in any even in Iranian territorial waters. Query whether passage through the Straight of Hormuz through that area...