Sanctions Risks of Iranian Demands for Strait of Hormuz Passage (Alert)

Date issued: Aug. 24 2026

Last substantive commentary amendment:
Aug. 26 2026

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (301 words)

Notes:

[8-24-26 – Alert amended in connection with "Economic D-Day". See Treasury Launches Unprecedented Campaign Against Iranian Regime on Economic D-Day (Treasury Press Release).

Notable changes vis-à-vis original version include (i) specifying that “accepting insurance or other services or responding to information demands for guarantees of safe passage, even if there is no associated payment other exchange of value for these services” is prohibited and/or sanctionable, (ii) adding “government-to-government deals” as a category of prohibited/sanctionable conduct, (iii) specifying that “direct or indirect” transactions are covered, (iv) listing out “PGSA, PGMIC, Hormuz Safe” as sanctioned entities, (v) striking “Vessels of all nations entering or leaving Iranian ports and coastline are also subject to U.S. Central Command’s impartial naval blockade” (unclear why), and (vi) adding a due diligence requirement in connection with the provision of services to vessels to ensure that it is...