In late May 2026, the captain of a crude-oil tanker approaching the Strait of Hormuz from the Gulf of Oman received a radio call from an Iranian station identifying itself as the “Persian Gulf Strait Authority.” Before the vessel could proceed, the station transmitted a questionnaire: Who is the beneficial owner? What nationalities are represented in the crew? What cargo is aboard, and in what quantity? Who is the protection and indemnity insurer, and what is the policy number? According to accounts circulated by maritime security firms and trade publications, the list runs to more than 40 items. The tanker’s operator, a company with financing routed through New York, faced a question that no amount of seamanship could answer: respond and risk triggering a payment demand that violates U.S. sanctions, or refuse and risk an Iranian naval boarding in one of the world’s most critical shipping lanes.
That dilemma is now confronting a growing number of shipowners, charterers, and insurers with ties to the United States. The U.S. Treasury’s Office of Foreign Assets Control has drawn a hard line, while Iran appears to be asserting new procedural authority over strait transit. The collision between these two positions is playing out in a 21-mile-wide waterway through which the U.S. Energy Information Administration estimates roughly one-fifth of the world’s petroleum liquids pass every day.
OFAC’s prohibition: what the U.S. government has put in writing
The clearest piece of this puzzle comes from Washington. OFAC published FAQ 1249, which states that payments to the Government of Iran or the Islamic Revolutionary Guard Corps for safe passage through the Strait of Hormuz “are not authorized” for U.S. persons, U.S. financial institutions, or U.S.-owned and U.S.-controlled foreign entities. The language is unusually broad. It covers not just American-flagged ships but any company in which a U.S. person holds a controlling interest, and it extends to banks that clear dollar transactions on behalf of those entities.
Treasury reinforced the point with a separate advisory directed at maritime actors, naming shipowners, charterers, and insurers as the audiences most exposed. The advisory warns that Iranian demands for payment in exchange for Hormuz passage create sanctions liability for anyone in the transaction chain and signals that Treasury expects the private sector to build internal compliance controls rather than wait for case-by-case enforcement guidance.
Together, the two documents establish a legal boundary with real teeth. Any entity with a U.S. nexus that pays Iran or the IRGC for Hormuz transit risks asset freezes, exclusion from the dollar-clearing system, and civil or criminal penalties. The guidance draws no distinction between a formal toll and an informal facilitation fee, meaning even ambiguous charges could trigger enforcement scrutiny. For compliance officers, the safest reading is the strictest one: if a charge can plausibly be characterized as payment for safe passage, treat it as prohibited.
The Iranian questionnaire: what industry sources describe
The Iranian side of the story is harder to pin down. Multiple maritime security advisories and trade press reports describe a body called the “Persian Gulf Strait Authority” that requires vessels to complete a detailed questionnaire before receiving transit clearance. The reported questions span beneficial ownership structures, crew nationalities, cargo manifests, and the names and policy numbers of P&I insurers. Some accounts put the total at more than 40 individual data points.
No primary Iranian government text establishing this authority or specifying its data requirements has been published in English or confirmed through official channels accessible to Western researchers as of June 2026. That gap matters because the nature of the demand shapes the sanctions risk. If the questionnaire is a precursor to a formal toll, any resulting payment falls squarely within the OFAC prohibition. If it functions as a navigational or security check with no financial component, the direct sanctions exposure is lower, though the intelligence value of the collected data could still raise red flags for Western governments.
Competing accounts also exist about what happens on the water. Some advisories describe Iranian naval vessels, often from the IRGC Navy rather than the regular Islamic Republic of Iran Navy, boarding or diverting tankers that failed to respond to radio queries. Other operators report transiting without incident, suggesting the process may be applied selectively, possibly targeting vessels linked to countries or companies Tehran considers hostile. Neither version can be fully confirmed from public records, and the operational picture likely shifts with the broader temperature of U.S.-Iran relations.
Why the legal geography is so complicated
The Strait of Hormuz is not a simple open-water passage. Iran controls the northern shore; Oman controls the southern shore and the Musandam Peninsula. The internationally recognized Traffic Separation Scheme routes inbound and outbound shipping lanes through waters where Iranian and Omani territorial claims overlap with transit-passage rights under the United Nations Convention on the Law of the Sea. UNCLOS Article 38 grants all ships the right of transit passage through straits used for international navigation, a principle the United States and its allies have long insisted applies to Hormuz regardless of Iranian domestic regulations.
Iran has historically taken a narrower view, arguing that foreign warships and certain commercial vessels need prior authorization. The reported questionnaire, if it carries the force of Iranian domestic law, could represent an extension of that position into routine commercial shipping. For shipowners, the practical question is not which legal framework is correct in theory but which authority can impose consequences on a given voyage. A tanker transiting Hormuz is physically within reach of Iranian patrol boats and simultaneously within the financial reach of OFAC. Both can act, and neither defers to the other.
What operators with U.S. exposure should be doing now
Richard Gharis, a Washington-based sanctions attorney who advises shipping clients, told the trade publication TradeWinds earlier this year that the OFAC guidance “effectively forces U.S.-nexus companies to choose compliance over convenience.” That choice starts with contracts. Shipowners and charterers should review existing charter party agreements, insurance policies, and agency arrangements for any clause that could result in a payment to an Iranian government entity or the IRGC for strait passage. Flagging those provisions with compliance teams and, where necessary, restructuring contracts to ensure no U.S. person or controlled entity bears liability for such a payment is the baseline step. The OFAC guidance gives companies a clear legal basis for refusing these charges, and documenting that refusal creates an audit trail useful in any future regulatory inquiry.
Beyond contracts, firms need to map their corporate structures and financing chains to identify where U.S. jurisdiction attaches. A non-U.S. shipowner that relies on dollar financing, U.S. insurance markets, or a U.S.-controlled parent company may find its room to maneuver is narrower than it appears. Banks and insurers, for their part, are likely to tighten credit terms or coverage for operators they view as high-risk, adding commercial pressure on top of the legal exposure.
Some operators are also weighing route alternatives. Diverting around the Cape of Good Hope adds roughly 10 to 15 days and significant fuel costs to a voyage from the Arabian Gulf to Europe or North America, but for certain cargoes and certain risk profiles, the math may favor the longer route. That calculus depends on freight rates, insurance premiums, and how aggressively Iran enforces its questionnaire process in any given week.
The structural bind that will not resolve quickly
At its core, this is a story about two governments projecting authority over the same narrow waterway through different instruments. Iran uses physical proximity and naval presence. The United States uses the global dollar-clearing system and the threat of financial exclusion. Shipping companies occupy the space where those two projections of power overlap, forced to satisfy one set of demands without violating the other.
No public OFAC enforcement action has yet targeted a Hormuz transit payment specifically, based on a review of published cases through May 2026. But Treasury has a well-established pattern of issuing guidance documents to put industry on notice before pursuing penalties, building a compliance expectation that strengthens future enforcement cases. The absence of a precedent case is not evidence of tolerance; it is more likely a ticking clock.
For now, the only certainties are the ones OFAC has written down: U.S.-linked entities may not pay Iran or the IRGC for safe passage, full stop. Everything else, including how to respond to radio queries, when to reroute, and which voyages to accept, will be shaped by each operator’s risk tolerance, the quality of its intelligence, and the willingness of its lawyers and insurers to navigate a chokepoint where local security demands and extraterritorial financial rules are pulling in opposite directions.
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*This article was researched with the help of AI, with human editors creating the final content.
