Date: July 29, 2026
Agency: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
Designations: Persian Gulf Marine Insurance Company; HormuzSafe Marine Services Authority; vessel owners and managers; eight identified vessels
Legal Basis: Iran-related sanctions authorities
Notable Feature: HormuzSafe expressly identified as accepting Bitcoin and other digital assets
Secondary-Sanctions Risk: Certain designated parties expressly identified as presenting secondary-sanctions risk

OFAC's action targets an alleged IRGC-backed arrangement requiring vessels transiting the Strait of Hormuz to purchase maritime "insurance" from designated entities. The scheme has two designated components:

Persian Gulf Marine Insurance Company: Designated as the insurance vehicle through which vessels transiting the Strait are required to obtain coverage. The designation blocks all property and interests in property of the company that are in the United States or come within the possession or control of U.S. persons.

HormuzSafe Marine Services Authority: Designated as the administrative body managing the compulsory transit-fee arrangement. OFAC expressly notes that HormuzSafe accepts Bitcoin and other digital assets as payment — a feature that extends the sanctions compliance obligation to cryptocurrency payment processors, exchanges, and wallet providers that may handle these transactions.

The designation of Persian Gulf Marine Insurance Company and HormuzSafe triggers the standard OFAC blocking prohibition: all property and interests in property of the designated entities that are in the United States or come within the possession or control of U.S. persons must be blocked and reported to OFAC. U.S. persons are prohibited from engaging in any transactions with the designated entities without an OFAC license.

OFAC's express identification of certain designated parties as presenting secondary-sanctions risk is significant. Secondary sanctions apply to non-U.S. persons who engage in specified conduct with designated parties, even if that conduct occurs entirely outside the United States and involves no U.S. persons or U.S. dollar transactions. The practical effect is that non-U.S. shipowners, charterers, insurers, and financial institutions that engage with the designated entities may themselves become subject to U.S. sanctions.

The secondary-sanctions risk is particularly acute for:

P&I clubs and marine insurers: Clubs and insurers that provide coverage to vessels that have paid the HormuzSafe transit fee may be deemed to have facilitated a transaction with a designated party. The insurance certificate itself — if it covers a vessel that has paid the compulsory fee — may constitute a prohibited transaction.

Banks and financial institutions: Banks that process payments related to the HormuzSafe transit fee, including payments made in fiat currency through correspondent banking channels, face secondary-sanctions exposure.

Commodity traders: Traders who purchase petroleum cargoes from vessels that have paid the HormuzSafe fee may be deemed to have indirectly facilitated a transaction with a designated party.

OFAC's express identification of Bitcoin and other digital asset payments as a feature of the HormuzSafe scheme extends the compliance obligation to:

Cryptocurrency exchanges: Exchanges that process transactions involving wallets associated with HormuzSafe must screen for OFAC-designated addresses. OFAC maintains a list of designated cryptocurrency wallet addresses, and exchanges are required to block transactions involving these addresses.

Payment processors: Any payment processor — whether handling fiat or digital assets — that processes a HormuzSafe transit fee payment faces potential OFAC liability.

Blockchain analytics: The identification of cryptocurrency payments in the designation creates an obligation for compliance teams to conduct blockchain analytics to identify whether any wallets in their customer base have transacted with HormuzSafe-associated addresses.

OFAC's 50% rule provides that any entity owned 50% or more by a designated person is itself treated as a designated party, even if not expressly listed on the SDN List. The designation of Persian Gulf Marine Insurance Company and HormuzSafe requires compliance teams to identify and screen all entities in which these companies hold a 50% or greater ownership interest.

Shipowners, charterers, P&I clubs, marine insurers, commodity traders, banks, brokers, ports, and logistics providers should immediately screen:

Vessel identifiers: Vessel names and IMO numbers must be screened against the SDN List. Screening by company name alone is insufficient — the eight designated vessels must be identified by IMO number and vessel name.

Beneficial ownership: The beneficial owners, technical managers, and commercial operators of vessels transiting the Strait of Hormuz must be screened. Vessels may be operated by non-designated entities while being beneficially owned by designated parties.

Insurance documentation: Maritime insurance certificates and compulsory transit-fee arrangements must be reviewed to determine whether any coverage has been obtained from or through designated entities.

Crypto wallets: Payment intermediaries and cryptocurrency exchanges must screen wallet addresses associated with HormuzSafe against OFAC's designated cryptocurrency address list.

Newly incorporated entities: The 50% rule requires screening of newly incorporated entities that may have been established by designated parties to circumvent sanctions.

Charterparties: Charterparties for vessels transiting the Strait of Hormuz should be reviewed for sanctions warranties, alternative-routing rights, blocked-payment procedures, off-hire allocation, and termination rights. Charterers who discover that a vessel has paid the HormuzSafe fee may need to invoke sanctions warranty provisions to terminate the charter or seek indemnification.

Bills of lading: Bills of lading for cargoes carried on vessels that have transited the Strait should be reviewed for sanctions representations and warranties.

Insurance contracts: Marine insurance contracts should be reviewed for sanctions exclusions and the insurer's rights to void coverage if the insured vessel has engaged in sanctioned transactions.

Turkish companies engaged in energy trading, shipping, and maritime services that involve the Strait of Hormuz face heightened compliance obligations following this designation. Turkey is a significant importer of energy from the Persian Gulf region, and Turkish shipping companies and traders may have existing relationships with entities in the designated supply chain.

Turkish companies with U.S. operations, U.S. dollar transactions, or U.S. correspondent banking relationships are subject to U.S. primary sanctions. Turkish companies without these U.S. nexus points may nonetheless face secondary-sanctions risk if they engage with the expressly identified secondary-sanctions parties.

This article is based on publicly available OFAC announcements. It does not constitute legal advice. Sanctions compliance requires individualized legal analysis.