Since issuing its Frequently Asked Questions (“FAQ”) 1249 on April 28, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has updated its position with respect to “toll” payments to Iran for safe passage through the Strait of Hormuz. At the time of its publication, FAQ 1249 made it clear that payments to Iran for “safe passage” through the Strait of Hormuz are prohibited for U.S. persons. However, to further maximize…