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 pressure against Iran, on May 29, 2026 OFAC issued updated guidance that builds upon the current enforcement posture detailed in our May 7th post by expanding prohibited conduct at the Strait of Hormuz.
The updated FAQ 1249 guidance states that prohibited conduct is not limited to monetary payments. U.S. persons are prohibited from receiving services from the Government of Iran, including guarantees of safe passage even when no payment is made. Additionally, FAQ 1249 now includes guidance on Iran’s newly established Persian Gulf Strait Authority (“PGSA”), which was created to collect tolls and extort vessels transiting the Strait of Hormuz. On May 27, OFAC designated the PGSA as a Specially Designated National (“SDN”) under U.S. counterterrorism authorities, based on its support for the Islamic Revolutionary Guard Corps, a sanctioned entity designated as a Foreign Terrorist Organization by the U.S. State Department. As a result of this SDN designation, the PGSA’s assets are blocked, and U.S. persons are generally prohibited from engaging in transactions or dealings with the PGSA, whether directly or indirectly.
We will continue to report on these developments, including those stemming from the White House’s announcement over the weekend regarding an agreement with Iran to reopen the Strait of Hormuz.
The authors thank Tamara Kissoon for her contribution to this blog.
