OFAC warned that digital asset payments tied to Strait of Hormuz passage can create sanctions exposure. The alert says digital assets do not reduce legal risk for maritime firms, financial institutions, insurers, or counterparties.
Key Takeaways:
OFAC warned crypto payments tied to Hormuz transit may trigger sanctions exposure. Reports say Iran operates a crypto-based toll system generating about $20 million in daily revenue. Foreign firms risk secondary sanctions and restricted access to U.S. financial system. OFAC Alert Raises Crypto Sanctions Risk for Hormuz Transit“These demands may include several payment options, including fiat currency, digital assets, offsets, informal swaps, or other in-kind payments, such as nominally charitable donations made to the Iranian Red Crescent Society, Bonyad Mostazafan, or Iranian embassy accounts.”
Maritime Firms Face Enforcement Pressure Over Digital Asset PaymentsTRM Labs estimates daily IRGC revenue at about $20 million. Outside the United States, sanctions exposure still applies. OFAC said foreign actors may face penalties for transactions involving the Government of Iran or the IRGC. Secondary sanctions could restrict access to the U.S. financial system. OFAC added:
“Non-U.S. persons engaging with blocked Iranian digital asset exchanges may also risk sanctions for operating in or supporting the sanctioned Iranian financial sector.”
Even indirect involvement can create liability if a transaction passes through U.S.-linked insurers, banks, or financial intermediaries. For maritime operators, that risk shifts focus to payment transparency and counterparty checks. OFAC urged firms to review vessels, identify who arranged transit, and determine whether any Iran-linked fees were paid or promised. Under the IRGC system, ships must submit ownership and cargo details through intermediaries before approval. Payments are then sent to designated wallets via a “conversion window” on Qeshm Island, followed by a VHF-issued passcode and naval escort. This process makes verifying wallet addresses and counterparties critical for compliance.
