Strait of Hormuz: Sanctions Considerations Persian Gulf Strait Authority and OFAC FAQ 1249 Articles Edward Barnes Published: May 14, 2026, Updated: May 28, 2026 Contact author Download article pdf OFAC designation of the Persian Gulf Strait Authority (27 May 2026) Since the publication of this article, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has formally designated the Persian Gulf Strait Authority as a Specially Designated National (“SDN”) under counter terrorism authorities. The designation reflects OFAC’s assessment that the PGSA is linked to, and operates in coordination with, the Islamic Revolutionary Guard Corps (“IRGC”), a U.S.-designated Foreign Terrorist Organization. This development materially elevates and clarifies the sanctions risk profile previously identified in OFAC FAQ 1249. Any transaction or dealing with the PGSA, including payments, provision of services, or facilitation of transit arrangements, is prohibited for U.S. persons absent authorisation. Non U.S. persons, including shipowners, charterers, insurers and financial institutions, may face sanctions exposure where they materially assist, sponsor or provide services to a designated entity or to the IRGC-linked scheme. OFAC has now effectively aligned its earlier guidance (that payments for safe passage may trigger sanctions risk) with a specific designated counterparty. OFAC has warned that cooperating with the PGSA, such as submitting vessel information, complying with routing instructions, or otherwise interacting with the scheme, may constitute the provision of support to, or receipt of services from, the IRGC. The designation therefore marks a shift from generalised sanctions risk to a clearly identified blocked counterparty. In practical terms, given the potentially significant legal, financial, and insurance consequences, Members should undertake robust sanctions due diligence and approach any interaction with the PGSA, or related transit arrangem