The U.S. Treasury's Office of Foreign Assets Control sanctioned two Iranian maritime insurance firms accused of running a Bitcoin-toll scheme for ships crossing the Strait of Hormuz. The same action blocked eight companies and eight vessels tied to a separate Iranian petroleum shadow-fleet network, and it lays out ownership-tracing and reporting duties that reach beyond the two named firms.
The U.S. Office of Foreign Assets Control added two Iranian maritime insurance firms to its Specially Designated Nationals list on July 29, naming HormuzSafe Marine Services Authority and Persian Gulf Marine Insurance Company as blocked counterparties for U.S. persons and for transactions within or transiting the United States. Treasury alleged that the two firms support an Islamic Revolutionary Guard Corps-backed scheme that forces commercial vessels to buy purported insurance for passage through the Strait of Hormuz. Treasury also said HormuzSafe accepts Bitcoin and other digital assets to bypass Western sanctions, though neither July 29 filing identifies wallet addresses or payment volume.
A second, separate shadow-fleet designation
The designation falls under Executive Order 13902 for operating in Iran's financial sector and subjects both firms to secondary sanctions. HormuzSafe had previously been described as a Bitcoin-settled insurance proposal. The July 29 action adds two named entities to an existing sanctions-risk framework. A separate shadow-fleet component of the same action designated eight companies for operating in Iran's petroleum sector and identified eight vessels as blocked property linked to them, forming a different group from the two insurance firms.
Compliance duties reach beyond exact-name matches
OFAC rules cover U.S. citizens and permanent residents wherever located, people and entities in the United States, and U.S.-incorporated companies and their foreign branches; the sanctions can also reach foreign entities owned or controlled by U.S. persons. Property belonging to HormuzSafe, PGMIC or another blocked person must be frozen once it enters the United States or a U.S. person's possession, and related transactions are generally prohibited unless authorized or exempt. An initial block must be reported to OFAC within 10 business days, the same deadline that applies when rules require rejecting a transaction that doesn't involve blockable property.
Under the 50 Percent Rule, an unlisted entity is blocked once one or more blocked persons own at least 50% of it, directly or indirectly and individually or in the aggregate. OFAC recommends ownership due diligence on transaction parties, and its insurance guidance separately recommends risk-based screening across policy issuance, renewal, amendments, claims and payments.
Foreign counterparties face a separate test
OFAC may impose civil penalties for sanctions violations on a strict-liability basis, meaning a person subject to U.S. jurisdiction can face civil liability without knowing a transaction was prohibited. Non-U.S. persons are barred from causing or conspiring to cause U.S. sanctions violations or engaging in evasion. Executive Order 13902 can also reach people who knowingly engage in significant sector-related transactions, people who materially support designated persons, and foreign financial institutions that knowingly facilitate significant transactions for them.
Separate Hormuz guidance warns that safe-passage payments or services can create significant sanctions exposure for non-U.S. actors. Transit through the strait alone is not the trigger described in the July 29 action; the applicable response instead depends on the counterparty, ownership, conduct, jurisdiction and any U.S. nexus involved.
Sources:
Trading involves risk.
Risk Disclaimer
