Direct answer
The screening question changed after May 27. A Hormuz safe-passage request is no longer only a broad review of whether value may reach Iran. Teams now have a named sanctioned counterparty to check: the Persian Gulf Strait Authority (PGSA).
OFAC added PGSA to the Specially Designated Nationals and Blocked Persons List on May 27, 2026. Two days later, OFAC updated FAQ 1249 to state that cooperating with PGSA or engaging in direct or indirect transactions or dealings with it, including receiving services from PGSA, carries sanctions risk.
A typical friction point is a request described as a coordination fee or passage assurance rather than a toll. Finance may see no conventional payment, while the vessel team sees a service arrangement. After the PGSA update, both facts belong in the same screening record.
How is this different from the earlier Hormuz guidance?
The May 11 Hormuz sanctions-risk guide covered the broader issue: Iranian safe-passage demands should not be treated as routine operating costs merely because the method or invoice label changes.
That earlier framework still matters. OFAC’s May 1 alert noted that safe-passage demands can involve different methods of transferring value, including fiat currency, digital assets, offsets, informal swaps, in-kind payments, and nominally charitable donations.
The new article has a narrower purpose. The May 27 designation and May 29 FAQ update add PGSA-specific transaction screening: is PGSA involved directly or indirectly, and is a vessel or another party receiving services from PGSA even when no obvious payment appears?
What are the PGSA-specific screening boundaries?
| Screening category | What changed or remains in force | Question for the shared review record |
|---|---|---|
| Direct or indirect dealings with PGSA | FAQ 1249 states that cooperating with PGSA or engaging in direct or indirect transactions or dealings with it carries sanctions risk. | Is PGSA a requester, recipient, beneficiary, intermediary, or coordinating party? |
| Receipt of PGSA services | FAQ 1249 expressly includes receiving services from PGSA. A no-payment structure does not end the PGSA inquiry. | Is PGSA providing coordination, assurance, or another passage-related service? |
| Government of Iran or IRGC payments and guarantees | FAQ 1249 states that direct or indirect safe-passage payments to, and guarantees from, the Government of Iran or the Islamic Revolutionary Guard Corps (IRGC) are not authorized for U.S. persons, including U.S. financial institutions, or for U.S.-owned or -controlled foreign entities. | Does the arrangement involve a payment, indirect transfer, or guarantee connected to the Government of Iran or the IRGC? |
| Non-U.S. sanctions exposure | FAQ 1249 describes significant sanctions exposure for non-U.S. persons from certain safe-passage payments, services, transactions, or activities. | Does a non-U.S. structure still involve PGSA, another blocked person, or conduct covered by OFAC’s warning? |
The detail I would separate first is the service question. A review limited to outgoing payments can miss a passage arrangement where the relevant fact is what the vessel receives and from whom.
Which facts should teams put in one record?
This update calls for a focused record, not another broad maritime checklist. Shipping, insurance, reinsurance, and finance teams should align on four questions:
- Is PGSA directly or indirectly involved in the request, arrangement, or service?
- Is any party receiving a passage-related service or guarantee even if no conventional payment is made?
- Does the structure involve the Government of Iran, the IRGC, another blocked person, or an intermediary acting for one of them?
- Are U.S. persons, U.S. financial institutions, or U.S.-owned or -controlled foreign entities participating in the transaction or supporting services?
Invoice names remain useful evidence, but they are not the decision rule. The screening boundary follows the parties, services, and substance of the arrangement.
What should teams monitor next?
The practical watch point is OFAC’s wording, not a forecast about military conditions in the Strait.
- Check whether OFAC revises FAQ 1249 again.
- Monitor OFAC notices for additional PGSA-related designations.
- Compare new passage requests against the four PGSA-focused categories above.
- Confirm that shipping, insurance, and finance teams are reviewing the same counterparties, intermediaries, and services.
The checkpoint after the PGSA designation is specific: identify PGSA involvement first, then map payments, guarantees, services, and participating parties before reaching a transaction-specific conclusion.
Official sources
Frequently Asked Questions
The earlier guidance focused broadly on Iranian safe-passage demands and payment methods. The May 27 designation and May 29 FAQ update add PGSA as a named sanctioned counterparty and state that dealings with PGSA, including receipt of its services, carry sanctions risk.
Yes. FAQ 1249 states that receiving services from PGSA carries sanctions risk. It also states that U.S. persons are prohibited from receiving services from the Government of Iran, including services related to a safe-passage guarantee, regardless of whether payment is made.
No. Teams should also review direct or indirect safe-passage payments to, and guarantees from, the Government of Iran or the IRGC, as well as the involvement of blocked persons and intermediaries.
No. FAQ 1249 describes significant sanctions exposure for non-U.S. persons from certain safe-passage payments, services, transactions, or activities.
Official Sources
- OFAC FAQ 1249U.S. Department of the Treasury, Office of Foreign Assets Control
- OFAC PGSA designationU.S. Department of the Treasury, Office of Foreign Assets Control
- OFAC Hormuz alertU.S. Department of the Treasury, Office of Foreign Assets Control