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The U.S. Treasury Department's OFAC issued a new warning on May 1st, stating very clearly that any shipping company, insurer, or financial institution that pays tolls for the Strait of Hormuz will trigger sanctions risks. The warning applies regardless of whether the entity is American or non-American.
This time, the U.S. Treasury named all possible pathways. ① Fiat currency. ② Crypto assets. ③ Informal exchanges. ④ Physical payments. ⑤ Nominal charitable donations.
OFAC specifically mentioned that Iran’s digital asset exchanges are now considered sanctioned financial institutions, and even indirect involvement could expose entities to sanctions. Additionally, the Iranian Islamic Revolutionary Guard Corps (IRGC) has been designated as a foreign terrorist organization by the U.S., and paying tolls is considered substantial support to terrorists, with consequences including hefty fines and life imprisonment.
Of course, Iran is not sitting idle.
On April 26th, the Chairman of Iran’s Parliament’s National Security and Foreign Policy Committee directly stated that the 47-year era of hospitality is over. All ships passing through the Strait of Hormuz must pay a fee. The fee is reportedly about $1 per barrel of oil. Reports say Iran has received its first toll payment, credited to the Central Bank of Iran in the form of “cash foreign exchange.”
In terms of payment methods, crypto is explicitly an option. Earlier reports indicated that Iran accepts crypto assets, as well as various other methods like the Chinese yuan.
However, using crypto assets has a notable consequence. Once payment is made via cryptocurrency, everything will be recorded on a fully transparent blockchain ledger, with transaction addresses and counterparties traceable and reviewable. Essentially, this provides clear evidence for OFAC enforcement.
Currently, the average daily transit volume through the Strait of Hormuz has plummeted from 125-140 ships per day before the conflict to single digits. German company Hapag-Lloyd revealed that their weekly extra costs amount to about $50 million. For operators, the toll itself might be considered part of costs, but once touching the U.S. sanctions network, losing dollar settlement channels and being expelled from the global financial system are costs that cannot be measured in money.