U.S. Sanctions Iranian Firms Over Bitcoin Safe-Passage Scheme

The U.S. Department of the Treasury’s Office of Foreign Assets Control added HormuzSafe Marine Services Authority and Persian Gulf Marine Insurance Company to the Specially Designated Nationals list on July 29. The action blocks property of both entities and identifies them as operators in Iran’s financial sector subject to Executive Order 13902 and potential secondary sanctions.

Treasury alleges the two companies were involved in a scheme that compelled commercial vessels to purchase purported insurance or safe-passage services for travel through the Strait of Hormuz. The department says HormuzSafe accepted Bitcoin and other digital assets as part of an effort to evade Western sanctions. Treasury did not provide wallet addresses or details of payment volumes linked to the alleged digital-asset payments.

The designations were issued alongside a separate set of measures that targeted eight companies in Iran’s petroleum sector and listed eight vessels as blocked property. The petroleum companies and vessels are distinct from HormuzSafe and PGMIC.

The OFAC designation requires U.S. persons to block any covered property that comes into their possession or control and to report an initial block or a required rejection of a transaction to OFAC within 10 business days. U.S. persons include U.S. citizens and lawful permanent residents wherever located, people and entities in the United States, and U.S.-incorporated companies and their foreign branches. Blocking freezes the property and generally prohibits transactions involving it unless an authorization or exemption applies.

The sanctions reach extends beyond exact-name matches under the 50 Percent Rule. Any entity more than 50% owned, directly or indirectly, by one or more blocked persons is treated as blocked. OFAC advises enhanced ownership due diligence on transaction parties and account relationships and recommends risk-based screening across insurance activities, including policy issuance, renewals, amendments, claims and payments.

Civil penalties for violations can be imposed on a strict-liability basis for persons subject to U.S. jurisdiction, meaning civil enforcement may apply even without knowledge that a transaction was prohibited. For non-U.S. persons, exposure depends on conduct and any nexus to the United States. OFAC’s sector guidance explains Executive Order 13902 can reach foreign actors who knowingly engage in significant sector-related transactions, who materially support designated persons, or foreign financial institutions that knowingly facilitate significant transactions for them.

Treasury guidance on the designations warns that payments described as safe-passage or insurance can create sanctions exposure for non-U.S. actors. The guidance notes that mere transit through the Strait of Hormuz alone is not identified as a triggering factor in the July 29 action.

The designations add two named entities to the U.S. sanctions framework and include compliance guidance for financial institutions and companies involved in maritime insurance and related payments.