US FAQ 1249 – “toll” payments through Strait of Hormuz breach US sanctions

1 May 2026

The US has issued FAQ 1249 to address paying tolls for safe passage through the Strait of Hormuz. Iran has said it will charge a fee of up to $2m per vessel passing through the Strait. The FAQ says such payments would breach US sanctions on Iran because:

• US people/entities and US-owned/controlled foreign entities are prohibited from making payments – whether made directly or indirectly – to Iran’s government.

• “Toll” payments create significant sanctions exposure for non-US persons if they engage in transactions or activities involving designated or otherwise blocked persons, including the Iranian government and the IRGC.

• Foreign persons that are engaged in certain transactions could also risk sanctions exposure under authorities such as Executive Order 13902, which authorises sanctions on people/entities who have knowingly engaged in significant transactions in certain sectors of Iran’s economy.

See our US-Iran pages for a consolidated list of US Iran sanctions FAQs.