OFAC adds PERSIAN GULF STRAIT AUTHORITY to SDN List under EO 13224 (IRGC-linked)
US persons must block PERSIAN GULF STRAIT AUTHORITY and any entity 50%+ owned by it; non-US financial institutions and maritime operators face secondary-sanctions exposure under EO 13224 §1(b)
- — Bank sanctions-screening teams at US financial institutions must add PERSIAN GULF STRAIT AUTHORITY to SDN filters and block all transfers involving the entity or any entity 50% or more owned by it (singly or aggregated with other blocked persons) under OFAC's 50% rule — failing to block constitutes a prohibited transaction under SDN authorities and carries strict liability for the institution.
- — Sanctions compliance teams at non-US financial institutions must refuse or unwind transactions providing funds, goods, or services to PGSA or its 50%+ owned subsidiaries — §1(b) of EO 13224 carries secondary-sanctions exposure including potential loss of US correspondent banking access and SDN listing of the institution itself.
- — Maritime insurers (hull, cargo, P&I clubs), shipping companies, charterers, and ship managers with Strait of Hormuz transit or Iranian-port operations must screen vessel ownership chains, charterer parties, port-call counterparties, beneficial cargo interests, and brokerage agents for PGSA involvement — policies covering PGSA-linked voyages, vessels calling Iranian ports under PGSA jurisdiction, and cargoes routed through PGSA-controlled waters face blocking and underwriting exposure.
Full decision brief
See the decision layer
Use 1 free preview to unlock implications, who’s affected, what to watch, and Clarify for this brief.
2 free previews left this month · Resets 1 Jun