Sanctions Evasion Reference

Insurance against a risk the seller creates

Treasury designated two Iranian maritime insurance entities in 2026 for compelling vessels transiting the Strait of Hormuz to buy IRGC-approved policies, accepting payment in digital assets.

period

2026

outcome

Designation

parties

Persian Gulf Marine Insurance Company; HormuzSafe Marine Services Authority; Islamic Revolutionary Guard Corps

programmes

Islamic Republic of Iran

reviewed

2026-08-20

Designated on 29 July 2026 under Executive Order 13902, alongside eight shipping companies and vessel operators. An unusual entry in the marine insurance material, because the cover here is not merely unverifiable — it is the instrument.

The scheme

Treasury describes an IRGC-backed arrangement compelling commercial vessels transiting the Strait of Hormuz to purchase mandatory “insurance” policies. Through Persian Gulf Marine Insurance Company and HormuzSafe Marine Services Authority, in Treasury’s words, “the regime brokers IRGC-approved policies designed to extract revenue under the guise of maritime services.”

The policies purport to protect vessels against risks including seizure. Treasury’s observation is that those risks are “overwhelmingly created by Iran itself.”

Payment is accepted in digital assets: HormuzSafe “accepts payment in Bitcoin and other digital assets as part of the regime’s attempts to bypass Western sanctions.”

Why it belongs on the insurance page

The opaque marine insurance page sets out three patterns: the unidentifiable insurer, cover the named insurer does not confirm, and policies rendered ineffective in practice. This is a fourth, and it is worse than any of them.

The established protection and indemnity market exists to answer one question — who pays when there is a spill or a casualty. Its members are mutuals with published rules and known reinsurance, and a claim can be tested. A policy whose economic function is to collect a transit fee, underwritten by an entity whose capacity to meet a marine casualty claim has never been demonstrated, provides none of that. A vessel carrying it is, for practical purposes, uninsured while holding a certificate.

For a port state or a charterer, the test is unchanged and remains the one the 2020 advisory states: whether the provider can be identified and whether its ability to meet a claim can be established.

The digital asset leg

The payment channel is the detail worth noting. A designated entity cannot be paid through correspondent banking, so a fee-collecting operation needs a rail that does not touch it. Accepting bitcoin and other digital assets solves the transfer problem, and it is the same reasoning that puts stablecoins into commercial settlement elsewhere on this site.

Scope note

The designation identifies eight vessels by name and IMO number. Those records are vessel- level and are deliberately not reproduced here; they are the province of the sister vessels site.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Iran sanctions — A layered set of US, EU and UN measures dating from 1979 and substantially rebuilt after 2018, covering energy, finance, shipping, and proliferation-related procurement.

Enforcement documents and sources

  1. Treasury Disrupts Iranian Regime's Strait of Hormuz Extortion Network. U.S. Department of the Treasury, 2026. Press release sb0581, 29 July 2026.
  2. Guidance to Address Illicit Shipping and Sanctions Evasion Practices. U.S. Department of State, U.S. Department of the Treasury and U.S. Coast Guard, 2020. Global maritime advisory, 14 May 2020.
  3. Sanctions Advisory for the Maritime Oil Industry and Related Sectors. U.S. Department of the Treasury, Office of Foreign Assets Control, 2023. Price cap advisory, 12 October 2023.
  4. Sanctions Compliance Guidance for the Virtual Currency Industry. U.S. Department of the Treasury, Office of Foreign Assets Control, 2021.

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