The U.S. Treasury’s Office of Foreign Assets Control on July 29 added two Iranian insurance firms to its Specially Designated Nationals list, accusing them of accepting Bitcoin and other digital assets to help vessels bypass Western sanctions while transiting the Strait of Hormuz. HormuzSafe Marine Insurance Services Authority and Persian Gulf Marine Insurance Company were designated under Executive Order 13902 for operating in Iran’s financial sector, the agency said.
Crypto as a sanctions workaround
According to the Treasury, both firms support a scheme backed by the Islamic Revolutionary Guard Corps that forces commercial ships to buy what amounts to protection insurance for passage through the strategic waterway. HormuzSafe, in particular, accepts Bitcoin and other cryptocurrencies to process payments that would otherwise be blocked by the U.S. financial system.
OFAC did not identify any specific wallet addresses or transaction volumes in the July 29 action. That leaves compliance teams at exchanges and crypto businesses without a clear list of flagged addresses to screen against — a gap that could complicate efforts to block related payments.
Broader Iran sanctions push
The insurance designations came alongside a separate action targeting eight companies operating in Iran’s petroleum sector and eight vessels, though those are distinct from the two insurance firms. The Treasury has been steadily expanding its Iran-related sanctions under Executive Order 13902, which targets sectors including financial services, energy, and shipping.
For U.S. persons and entities, the designation triggers an immediate obligation to freeze any property belonging to HormuzSafe or PGMIC and report the block within 10 business days. Under OFAC’s 50 Percent Rule, any unlisted entity that is at least 50% owned by one or more blocked persons is also considered blocked.
Liability risks for non-U.S. firms
OFAC warned that civil penalties for sanctions violations can be imposed on a strict-liability basis — meaning a person subject to U.S. jurisdiction can face liability even without knowing a transaction was prohibited. Non-U.S. persons can also be held liable for causing or conspiring to cause a violation, or for engaging in evasion.
The agency stressed that simply transiting the Strait of Hormuz is not enough to trigger sanctions exposure under this action. The trigger is the purchase of insurance from a designated entity or any other prohibited dealing.
The lack of published wallet addresses means crypto businesses will have to rely on broader due diligence — checking corporate ownership, vessel names, and any links to the IRGC — rather than a simple address blocklist. That’s a heavier lift for compliance teams already stretched by overlapping sanctions regimes.
