On April 29, July 2 -- pay the Hormuz service fee Iran intends to charge, or risk Iran refusing passage. Under the current state of US sanctions law, paying that fee would expose the operator, its bank, and its insurer to liability under Treasury guidance that has not been modified, rescinded, or addressed since it was issued in April. After two days in Doha, that guidance is still in place, and no one publicly acknowledged it.

such payments "would not be authorized" for US persons, financial institutions, or US-owned or controlled foreign entities. OFAC extended the warning to non-US parties as well - foreign shipowners, banks, insurers, and counterparties engaging in transactions with designated Iranian entities face exposure under Exe...