Tehran’s ‘toll booth’ system is now controlling Hormuz traffic

Iran said in a communique earlier this week that navigation through the strait continued for vessels from friendly nations “in co-ordination with the competent Iranian authorities”.

In a letter circulated among International Maritime Organization member states on Tuesday, Iran’s foreign ministry said Tehran had “taken necessary and proportionate measures to prevent the aggressors and their supporters from exploiting the Strait of Hormuz to advance hostile operations against Iran”.

Iran’s representatives at the IMO have not responded to requests for details regarding the measures and payments being taken.

While Iran’s Supreme Leader Mojtaba Khamenei has said Iran should keep the strait shut, the letter said the waterway remained open and “traffic has not been suspended”.

The critical waterway has seen about a day’s normal traffic pass through since March 2, the second full day of the war.

Transit payments

In total 142 vessels have transited since the start of the month, but 67% of that traffic has a direct affiliation with Iran (either through trade or ownership). This figure rises to 90% when looking at traffic in recent days.

Loadings of Iranian crude continue at over 1.5m bpd, according to Vortexa. About 1m bpd is assessed to have transited the strait since March 1, although that number might be higher. At least eight very large gas carriers carrying Iranian liquefied petroleum gas have also transited the strait since March 1.

The remaining trickle of non-Iranian ships is made up primarily of Greece-owned or affiliated vessels (15%) and Chinese (10%).

While all vessels transiting are now understood to be using the new Iran-controlled vetting system, not all vessels are being required to make payments to secure safe passage.

Iran’s foreign minister Abbas Araghchi has discussed the status of the Strait of Hormuz directly with counterparts in several states over recent days, including: Malaysia, China, Egypt, South Korea and India.

According to the account of each telephone call published on Araghchi’s Telegram feed, in each case he stressed that “non-hostile vessels” can transit the Strait of Hormuz “in co-ordination with Iranian authorities”.

Any discussion of payment is not referred to.

According to the Indian government, however, no fees or protection money is being paid for the safe passage of Indian ships, suggesting that many of the vessels transiting are doing so on the basis of diplomatic intervention rather than direct payments.

Since details of the Tehran transit corridor first starting circulating around industry security officials earlier this week, several companies have been approaching security firms with requests for help to negotiate transit.

Sanctions risk

Most shipping companies with vessels trapped inside the Middle East Gulf, however, remain very nervous about the prospect of legal or political consequences if they are seen to be engaging with the IRGC, even via intermediaries.

“The IRGC remains a Foreign Terrorist Organization, as designated by the US State Department,” said Claire McCleskey, a sanctions and compliance expert who previously led the compliance division within the US Treasury’s Office of Foreign Assets Control.

“Under US law, providing ‘material support’ to a designated FTO carries not just civil and regulatory risks but the risk of criminal prosecution. However, even with these very real concerns, many non-US companies are likely evaluating recent statements from the US Treasury Department to weigh the sanctions risks of engaging in this kind of activity versus the reward of getting a ship safely through the strait,” said McCleskey, who is a co-founder of Clarity Compliance Consulting.

Despite increased interest from mainstream shipping in the Iran-controlled scheme, most shipping companies with vessels currently stuck in the MEG approached by Lloyd’s List confirmed they would not be engaging with the IRGC, even indirectly.

Lloyd’s List understands, however that shipowner representatives and security firms have been inundated with requests from owners seeking clarity over the practical and legal consequences of seeking Iranian approval to transit.

Maritime lawyers remain doubtful that most companies would take the risk.

“Until and unless Ofac provides additional clarification, I would expect financial institutions to be extremely sceptical as to whether the ‘toll’ fees would qualify as transactions ‘ordinarily incident and necessary’ to the sale, delivery, or offloading of Iranian-origin oil or gas authorised under general license U,” said Manny Levitt, a trade attorney at Holland and Knight, referring to the recent Ofac authorisation that allows for the delivery and sale of Iranian-origin crude oil and petroleum products already loaded on to vessels as of March 20, 2026.

While the general license can be used to mitigate certain US sanctions compliance risks, even if the toll payments were permitted, there are other reputational and legal risks that could arise for a company involved in making payments to the Iranian government, Levitt explained.

“Specifically, the general license would not mitigate the risks that could arise under UK or EU sanctions, which still apply, nor would they prevent a company from potentially facing liability under separate US anti-terrorism-related statutes targeting the provision of ‘material support’ to Foreign Terrorist Organizations, which include the IRGC,” said Levitt.