THE latest US sanctions against an Iranian cryptocurrency exchange have done more than expose another sanctions-evasion network. They have provided the clearest evidence yet that Iran’s controversial Hormuz Safe scheme is not a theoretical threat to the maritime order, but an operational financial system through which vessels are still paying for passage through the world’s most important energy chokepoint.

According to the US Treasury, Tehran-based BitBank processed payments linked to the Hormuz Safe programme before transferring funds to Iranian state entities and the Islamic Revolutionary Guard Corps. The designation confirms what sanctions lawyers, insurers and shipowners have suspected for months: that a structured mechanism now exists to monetise transit through Hormuz.

What has changed most since the scheme first emerged in March is not the legal debate but the institutional maturity of the system.

Early reports described an ad hoc arrangement involving IRGC-linked intermediaries collecting information on vessels, cargoes and crew before granting passage. Payments were reportedly negotiated on a case-by-case basis, sometimes through informal channels and in non-dollar currencies. By May, however, Iran had formalised the process through the Persian Gulf Strait Authority, creating an administrative framework for permits, routing instructions and payments.

Crucially, the payments have not stopped.

Industry sources continue to report vessels paying significant sums to transit using routes favoured by Iran. Charges vary dramatically depending on vessel nationality, ownership links and cargo destination. A VLCC carrying US-linked cargoes can face demands measured in millions of dollars, while vessels linked to countries viewed more favourably by Tehran are reportedly charged a fraction of that amount. The rates themselves have stabilised, suggesting a market that is becoming institutionalised rather than improvised.

That matters because the debate is no longer simply about whether Iran can collect money from passing ships. The more significant question is whether Hormuz is becoming the centre of an alternative maritime ecosystem built around non-Western insurance, payments, ownership structures and compliance standards.

Iran appears to be testing whether the sanctions-resistant infrastructure created around Russian trade since 2022 can be replicated for Hormuz. Chinese payments, Russian insurance capacity, alternative flag registries and sanctions-tolerant operators all form ingredients of a parallel system that does not depend on Western financial or maritime institutions.

Yet the latest US sanctions also highlight the limits of that ambition.

For mainstream shipping, insurance and banking, Hormuz remains governed by Western compliance rules. London’s insurers have already moved to prevent vessels from paying for passage, while the US Treasury has repeatedly warned that payments to Iranian state entities may trigger sanctions regardless of how they are structured.

The battle over Hormuz for some time now has not been about closing a waterway — the ships are moving. It is a contest between competing systems determining who has the authority to regulate passage. The sanctions against BitBank suggest that while Iran may have succeeded in building the machinery, Washington is now targeting the financial plumbing that keeps it running.

Richard Meade
Editor-in-chief, Lloyd’s List

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