The US Treasury has stated this week that payments to Iran or the IRGC for Hormuz passage, direct or indirect, are not authorised for US persons or US banks. Walked through at desk level for tanker owners, charterers, correspondent banks, and refiners, the rule closes the dollar payer set for the current toll arrangement. The four-leg architecture of the regime is now complete from the US compliance side.
On 25 April OFAC sanctioned Hengli Petrochemical (Dalian), China’s second-largest teapot refinery, for buying Iranian crude, plus 40 shadow-fleet vessels, plus the named Iranian Armed Forces General Staff oil-sales arm Sepehr Energy. Combined with yesterday’s $344M USDT freeze, three of the four legs of the Hormuz toll architecture have been entity-mapped in 48 hours. The Suez and Panama models have no off-grid leg because they are treaty-backed.
On 24 April the US Treasury and Tether jointly executed a 344 million dollar USDT freeze across two Tron wallets associated with Hormuz transit-fee receipts. The action is less a political moment than an architectural one. It reveals what kind of payment channel a non-treaty toll regime can sustain, and why a treaty-backed authority chooses conventional banking instead.