Sanctioning the Collector: The OFAC Designation of the PGSA
On 27 May 2026, OFAC added the Persian Gulf Strait Authority to the SDN list, framing it as an IRGC instrument and warning shippers, insurers, financiers, and charterers of sanctions exposure regardless of payment method. Designating the collector itself is the institutional crux — and it collides directly with a reopening deal that would route global shipping through that very body. This post reads the collision and what an acceptable collector looks like.