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The Holding Queue: Bilateral Carve-Outs and a Bifurcating Strait

Six India-flagged vessels transited inbound on 18 May 2026 in a coordinated cluster under bilateral Iran-India arrangements. The chokepoint is now operationally bifurcated: a compliant fleet under PGSA-administered transit and a holding queue of about 2,000 vessels waiting for the institutional configuration the operator class can use. This post reads the bifurcation, the historical parallel of the 2018-2025 shadow fleet, and what a treaty-backed authority would do to consolidate it.

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Naming the Buyer: The April 25 Hengli Sanction and the Hormuz Toll Architecture

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.

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