Chris Morgan is global head of credit and compliance at Shipergy. Image Credit: Shipergy

It is probably fair to say that OFAC came flying out of the blocks a bit faster than many of us were expecting on the Iran sanctions, given the ongoing peace negotiations.

Having read through the General License article, it does read perhaps a bit rushed. It is unusually broad in scope, and that is something that is going to take some time for us all in bunkering to collectively get our heads around.

For bunker companies, it basically means you can now bunker vessels carrying hitherto-sanctioned Iranian product, and do so in USD if you wish.

You may do so until at least August 21, 2026, at which point we’ll either get an extension to the deadline or it will be rolled back to how it was if there is no meaningful agreement between the Iranian leadership and the US delegation.

I think we can all agree this is quite the development.

There are some caveats though that we as bunker companies must be aware of. It is not carte blanche to do as you please.

1. There are existent sanctions on thousands of members of the Iranian regime, IRGC, military etc, and vessels owned by these, or by companies owned by/linked to these individuals, are still sanctioned and will likely to continue to be so for a while. So vessel checking is very important still. Providing bunkers to a sanctioned vessel - even if her cargo at that time isn't sanctioned - could still land you in trouble.
2. August 21 is less than two months away, and even if you are selling to them today on 30dd, it is very plausible you may encounter a delay. You certainly wouldn’t want to have an exposure out in this sector come the August 21 if there is no deal, as any reapplication of sanctions could put you in a difficult position.
3. If you have a borrowing base facility with your bank, and August 21 comes and goes without an extension, the bank will be in a difficult position which you definitely need to avoid.
4. Dry bulk, general cargo and container cargoes are expressly not included under this rollback, and you will need to make a determination in each instance if and how sanctions apply for these cases.
5. OFAC is not the be-all-and-end-all. The EU, UK and other domains have sanctions against Iran that need to be adhered to, so even if OFAC are nominally clear for you to do the deal, others may not be.

The emphasis here is on caution. Yes, it is a meaningful step in what most, I think, would agree is a positive direction, certainly relative to the war and misery we’ve just lived through here in the Middle East. But you need to understand your risk and be careful not to get carried away.

Likely, the way most of us will experience this is via predominantly Asian charterers approaching us for prompt bunkers in Middle Eastern ports to supply vessels that may have been doing sanctions trades very recently. If like most of us you employ a firebreak for Iran in terms of port calls and so, do you make an exception now or stick to your policy?

How will you manage any delays that creep in? Do you really want to be arresting a vessel that was sanctioned, wasn’t briefly, and then went back to being sanctioned whilst her charterers or owners owed you money, if there is no permanent deal?

Not for the first time in writing articles and op-ed pieces about bunkering these days, I find myself nodding wryly in the direction of what promises to be some interesting times ahead.