Marine Advisory: 21/2026 - Enhanced Due Diligence for Vessels Transiting the Strait of Hormuz

SUBJECT: Enhanced Due Diligence for Vessels Transiting the Strait of Hormuz

Dear Shipowners, Operators, Ship Managers, Designated Persons Ashore (DPAs), Masters, and Other Maritime Stakeholders:

Purpose

The purpose of this Marine Advisory is to remind shipowners, operators, managers, DPAs, and masters of the importance of conducting appropriate due diligence and risk assessments when planning or undertaking voyages involving transit through the Strait of Hormuz.

Background

Recent developments have highlighted increased regulatory, sanctions, and compliance risks associated with certain activities and arrangements relating to vessel transits through the Strait of Hormuz. Maritime stakeholders are encouraged to maintain awareness of applicable legal and regulatory requirements, conduct enhanced due diligence where appropriate, and remain alert to circumstances that may expose vessels or associated parties to sanctions, commercial, or reputational risks.

Administration Guidance

The Administration recommends that shipowners, operators, managers, and DPAs:

1. Conduct appropriate due diligence before authorizing or undertaking voyages involving the Strait of Hormuz;
2. Evaluate voyage plans, routing arrangements, and operational activities for any indicators of elevated sanctions or compliance risk;
3. Obtain sufficient information from relevant counterparties regarding transit arrangements, coordination of passage, and any related services provided by third parties;
4. Maintain records supporting due diligence efforts and compliance reviews conducted before, during, and after transit;
5. Ensure that internal sanctions compliance procedures, risk management processes, and reporting mechanisms remain effective and are followed by vessel and shore-based personnel.

Conclusion

This Advisory is intended to promote sound risk management and compliance practices for vessels operating in or near the Strait of Hormuz. Shipowners, operators, managers, DPAs, and masters should continue to exercise prudent commercial judgment and conduct appropriate due diligence in accordance with their own compliance programs and applicable legal and regulatory requirements.

For additional information regarding sanctions compliance matters, please contact the Compliance Department at Compliance@liscr.com.

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