Neil Roberts
Head of Marine & Aviation
Committee secretary
The JWC brings together senior underwriters from across the market to discuss and debate on key issues affecting the marine insurance market. It works with a range of people, including government personnel, security firms and shipping companies.
Soon after the conflict began, the JWC extended the Listed Areas by adding those countries in the Gulf region that had US bases as they are now considered as targets by Iran. Despite some regrettably incorrect reporting about cancellation, hull war insurance cover remains in place and available in the London market, through both Lloyd’s syndicates and IUA companies.
The notice sent by liability underwriters was to review a limited section of their book, the charterers and non-poolable exposures. Cover remained and remains in place but can now be reviewed on a case-by-case basis reflecting the perception of risk.
This is an evolving situation and remains highly unpredictable. There have now been almost 100 attacks on commercial tonnage. Many ships remain at anchor whilst masters wait for clarity on the alleviation of physical dangers to vessel and crew. In addition, there are layers of legal complexity to navigate and there is no certainty on whether any authority will levy some form of charge for accessing an international waterway.
Date released: 28 April 2026
Date updated: 29 May 2026
1249. Are “toll” payments to Iran for safe passage through the Strait of Hormuz authorized?
No. Payments to and guarantees from the Government of Iran or the Islamic Revolutionary Guard Corps (IRGC), directly or indirectly, for safe passage through the Strait of Hormuz would not be authorized for U.S. persons, including U.S. financial institutions, or for U.S.-owned or -controlled foreign entities. Regardless of whether a payment is made, U.S. persons are prohibited from receiving services from the Government of Iran, including services related to a guarantee of safe passage. For additional guidance, please see “OFAC Alert: Sanctions Risks of Iranian Demands for Strait of Hormuz Passage.”
Iran created a new entity, the so-called Persian Gulf Strait Authority (PGSA), to collect tolls and extort vessels transiting the Strait of Hormuz. On May 27, OFAC designated PGSA pursuant to our counterterrorism authorities, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC. Cooperating with or engaging in direct or indirect transactions or dealings, including the receipt of services from the PGSA, carries sanctions risk.
Payments or services for or related to safe passage also create significant sanctions exposure for non-U.S. persons. Specifically, foreign financial institutions and other non-U.S. persons risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. This includes the Government of Iran and the IRGC, which is designated as a Foreign Terrorist Organization and sanctioned pursuant to several authorities, including nonproliferation and counterterrorism sanctions authorities.
Foreign persons that are engaged in certain transactions could also risk sanctions exposure under authorities such as Executive Order 13902, which authorizes sanctions on, among others, persons who have knowingly engaged in certain significant transactions involving determined sectors of the Iranian economy or who have been determined to operate in those sectors, including the financial and petroleum and petrochemical sectors.
In conjunction with independent security advisers, Herminius, the JWC publishes a list of geographical areas where vessels are considered at increased risk of war-related perils. Ships sailing into the regions appearing on the Listed Areas would be required to notify underwriters.
Rating is a matter for individual negotiation between underwriters and brokers and the JWC plays no role in that. The committee last reviewed the areas in September 2026. The current listed areas are linked below:
Full LMA members can access Herminius’ Joint War Committee Quarterly Briefings here.
The tri-partite conflict remains extant. Problems for underwriters are essentially kinetic, navigational, humanitarian and legal. Coverage remains available on request and it has been thought necessary to issue a tolls clause to protect underwriters insuring vessels trying to enter or leave the Strait of Hormuz.
The Houthis have announced the embargo of all Saudi ports and their intention to target Saudi-linked vessels. Two were attacked in the first few days after the announcement. The JWC has adjusted the Red Sea notification line northwards to reflect this development.
The overall situation remains unstable so caution is advised. The Listed Areas will be re-adjusted if required by circumstances. Recent escalation in the Black Sea is very concerning, with over 250 ships hit since August. This necessitates an expansion of the Listed Areas to include all of the Black Sea, other than territorial waters of adjoining non-combatant countries.
The Roundtable of Shipowners removed their high-risk area (HRA) at the beginning of 2023. The JWC continues to maintain the Listed Areas as before. Recent incidents are not considered to be a clear trend requiring expansion eastwards, but the situation is under close watch.
The JWC listed areas are set for business reasons and the Indian Ocean area was never the same as the UKMTO or the industry BMP/HRA areas but does serve to alert parties to the potential dangers. The applicable US Executive Order effectively requires insurers to contact OFAC should they be involved in a piracy case.
There has been a recent increase in piracy incidents off of Somalia, with at one stage five vessels being held offshore by perhaps two groups of well-organised pirates. Owners should follow the advice in BMP-MS.
Pirate activity is intermittent off Eastern Malaysia and a number of oil cargo seizures have occurred there.
In the Gulf of Guinea, crew abductions are the main threat. Since mid 2021, the number of incidents has notably decreased, but attacks still occur.
The situation is uncertain and, in some ways, unique. For now, the kinetic risk is assessed to be less of a concern than the potential for seizures or detentions.
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22 July 2022
17 September 2020
20 June 2005