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 more than 45 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.
It should also be noted that the Houthis retain the capability to intervene in the Red Sea.
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 may require additional war risk coverage.
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 2024. The current listed areas are linked below:
JWLA-033 Iran
JWLA-032 Guyana
JWLA-031 Sudan
Full LMA members can access Herminius’ Joint War Committee Quarterly Briefings here.
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.
The Houthis have announced a truce, though it does not include Israeli-linked vessels. The threat to commercial shipping is thus on hold for now, but hostilities could resume if the ceasefire fails. Houthi forces seek recognition of their regime whilst also trying to change Israeli policy in Gaza.
Iran and Saudi Arabia were engaged in a proxy conflict in Yemen. That war was estimated by the UN to have cost 150,000 military casualties and perhaps 377,000 deaths in all. A fragile truce is in place between the Houthis and the Saudis and the Houthis have established de facto control of urban centres in Yemen.
Foreign vessels are currently forbidden from entering Yemeni waters. Yemen does not have an effective navy of their own, so the Egyptian and Saudi navies were mandated to enforce this. There are entry procedures for vessels to enter Hodeidah or Saleef port – a completed form must be sent to the Yemen Ministry of Transport, now based in Jeddah. The system works but is complex.
The overall situation remains unstable so caution is advised. The Listed Areas will be re-adjusted if required by circumstances.
The fighting was centred on the capital Khartoum, 400 miles from the coast. There is assessed to be no immediate threat to shipping and there have been no reports of attacks on ships or port infrastructure. The SAF have full control over Port Sudan and no impact has been reported at other terminals.
Vessels picking up refugees may have to divert to a different port to that originally intended; voyages may be lengthened and there are likely to be logistical and operational consequences.
The shipowners removed their HRA at the beginning of 2023. The JWC continues to maintain its listed area 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.
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 JWC helps to develop and issue wordings for use across the market. To receive email notification of new wordings, please subscribe.
22 July 2022
17 September 2020