Iran has placed 46 merchant vessels on a “Non-Compliant Vessels List” over alleged breaches of its arrangements for transiting the Strait of Hormuz, raising new legal and operational risks for shipping in the Persian Gulf.

The Persian Gulf Shipping Administration (PGSA), which published the list, warned that the named ships could face restrictions during future transits. Potential measures identified by the Iranian authority include fines, detention, seizure and confiscation.

The notice advises shipowners, charterers and cargo interests to check vessel status before fixing voyages involving Persian Gulf ports. According to the PGSA, companies seeking the removal of a vessel from the list must submit a request accompanied by an explanation.

Iran’s warning also extends beyond ships directly accused of violating its transit requirements. Vessels undertaking ship-to-ship transfers, transshipment or other commercial operations with a listed ship could themselves be designated as non-compliant. This could affect chartering decisions, cargo movements and transfer operations across the Gulf, rather than only individual passages through Hormuz.

The measure creates a compliance conflict for maritime companies because the United States sanctioned the PGSA in May. US authorities accused the IRGC-backed administration of operating an extortion scheme involving commercial vessels using the Strait. The US Office of Foreign Assets Control has warned that cooperation with Iranian transit demands, including payments or the provision of sensitive vessel information, may create exposure to US sanctions.

The Iranian list covers tankers, gas carriers and other merchant vessels. Several have already been involved in attacks during the prolonged disruption to commercial navigation through the Strait.

MINOAN DIGNITY, IMO 9294484, is among the designated ships. The vessel was struck while sailing outbound through Hormuz on August 18, sustaining engine-room damage and a crew casualty. AL BAHYAH, IMO 9937799, and MOMBASA B, IMO 9739501, which were attacked in Omani waters in July, are also included.

Martin Kelly, Head of Advisory at EOS Risk Group, said the designation introduces an additional risk for companies trading through the Gulf. He observed that the list is weighted towards UAE state-linked, Greek-managed and Indian-linked tonnage, with gas carriers featuring prominently.

Kelly advised owners and charterers to screen both their fleets and planned fixtures against the 46 IMO numbers identified by Iran. The warning means counterparties may also need to assess whether planned ship-to-ship transfers or other dealings with designated vessels could lead to further listings, while separately considering the potential implications of US sanctions.