The Iran War and International Shipping: Navigating Disruption and Legal Risk in the International Shipping and Logistics Industries( continued from page 5)
conflict has added new layers of complexity. Companies should monitor any new sanctions that may be levied against Iran in connection with this conflict. In addition, as companies consider making changes to trade routes or supply chains, they should exercise careful due diligence and be aware of other sanctions restrictions that may apply to other parties in the Middle East or Russia, in particular, individuals and entities sanctioned for trading Iranian or Russian oil or“ shadow fleet” vessels that have been designated under the Iran and Russia sanctions regimes.
Adding further complexity to situation, the Trump administration has temporarily eased certain limited sanctions on oil-producing countries, e. g., Russia, Venezuela, and Iran, to stabilize global energy markets. These include:
• Russia: On March 19, 2026, the Office of Foreign Assets Control(“ OFAC”) issued a 30-day general license authorizing the delivery and sale of Russianorigin crude oil and petroleum products loaded on tankers as of March 12, excluding transactions involving North Korea, Cuba, and Crimea.( This license supersedes the similar license issued on March 12 was scheduled to expire on the original April 11, 2026, date).
• Iran: On March 20, 2026, OFAC issued a 30-day general license authorizing the deliver and sale of Iranian-origin crude and petroleum products loaded on vessels as of March 20.
Various American and European parties have been critical of the sanctions relief arguing that it provides a windfall to Russia and Iran and funds their respective war efforts.
As of now, the United Kingdom and European Union have not issued corresponding sanctions relief, creating a separation between the major Western sanctions regimes, which may result in compliance difficulties for international companies subject to multiple jurisdictions.
Jones Act Waiver In response to energy market volatility caused by the conflict, on March 17, 2026, the Trump Administration announced a 60-day limited waiver of the Jones Act( 46 U. S. C. § 55102) upon request of the Department of War. The waiver permits foreign-flag vessels to transport certain goods, including oil, natural gas, coal, and fertilizer, between U. S. ports for the duration of the waiver period, which voyages would normally be prohibited under the Jones Act.( For a more detailed discussion of the Jones Act Waiver, see our separate article in this issue.)
Recommended Actions for Industry Participants In light of the rapidly evolving situation, industry participants should consider a number of proactive measures, including:
1. Contract Review: Companies should review their charters and other supply and logistics contracts to understand their exposure and rights with respect to force majeure, insurance, delivery deadlines, and related liquidated damages or other fee provisions, potential defaults, voyage routes, and cost escalation and allocation. Companies should ensure that they send any required notices relating to delays, performance, or insurance.
2. Review Insurances: Companies should review their existing insurance policies and confirm their understanding of any war risk coverage requirements, policy exclusions, cancellation rights, and notice obligations. Companies should also confirm any insurance coverage requirements in their charters, loan documents, or other contracts to avoid any inadvertent defaults. For any ambiguities, companies should consult their insurance broker for clarification on coverage.
3. Contingency Planning: Companies should plan for various contingencies, including evaluating potential alternative routes and related costs changes, obtaining alternative insurance coverages, or changing suppliers of goods or services.
4. Sanctions Compliance: Companies should review their sanctions compliance programs and update them to account for any new counterparties, trade routes, and the evolving regulatory landscape across multiple jurisdictions. Any company considering using any of the recent OFAC general licenses should carefully review and analyze the general license requirements and confirm that any such activity would not be subject to another sanctions regime.
The conflict has introduced a new degree of risk to international shipping and logistics not seen since the early days of the COVID-19 pandemic. Whether the current disruption proves to be short-lived or marks a new beginning, an early and thorough assessment of operational and legal risk is crucial to reduce commercial risk exposure and preserve potential legal rights and remedies for the future.
p – 2026 BLANK ROME LLP
This article was first published as a Maritime client alert on March 26, 2026.
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