What if cargo only transits through a sanctioned country without being delivered there?

Transit can still violate OFAC rules. Under 31 CFR § 560.204 (Iranian Transactions and Sanctions Regulations), the export prohibition covers goods sent to a third country “with knowledge or reason to know” they are intended for transshipment or re-export to Iran — intent and knowledge control, not merely the shipment’s final stop. Section 560.406 separately governs Iranian-origin goods transiting through the United States. OFAC’s maritime sanctions advisories, including the joint 2020 Sanctions Advisory for the Maritime Industry issued with the U.S. Department of State and U.S. Coast Guard, flag deceptive practices used to disguise transit — AIS signal manipulation, ship-to-ship transfers, falsified documentation — for Iran, North Korea, and Syria routes. In a 2022 enforcement case, Toll Holdings Limited paid $6,131,855 to settle 2,958 apparent violations tied to shipments processed “to, from, or through” the DPRK, Iran, or Syria. Routing through a sanctioned jurisdiction requires the same licensing and due-diligence analysis as direct delivery.