Iran’s Persian Gulf Strait Authority (PGSA) added 114 vessels to its Non-Compliance List on 2 November 2026, taking the total to 240. The PGSA says listed ships face fines, detention or confiscation on future Strait of Hormuz passages, and Reuters reported in August that their cargo could be confiscated too.

For container shippers, a list check covers only the vessel and list version checked. The carrier assigns the vessel, and an onward feeder can change after booking. Three container ships attacked in October were absent from the list when they were hit. Checking the ship named on the original booking cannot establish the status of a different vessel carrying the container on a later leg.

What Changed on 2 November

This was the largest update since the list first appeared in August. Earlier changes arrived at irregular intervals, and duplicate entries and vessel-name changes have complicated comparisons between versions.

DateDistinct vesselsNotable development
23 August45First list, including the 7,000 TEU container ship GFS Galaxy
14 September77Additions were mostly crude tankers; insurers and classification societies were warned
28 September8081 entries included the same ship under two names; charterers ordering unapproved transits were warned they could be listed
26 October123Two vessels added, including one replacing a duplicate entry
28 October125One LNG carrier removed and three vessels added
2 November240114 added, at least 29 of them linked to Sinokor
Sources: Seatrade Maritime News reports published 24 August to 2 November 2026; The Maritime Executive, 3 November 2026. Counts distinguish vessels by IMO number in Seatrade’s reproduced lists. The first list had 46 entries for 45 vessels. On 28 September, Silver Shine and its former name Arsan shared IMO 9421415, giving 80 vessels across 81 entries. Alraya was added after 28 October, bringing the count to 126 before the 114 additions on 2 November.

Container ships are a small share of the total. Risk intelligence firm Orbital counted 118 crude tankers and four container ships among the 240, according to The Maritime Executive. That breakdown does not measure the exposure of individual container shipments, which may move between ships at transshipment ports or depend on an onward feeder operated by another carrier.

Why a List Check Can’t Clear a Container

The original advice assumed vessel chartering. The PGSA’s August warning told cargo owners to check the list before chartering a vessel. Its subsequent warnings also address cargo owners shipping to or from the Gulf. A container shipper books carriage on a service, while the carrier determines the carrying vessels. As our review of the GFS casualties explained, the vessel on the original paperwork may change after a transshipment or substitution. Contingency routes can add more legs, including feeders inside the Gulf.

Earlier attacks show the limits of the list. In its 19 October review of 121 distinct listed vessels, Seatrade Maritime News counted at least 39 that were attacked before being listed. Eighteen of the 20 ships added on 15 October had already been struck, one of them by US forces, while five were clearly listed first and targeted later. GFS Pride, GFS Giselle and Al Saadiyat were absent from the list when they were attacked in October.

The November expansion had a different profile. Seatrade identified at least nine of the 114 additions as having suffered earlier attacks recorded by the International Maritime Organization (IMO). It cautioned that other attacks may have gone unreported or unverified. The October findings demonstrate that absence from the list provides no assurance against attack; they do not describe the majority of the November additions.

The wording does not explain terminal-based container relays. Since 23 August, the PGSA has said vessels carrying out ship-to-ship transfers or transshipment with listed ships will also be added. The published wording does not specify how this applies to containers discharged at a terminal and loaded onto another vessel. The scope for such relays remains unclear.

If your team would only discover a vessel change after a consignee asks or a new list appears, walk through how ops teams review reported vessel and voyage changes and flag gaps at container handovers.

What Each Result Means for Your Cargo

What you findWhat is knownWhat to do
Current vessel is listedThe PGSA threatens fines, detention or confiscation on future passages. Windward’s September analysis found that listing had not stopped ships trading in the region.Ask the carrier in writing for the planned routing and any onward change. Notify your cargo insurer or broker and confirm applicable war-risk terms.
Vessel belongs to a named fleetThe PGSA told Seatrade that all Sinokor ships face action similar to listed vessels. Application to particular ownership and chartering arrangements remains unclear.Establish the vessel’s legal owner, operator and charterer, and ask how the carrier has assessed the warning.
Another leg involves a listed shipThe PGSA’s warning covers ship-to-ship transfers and transshipment with listed vessels. Its application to a terminal-based container relay is unclear.Record both vessels and voyages. Ask how the carrier has assessed the connection and whether it plans to change it.
No listed vessel on any remaining legAn unlisted result provides no assurance against attack. JMIC’s 1 November assessment recorded 18 confirmed attacks in the Strait of Hormuz since 6 October, and unlisted container ships were among October’s casualties.Continue route and war-risk checks for each remaining sea leg. Repeat list checks after updates or vessel changes.
Someone says passage was cleared with the PGSAOFAC warns of sanctions exposure from dealings with the PGSA for safe-passage guarantees, including when no payment is made.Refer the details to compliance or legal counsel before acting.
Sources: Seatrade Maritime News, Windward, JMIC Advisory Update 110 and OFAC. The attack count is a dated assessment for the Strait of Hormuz, not a current total for the wider Gulf. These are general operating checks; applicable law, contract terms and insurance wording determine the response.

The Sinokor Warning and Container Cargo

On 27 October, the PGSA warned cargo owners, stakeholders and insurers that it would take legal action against all Sinokor vessels from 1 November, alleging the most passage violations of any company over three months. Seatrade counts at least 46 Sinokor-linked vessels on the list after the latest update and reports that the PGSA confirmed its warning applies across Sinokor’s fleet.

Coverage has focused on Sinokor’s tanker fleet. Bloomberg vessel-tracking analysis cited by Splash247 estimated that Sinokor-controlled tankers carried about 37% of the crude moving through Hormuz in September. Sinokor also operates container services, but the fleet-wide warning does not explain its application to particular container operations or chartered vessels. Splash247 reports that Sinokor is seeking clarification. For a Gulf leg involving a Sinokor-linked vessel, ask the carrier how it has assessed the warning against that ship’s ownership and operating arrangements.

Why PGSA Contact Is a Compliance Question

OFAC designated the PGSA on 27 May 2026. Its 24 August alert warns that US and non-US persons risk sanctions or penalties through dealings with the authority for safe-passage guarantees, including accepting services or responding to information demands, even without payment.

US persons and US-owned or -controlled foreign entities are generally prohibited from transactions with Iran or its government, including receiving services, unless exempt or authorized. Non-US persons may also face sanctions exposure for relevant transactions, including secondary sanctions on participating foreign financial institutions. The applicable restrictions depend on the parties and conduct involved, so any proposed arrangement needs legal review.

Windward’s September review of the first 77 listed ships found that each had used the southern corridor or crossed the northern corridor without paying tolls. Those findings describe the listed ships. They cannot establish why another vessel is absent from the list or whether it obtained Iranian clearance. List status alone cannot establish safety or sanctions compliance.

OFAC encourages maritime service providers to ask counterparties who they coordinated with for a Hormuz transit, whether safe-passage fees were or will be paid to Iran, and whether any Iranian services were accepted. Forwarders should ask counsel how this applies to their role. Cargo owners can put the same questions to their carrier or forwarder.

What to Check This Week

  • Confirmed events and planned legs. For each container touching a Gulf port, record the latest confirmed loading or discharge event, its timestamp, and the associated vessel and voyage. Keep the planned onward vessel separate. If the latest event is a discharge, confirm whether the container is still at the terminal or has loaded onto another ship.
  • Match on IMO. The list has carried duplicate entries and out-of-date names, including Bahri’s Silver Shine under its former name Arsan. Check the IMO number against a dated published copy such as Seatrade’s.
  • Recheck triggers. Repeat checks when the list updates and when a vessel assignment or planned route changes. Log the date and the version checked.
  • Written carrier answers. Ask whether each remaining sea leg will transit Hormuz, who coordinated the passage, and whether any safe-passage fees paid to Iran or Iranian services are involved.
  • Insurance terms. If a listed vessel appears on a remaining leg, notify your cargo insurer or broker and confirm applicable war-risk cover and any notification requirements. Our GFS post explains relevant cargo and war-risk clauses.
  • A compliance route. Send any suggestion to apply to, pay or request a guarantee from the PGSA to counsel first.

Further Reading


List totals reflect trade-press reporting through 3 November 2026 and may change without notice. Historical counts distinguish vessels by IMO number in Seatrade’s reproduced lists. The list states PGSA allegations and is not a legal finding against any vessel or company. Vessel-type counts are Orbital’s figures as reported by The Maritime Executive. Windward’s September findings concern the first 77 listed ships. The 18-attack figure is JMIC’s 1 November assessment for the Strait of Hormuz since 6 October, not a current total for the wider Gulf. Attack reports and attribution remain subject to investigation. Sanctions references summarize OFAC’s 24 August alert and FAQ 1249 and are not legal advice. Confirm routes, vessel assignments and insurance terms with your carrier, forwarder, insurer and counsel.

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