Hypothetical question
I own an import/export company that does significant volume through the Persian Gulf region. We don’t trade directly with Iran, but we have clients in the UAE, Oman, and Turkey who do, and we handle transshipment logistics for goods that may have Iranian-origin components.
With Operation Epic Fury, I’m bracing for a massive expansion of sanctions. My immediate concerns:
- OFAC compliance: Are we about to see a new round of executive orders expanding the SDN list and secondary sanctions? How fast do these typically roll out during active military operations?
- Contract performance: We have existing contracts with delivery obligations through the Strait of Hormuz. If shipping insurance gets pulled or routes become impassable, can we invoke force majeure?
- IEEPA authority: The administration has been using IEEPA (International Emergency Economic Powers Act) aggressively for tariffs — SCOTUS just struck that down. Does the Iran situation give them a stronger IEEPA footing for actual sanctions?
- Oil price contracts: We have several clients with fixed-price fuel supply agreements. Crude is already spiking. Who bears that risk?
I need practical guidance on protecting my business and my clients over the next 30-90 days. This feels like it could be existential for companies in our space.