Introduction

The current Iran-Israel-U.S. conflict is not mainly changing trade through new tariff schedules; it is changing trade through compliance risk. For customs teams, importers, exporters, brokers, banks, and logistics providers, the biggest issue is that shipments connected to Iran, the Gulf, or high-risk transshipment routes now face tighter scrutiny on sanctions, export licensing, origin, routing, vessel history, and payment flows. U.S. rules still treat Iran as subject to a broad embargo under OFAC, while BIS keeps parallel export and reexport licensing requirements in place under the EAR. In the UK, the Iran sanctions framework expressly covers trade, shipping, and financial services, and applies to indirect circumvention. In practical terms, that means customs is no longer just checking tariff classification and duty; it is acting as a frontline filter for sanctions compliance and diversion risk.

Export and Re-Export Licensing Risks

The first major effect is on exports and reexports. U.S. exporters and non-U.S. companies handling U.S.-controlled items must assume a much stricter licensing environment. Under 15 CFR 746.7, a license is required for many items on the Commerce Control List going to Iran, and the rule also reaches certain foreign-produced items under the Iran foreign direct product rule. BIS further states that no EAR license exceptions may be used for exports or reexports to Iran, while exports that OFAC would otherwise authorize can avoid duplicate BIS authorisation in limited cases. There are narrow carve-outs: food, medicine, and medical devices designated EAR99 are excluded from one part of the Iran FDP license requirement, and humanitarian applications may still be reviewed case by case. The UK system is similarly strict: it controls strategic goods, dual-use goods, and related services, and even uses tariff commodity codes to determine whether goods fall within scope.

Customs Declarations and Origin Verification

The second major effect is on customs declarations and origin control. In a wartime sanctions environment, the question for customs is no longer only “what is the product?” but also “where did it really come from, how did it move, who handled it, and who ultimately benefits?” OFAC’s 2025 maritime advisory is especially important here. It warns that Iranian-linked networks use ship-to-ship transfers, manipulated AIS data, falsified bills of lading, certificates of origin, invoices, packing lists, insurance documents, and last-port-of-call records to hide Iranian origin or destination. OFAC also says certificates of origin tied to jurisdictions such as Oman, the UAE, Iraq, Malaysia, and Singapore may need enhanced review where risk indicators exist, and notes that cargo testing can reveal chemical signatures unique to Iranian oil fields. For customs authorities and brokers, that means higher evidentiary expectations around origin, routing, and beneficial ownership, especially for petroleum, petrochemicals, chemicals, and high-risk dual-use goods.

Third-Country Diversion and Import Compliance Risks

The third effect is on import compliance and third-country diversion risk. A company importing from the UAE, Türkiye, India, Oman, or Southeast Asia may think it is outside Iran risk, but current enforcement shows that assumption is unsafe. OFAC’s February 2026 actions targeted not only Iran-based actors but also networks, owners, operators, and vessels tied to India, the UAE, Türkiye, Panama, Liberia, the Marshall Islands, Barbados, and the British Virgin Islands. Treasury said these networks were enabling illicit Iranian petroleum sales or supplying precursor chemicals and machinery for Iran’s ballistic missile, UAV, and advanced conventional weapons programs. For import teams, that changes the screening model. It is no longer enough to screen only the seller and consignee. Companies increasingly need to screen the vessel IMO number, registered owner, manager, operator, charterer, insurer, and financing chain, and compare voyage history against sanctions red flags before customs entry or payment release.

Shipping Disruptions and Operational Challenges

The fourth effect is operational: lawful cargo is becoming harder to move and clear. The Strait of Hormuz carried about 20 million barrels per day of oil and oil products in 2025, around 25% of world seaborne oil trade, plus almost 20% of global LNG trade, so even short disruptions have global customs consequences. The IEA says bypass capacity is limited, and UKMTO reported severe GNSS/GPS interference, AIS disruption, VHF warnings, and a high risk of collateral damage, even though no formal legal closure had been confirmed through IMO or NAVAREA channels. Major carriers including MSC, CMA CGM, and Hapag-Lloyd suspended bookings or ordered vessels to seek shelter, while insurers began cancelling or restricting war-risk cover and at least 150 vessels reportedly dropped anchor around Hormuz. For customs teams, that translates into rerouted cargo, amended manifests, late filings, shifting transshipment points, and much less certainty around arrival dates, landed costs, and customs document accuracy.

Limited Trade Relief and Sanctions Exceptions

A fifth effect, often missed, is that trade relief is now narrower and more conditional. Governments sometimes issue limited wind-down authorizations for stranded cargo, but those are not general safe harbours. OFAC’s General License T, issued on 23 January 2026, temporarily authorized safe docking, crew safety, emergency repairs, and the offloading of certain non-Iranian-origin cargo already loaded on specified blocked vessels. But it did not authorize new commercial contracts or any transaction involving Iran, the Government of Iran, or Iranian-origin goods prohibited under the Iranian Transactions and Sanctions Regulations. That is an important customs lesson: even when cargo is physically stuck on a sanctioned vessel, legal relief may apply only to a named vessel, a narrow time window, and very specific goods. Compliance teams therefore need document-level proof of cargo origin, loading date, and vessel identity before assuming a shipment can be cleared or discharged lawfully.

What Businesses Should Do to Manage Trade Compliance Risk

Overall, this war is pushing customs and trade compliance into a far more defensive posture. Exporters now face tougher license analysis, especially for dual-use, strategic, petrochemical, and U.S.-controlled goods. Importers face stronger origin checks, vessel screening, and transshipment due diligence. Customs brokers face greater exposure if declarations rely on incomplete or misleading routing data. Banks, insurers, and freight forwarders face elevated secondary-sanctions and facilitation risk. The real change is that customs clearance is no longer a routine border formality for Middle East-connected trade; it is a sanctions-control exercise. Businesses that continue importing from or exporting through the region need tighter denied-party screening, vessel-history checks, contract warranties, origin verification, and escalation procedures before goods are booked, declared, paid for, or released. In this conflict, the decisive trade barrier is not duty, it is compliance failure.