During the 60-day window, the insurance is free — no payment changes hands, and the sanctions exposure is arguably manageable. But after day 60, if the PGSA introduces fees as it has explicitly reserved the right to do, a shipowner acquiring PGSA-approved insurance would be paying a sanctioned entity. That creates a direct conflict between the operational need to comply with PGSA requirements and the legal prohibition on transacting with OFAC-designated organisations. The MOU’s “toll-free” guarantee does not extend to insurance fees. The US position, per JD Vance on Thursday, is that “international waterways should be free of tolls” — not free of insurance premiums.
