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The ship then received a code, which it broadcast on radio channel VHF 16 — the international distress frequency — as it approached the strait. Meanwhile, Iranian authorities checked the ship’s paperwork, including where the cargo was bound for and the nationality of the crew, Kelly said.
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None of the cargoes that have passed through the strait since the outbreak of hostilities have been destined for the U.S. and Europe. Most have gone to east Asia with some also heading to east Africa and South America, according to ship tracking data.
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The route through the strait is completely within Iranian territorial waters, rather than using the usual shipping lanes. Analysts have suggested that this allows Iran to visually verify ship details, despite U.S. assaults on its radar and observation posts.
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“There is obvious structure in place, there is an obvious sense of leadership,” Kelly said.
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Two Pakistanis involved in back-channel contacts with Iran said some third-country vessels were reflagging as Pakistani to pass through the strait.
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“Lots of shipping lines are changing flags to be sailing under Pakistan registration,” said one, a diplomat. The other said the arrangements were intended as “an olive branch to Trump.”
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Iran’s embassy in Madrid said Tehran was “receptive” to any request for Spanish ships to travel through the strait, saying it considered Spain to be “a country committed to international law.”
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Spanish Prime Minister Pedro Sánchez was the first European leader to criticize the U.S.-Israeli attacks on Iran.
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Shipping companies needing to pay for passage would have to get around sanctions placed on the Iranian regime and its Revolutionary Guard, which have been designated as a terrorist organization by the U.S., EU and other western countries.
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But Claire McCleskey, former head of compliance at the U.S. Office of Foreign Assets Control, said Iran had established clandestine payment networks.
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“They have a ready-made system of ‘shadow banking’ to sell their oil, access controlled technology, and fund weapons programs,” McCleskey said. “It would be very easy for Iran to use front company accounts at banks and exchange houses around the world to get paid.”
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A number of Indian and Chinese companies with ships that have passed through the strait since the start of the war did not respond to requests for comment. India’s foreign ministry said Iran was not asking anything in return for guarantee of safe passage. European and U.S. shipowners told the FT they had no knowledge of a payments system.
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“I heard a lot about [payments] through many shipowners but honestly nobody could say for sure that there is a window for a couple of million dollars,” said SV Anchan, chief executive of U.S.-based Safesea Group, whose ship Safesea Vishnu was struck in the Gulf on March 11.
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Iranians have pointed to historical precedents of governments charging fees for the use of strategic waterways.
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Denmark for centuries charged ships a percentage of the value of their cargo for use of the Danish straits at the mouth of the Baltic Sea. The toll, known as the Sound Dues, was abolished in 1857.
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Yahya Ale Es’hagh, head of the Tehran Chamber of Commerce, cited the Suez Canal as an example of a waterway that ships had to pay to use.
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“Iran has been too lenient so far in not exercising its rights while world powers imposed sanctions on us,” he said. “This could allow Iran to generate between US$70 billion and US$80 billion annually.”
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But Johanna Hjalmarsson, associate professor at the University of Southampton’s Institute of Maritime Law, said the Suez Canal was a different case as it was Egypt’s internal waters and governed by the 1888 Convention of Constantinople.

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