The US Office of Foreign Assets Control (OFAC) Chabahar waiver expired at 00:01 EDT on Sunday 26 April with no signed renewal text on the Treasury index. India's IPGL (India Ports Global Ltd) had already executed the operational transfer of its $120 million Chabahar Free Zone holding to an Iranian entity under a contractual reversion clause1. India's Ministry of External Affairs framed the transfer as "tactical recalibration" rather than exit and confirmed it remains in conversation with Washington on a renewal arrangement. OFAC is the Treasury sub-agency that administers US sanctions; Chabahar is the Iranian deepwater port India developed as a Pakistan-bypass route to Afghanistan and Central Asia.
The lapse arrived as forecast. The conversation continued past the deadline; the deadline did not wait. India's Iran portfolio now runs at three speeds inside one ministry. Foreign Secretary Vikram Misri is publicly engaged on the Epaminondas shipping demarche after the IRGC seized the Indian-bound vessel on 22 April; the MEA has held nine days of public silence on the 15 April Shamkhani designations naming five Indian nationals and eight India-registered firms; and Chabahar has now lost the only US sanctions exemption Delhi held for any Iran-facing infrastructure.
A reversion clause in a sanctions-driven asset transfer is an admission that the transferring party expects the sanctions regime to be temporary. Nothing signed in Washington this week supports that premise. The Iranian holding entity for the IPGL transfer becomes a subject of future OFAC designation if Hengli-style enforcement extends to non-Chinese facilities. Afghanistan and Central Asia trade routes that used Chabahar as a Pakistan bypass face renewed sanctions risk on every cargo from today.
The counter-reading is that Delhi has chosen the file with crews at sea (Epaminondas) and let the rest run because Mumbai and Chennai operators must be able to price their next cargo. That is the same ministerial logic that produced the silence on Shamkhani.
