WarBrief Live | November 1, 2026 | Sanctions
On October 21, 2026, OFAC designated a Panama- and Greece-based law firm, five individuals, three other companies and nine vessels linked to Iranian shipping, with wind-down dealings authorised until 12:01 a.m. EST on November 20, 2026.
Key Takeaways
- Designated: Karnakis and Karnakis, five individuals, Roxette, Amigoz, Whales, and nine vessels.
- Authority: Executive Order 13902, under Operation Economic Outcast.
- Deadline: Licenses GG and HH allow only wind-down and safety activities through November 20, 2026.
- Designation is an administrative blocking action, not a criminal conviction.
Target overview: who was designated on October 21, 2026?
Treasury says Iran’s commodity trade depends on firms that register, manage and service vessels, not only on vessels. Karnakis and Karnakis, a Panama- and Greece-based law firm, is accused of creating and administering companies transporting Iranian petroleum, petrochemicals and steel. Treasury cites Elias Shipping and Trading S.A., owner of RAMONA 1, and alleges the firm helped build structures used by Iranian LPG businessman Seyed Asadoollah Emamjomeh. These are U.S. government allegations, not court findings.
The firm was founded and is owned by Sofianos and Konstantinos Karnakis Kosmas, described as dual Panamanian-Greek nationals; the five individuals also include Ioanis Karnakis Kosmas, Pedro Ortega Jones and Roberto Ortega Jones. Roxette Maritime, for which the firm allegedly acted as corporate agent, was designated as operator or manager of seven Panama-flagged vessels: ANEMOS, GLORIS, PRIDE, DESTINY, FLAMINGO 1, HARMONY and PRINCE, some of which Treasury says carried Iranian petrochemicals and steel within the past year. Amigoz Singapore allegedly acted for a light-crude shipment overseen by Sepehr Energy and bunkered the LPG carrier Zixuan. Dubai-based Whales Shipping Line allegedly supported Amigoz and acted for Sparrow Trading FZE, a front company; its WHALES DIAMOND and WHALES PEARL complete the nine vessels.
Measures in place: what does designation actually do?
Designation generally blocks the designated persons’ property in the United States or held by U.S. persons, and bars U.S. persons from dealing with them unless OFAC authorises it. Entities owned 50 percent or more by a blocked person are themselves treated as blocked. See WarBrief’s sanctions hub and our earlier October wave analysis, which mentioned this round only as one row. It is distinct from the separate October package on presumed denial, a Turkish bank and BitBank. Treasury Secretary Scott Bessent said: “Whether you are conducting illegal oil transfers at sea or sitting in the corner office of a law firm, if you are supporting the Iranian regime, we will find you and sanction you.”
Recent actions: what do General Licenses GG and HH actually allow?
License GG authorises dealings necessary to winding down Karnakis and Karnakis and its 50-percent-owned entities, including blocked employees acting officially. License HH authorises winding down Roxette Maritime and its seven vessels, plus limited safety and port activities outside Iranian and Russian ports: vessel management, crewing, insurance, emergency repairs, and delivery of non-Iranian cargo loaded on or before October 21, 2026. Both expire at 12:01 a.m. EST on November 20, 2026, payments to blocked persons must go into blocked accounts, and neither reopens the underlying trade.
Two adjacent October 21 items differ from this package. FinCEN said it was coordinating with European partners, including in Greece, and had issued its first subpoena under 31 U.S.C. section 5318(k) over a Greek bank’s potential Iran-linked ties. Separately, Russia-related License 131K continued Lukoil International GmbH authorisations through November 21, 2026, a different programme and deadline.
Impact: who feels the November 20 deadline first?
For the designated network, the effect is isolation from U.S. persons and the U.S. financial system, with a short window to end relationships and offload permitted cargo. For others, the risk is indirect exposure: a charterer, insurer, registry, port provider or bank dealing with a blocked vessel or agent can face enforcement risk without careful screening. This entry is educational only, not legal advice.
What to watch next after November 20, 2026
Watch whether OFAC extends or lets Licenses GG and HH lapse, what happens to the nine vessels, whether follow-on designations name linked insurers or registries, and whether the FinCEN inquiry produces a public outcome.
Frequently asked questions
What did OFAC designate on October 21, 2026?
Five individuals, four entities and nine vessels under Executive Order 13902, as part of Operation Economic Outcast.
Do Licenses GG and HH allow normal business to continue?
No, only specified wind-down, safety, environmental and cargo activities, through 12:01 a.m. EST on November 20, 2026.
Does designation mean a criminal conviction?
No. It is an administrative blocking action based on U.S. government allegations.
Sources
- U.S. Department of State: Unmasking Service Providers Facilitating Iran’s Shadow Fleet Operations
- FinCEN: Operation Economic Outcast Targets Iran’s Shadow Fleet Networks
- Steptoe: Sanctions Update, October 26, 2026
- Seatrade Maritime: US sanctions law firm, shipping agents linked to Iran’s shadow fleet
