OFAC, new Iran sanctions: a law firm, two shipping agents and nine vessels of the «shadow fleet» hit

In short: on 21 October 2026 OFAC, the sanctions office of the US Treasury, added to the SDN list the law firm Karnakis and Karnakis (Panama and Piraeus), accused of registering the companies that own vessels of the Iranian «shadow fleet», together with a ship management company, two shipping agents in Singapore and Dubai and nine vessels. For those who export or ship, the news is about the target: not only oil tankers, but law firms, port agents and general cargo ships that also carry steel and petrochemicals.

What happened?

The designations are part of the US Treasury's «Operation Economic Outcast» against the networks that support the revenues of the Iranian regime, and are adopted under Executive Order 13902, which concerns, among other things, the Iranian oil and petrochemical sectors. On the same day, OFAC:

• published the Iran-related general licences GG (wind-down of ongoing transactions with Karnakis and Karnakis) and HH (wind-down, limited safety and environmental operations and offloading of cargo involving persons or vessels blocked on 21 October 2026);
• published the Russia-related general licence 131K, which authorises certain operations to negotiate and enter into contingent contracts for the sale of Lukoil International GmbH and related maintenance activities;
• amended FAQs 1224 and 1225;
• removed from the SDN list some entries under the Belarus and North Korea programmes, including two companies in Shanghai.

Who was designated?

Party	Location indicated by OFAC	Role according to the US Treasury
Karnakis and Karnakis	Panama City and Piraeus (Greece)	law firm that registers the shipowning companies of the shadow fleet and provides their directors, obscuring the real beneficial owners
Roxette Maritime Shipping and Trading S.A.	Panama and Piraeus (Greece)	operator and manager of seven Panama-flagged cargo vessels
Amigoz Singapore Pte. Ltd.	Singapore	shipping agency that handled a shipment of Iranian crude and supplied a shadow fleet vessel
Whales Shipping Line LLC	Dubai (United Arab Emirates)	shipping agent of a Dubai company already sanctioned, buyer of Iranian petrochemicals

The blocked vessels are ANEMOS (IMO 9205952), DESTINY (IMO 9385491), FLAMINGO 1 (IMO 9474199), GLORIS (IMO 9449510), HARMONY (IMO 9449522), PRIDE (IMO 9487407) and PRINCE (IMO 9548316), flagged in Panama and linked to Roxette, plus WHALES DIAMOND (IMO 9375032) and WHALES PEARL (IMO 9483114), flagged in the Emirates and linked to Whales Shipping Line. According to the Treasury, ANEMOS, GLORIS and PRIDE carried goods of Iranian origin in the past year, including petrochemicals and steel products. Five individuals linked to the law firm were also designated: their names are on the OFAC page linked in the sources.

What does a designation entail?

According to the Treasury's press release, the property of designated persons that is located in the United States or is controlled by US persons is blocked, and companies owned 50% or more, directly or indirectly, by one or more blocked persons are also blocked. US persons generally cannot deal with them without a licence. The Treasury adds that non-US persons may not cause US persons to violate sanctions or evade them, and that foreign financial institutions that facilitate significant transactions for designated persons risk secondary sanctions.

The press release does not mention Italian companies. For those exporting from Italy, the practical effect to verify concerns payments in US dollars, correspondent banks and partners with ties to the United States.

What to do if you export or ship to the Middle East and Asia

• Search for names and IMO numbers of vessels, shipowners, agents and intermediaries in your shipments in the OFAC list (Sanctions List Search) and in the EU Sanctions Map.
• Check who registers and administers the shipowner or the buyer: the scheme described by the Treasury uses a law firm to put its own employees as directors of the companies, so that the beneficial owner does not appear.
• Apply the 50% rule: a company not on the list but owned by half or more by designated persons is blocked as well.
• Ask your bank whether payments from a new customer or a new freight forwarder pass through US correspondent banks.

The same check applies to the Italian side of the chain: a distributor or intermediary that buys in order to resell abroad. The beneficial owner (€9.90) reconstructs, from the Registro Imprese (Italian Business Register), the shareholders and directors of the Italian company with which you sign the contract, before you ship the goods.

Sources

• OFAC, «Iran-related Designations; Belarus and North Korea Designations Removals; Issuance of Iran-related and Russia-related General Licenses and Amended Frequently Asked Questions», 21 October 2026, accessed 24/10/2026
• U.S. Department of the Treasury, «Operation Economic Outcast Targets Iran's Shadow Fleet Networks», press release of 21 October 2026, accessed 24/10/2026