Washington Sanctions a Panama Law Firm That Built Iran's Shadow Fleet Shells
On 21 October 2026 OFAC designated 18 parties under Executive Order 13902 in a strike on the professionals and agents behind Iran's shadow fleet. The lead target is Karnakis and Karnakis, a law firm in Panama City and Piraeus that Treasury says registered shipping companies already sanctioned for carrying Iranian oil and acted as corporate agent for Iranian LPG magnate Seyed Asadoollah Emamjomeh. Its two owners and three staff, who sit as nominee directors, were designated with it. OFAC also named ship manager Roxette Maritime and seven Panama-flagged cargo ships, Singapore port agent Amigoz and Dubai's Whales Shipping Line with two support vessels. General Licenses GG and HH allow a wind-down to 20 November for the law firm and for Roxette and its ships. The same notice removed three Shanghai parties tied to North Korea's SEK Studio and Belarusian Andrei Rybakov, who stays on the EU list, and renewed the Lukoil International licence as GL 131K.
This issue
- New designations
- 18
- Removals
- 4
- Entries amended
- 0
- Sources monitored
- 100
The Lawyers, the Ship Manager and the Agents
Treasury designated Karnakis and Karnakis under Executive Order 13902 for operating in Iran's petroleum and petrochemical sectors. It says the firm set up shipping companies already sanctioned for carrying Iranian oil, among them Elias Shipping and Trading, a front for Syria's Al-Qatirji Company, and served as corporate agent for the businesses of Iranian LPG magnate Seyed Asadoollah Emamjomeh. Its owners, Sofianos and Konstantinos Karnakis Kosmas, and staff Ioanis Karnakis Kosmas, Pedro Ortega Jones and Roberto Ortega Jones were designated for acting for the firm; Treasury says staff sit as directors of the companies it registers to hide their real owners.
Roxette Maritime Shipping and Trading S.A., for which the firm is corporate agent, manages seven Panama-flagged cargo ships now identified as blocked property: ANEMOS, DESTINY, FLAMINGO 1, GLORIS, HARMONY, PRIDE and PRINCE. Singapore port agent Amigoz Singapore Pte. Ltd. and Dubai's Whales Shipping Line LLC, owner of the support vessels WHALES DIAMOND and WHALES PEARL, were designated as agents to the shadow fleet. General Licenses GG and HH allow a wind-down to 20 November for the law firm and for Roxette and its ships, but not for Amigoz or Whales. Treasury also said FinCEN had issued its first administrative subpoena under the Bank Secrecy Act in an inquiry into a Greek bank's possible ties to Iran.
Party detail
Every row below was read against the issuing authority's own notice, not against a press report. Aliases are reproduced in full, including non Latin script forms, because the alias field is where a screening run usually fails. Identifiers are published sanctions data.
| Party | Action and instrument | Identifiers | Grounds |
|---|---|---|---|
| Sofianos Karnakis Kosmas | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Date of birth: 6 Jan 1975Place of birth: PanamaNationality: Panama, GreeceIdentifier: Cedula No. 8-708-550 (Panama)Passport: PA1335856 (Panama), expires 5 Feb 2030Address: Panama City, Panama | Designated under E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Karnakis and Karnakis. Treasury says the Panama- and Greece-based law firm has for years registered the shipping companies that own shadow fleet vessels carrying Iranian steel, petroleum and petrochemicals, and that its staff serve as directors and officers of those companies to hide their true owners. |
| Konstantinos Karnakis Kosmas | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Date of birth: 22 Feb 1981Place of birth: PanamaNationality: Panama, GreeceIdentifier: Cedula No. 8-744-805 (Panama)Passport: PA1035491 (Panama), expires 4 Apr 2028Address: Panama | Designated under E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Karnakis and Karnakis. Treasury says the Panama- and Greece-based law firm has for years registered the shipping companies that own shadow fleet vessels carrying Iranian steel, petroleum and petrochemicals, and that its staff serve as directors and officers of those companies to hide their true owners. |
| Ioanis Karnakis Kosmas | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Date of birth: 20 Aug 1982Place of birth: PanamaNationality: PanamaPassport: PA1335855 (Panama), expires 5 Feb 2030Address: Panama City, Panama | Designated under E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Karnakis and Karnakis. Treasury says the Panama- and Greece-based law firm has for years registered the shipping companies that own shadow fleet vessels carrying Iranian steel, petroleum and petrochemicals, and that its staff serve as directors and officers of those companies to hide their true owners. |
| Pedro Ortega Jones | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Date of birth: 31 Jan 1976Place of birth: PanamaNationality: PanamaIdentifier: Cedula No. 8-505-139 (Panama)Passport: PA0865191 (Panama), expires 10 Mar 2027Address: Panama City, Panama | Designated under E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Karnakis and Karnakis. Treasury says the Panama- and Greece-based law firm has for years registered the shipping companies that own shadow fleet vessels carrying Iranian steel, petroleum and petrochemicals, and that its staff serve as directors and officers of those companies to hide their true owners. |
| Roberto Ortega Jones | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Date of birth: 24 Dec 1972Place of birth: PanamaNationality: PanamaIdentifier: Identification Number PE-7-925 (Panama)Address: Panama City, Panama | Designated under E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Karnakis and Karnakis. Treasury says the Panama- and Greece-based law firm has for years registered the shipping companies that own shadow fleet vessels carrying Iranian steel, petroleum and petrochemicals, and that its staff serve as directors and officers of those companies to hide their true owners. |
| Karnakis and Karnakis | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Identifier: RUC 921299-2-23411 (Panama)Identifier: established 13 Mar 2006Identifier: website karnakiskarnakis.comAddress: Global Plaza Building, Calle 50, Floor 21, Panama City, Panama; 158 II Merachias and Alkiviadou, Piraeus 185 35, Greece | Designated under E.O. 13902 for operating in the petroleum and petrochemical sectors of the Iranian economy. Treasury says the firm set up Skyros Maritime and Trading S.A., Corfu Maritime and Trading S.A. and Elias Shipping and Trading Group S.A., all previously designated for owning vessels in the Iranian oil trade, and acted as corporate agent for many firms of Iranian LPG magnate Seyed Asadoollah Emamjomeh. |
| Roxette Maritime Shipping and Trading S.A. | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Identifier: RUC 155731846-2-2023 (Panama)Identifier: company IMO 6385886Identifier: established 3 Jan 2023Address: Panama; 5th Floor, 90 Iroon Politechneiou Avenue, Piraeus 185 36, Greece | Designated under E.O. 13902 for operating in the petrochemical sector of the Iranian economy. Treasury says ANEMOS, GLORIS and PRIDE, which Roxette manages, have shipped Iranian-origin petrochemicals and steel within the past year. |
| Amigoz Singapore Pte. Ltd. | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Identifier: Business Number 201940121Z (Singapore)Identifier: established 27 Nov 2019Identifier: website amigozsg.comAddress: 2 Leng Kee Road, #02-10, Thye Hong Centre, Singapore 159086, Singapore | Designated under E.O. 13902 for operating in the petroleum sector of the Iranian economy. Treasury says it acted as agent for a light crude shipment overseen by Sepehr Energy Jahan Nama Pars Company, has been associated with dark fleet actors including some tied to Mohammad Hossein Shamkhani's network, and bunkered the Iranian shadow fleet vessel ZIXUAN (IMO 9317298). |
| Whales Shipping Line LLC | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Identifier: Licence 681649Identifier: Chamber of Commerce No. 213388Identifier: Business Registration No. 10889096Identifier: Registration No. 1107940 (UAE)Identifier: company IMO 6417176Identifier: established 9 Jan 2013Identifier: website www.whalesshipping.comAddress: Office 412, Parcel 243-210, Al Qusais Industrial Second, Deira, Dubai, United Arab Emirates; 405 Al Mansour Building, Damascus Road, Al Qusais, Dubai, United Arab Emirates | Designated under E.O. 13902 for materially assisting Amigoz Singapore Pte. Ltd. Treasury says Whales acted as shipping agent for Sparrow Trading FZE, a sanctioned Dubai front company that bought Iranian petrochemicals with Persian Gulf Petrochemical Industry Commercial Co., and did business worth hundreds of thousands of dollars with Amigoz. |
| ANEMOS | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Nationality: PanamaIdentifier: IMO 9205952Identifier: MMSI 352898798Identifier: call sign 3E2064Identifier: built 1999 | Identified under E.O. 13902 as blocked property in which Roxette Maritime Shipping and Trading S.A. has an interest; Roxette is the ship manager and operator. Treasury says it has shipped Iranian-origin goods, including petrochemicals and steel, within the past year. |
| DESTINY | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Nationality: PanamaIdentifier: IMO 9385491Identifier: MMSI 370662000Identifier: call sign 3FRG6Identifier: built 2009 | Identified under E.O. 13902 as blocked property in which Roxette Maritime Shipping and Trading S.A. has an interest; Roxette is the ship manager and operator. Do not confuse it with an Iran-related crude oil tanker of the same name (SDN entry 15725): screen on IMO 9385491. |
| FLAMINGO 1 | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Nationality: PanamaIdentifier: IMO 9474199Identifier: MMSI 352002503Identifier: call sign 3E2656Identifier: built 2010 | Identified under E.O. 13902 as blocked property in which Roxette Maritime Shipping and Trading S.A. has an interest; Roxette is the ship manager and operator. |
| GLORIS | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Nationality: PanamaIdentifier: IMO 9449510Identifier: MMSI 352003155Identifier: call sign 3E6032Identifier: built 2010 | Identified under E.O. 13902 as blocked property in which Roxette Maritime Shipping and Trading S.A. has an interest; Roxette is the ship manager and operator. Treasury says it has shipped Iranian-origin goods, including petrochemicals and steel, within the past year. |
| HARMONY | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Nationality: PanamaIdentifier: IMO 9449522Identifier: MMSI 352003307Identifier: call sign 3E7470Identifier: built 2010 | Identified under E.O. 13902 as blocked property in which Roxette Maritime Shipping and Trading S.A. has an interest; Roxette is the ship manager and operator. Do not confuse it with two earlier Iran-related vessels of the same name (SDN entries 47312 and 53898): screen on IMO 9449522. |
| PRIDE | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Nationality: PanamaIdentifier: IMO 9487407Identifier: MMSI 352003589Identifier: call sign 3E5229Identifier: built 2011 | Identified under E.O. 13902 as blocked property in which Roxette Maritime Shipping and Trading S.A. has an interest; Roxette is the ship manager and operator. Treasury says it has shipped Iranian-origin goods, including petrochemicals and steel, within the past year. |
| PRINCE | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Nationality: PanamaIdentifier: IMO 9548316Identifier: MMSI 352005105Identifier: call sign 3E8283Identifier: built 2010 | Identified under E.O. 13902 as blocked property in which Roxette Maritime Shipping and Trading S.A. has an interest; Roxette is the ship manager and operator. |
| WHALES DIAMOND | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Nationality: United Arab EmiratesIdentifier: IMO 9375032Identifier: MMSI 470132000Identifier: call sign A6E2076Identifier: built 2006 | Identified under E.O. 13902 as blocked property in which Whales Shipping Line LLC, its registered owner, has an interest. A small UAE-flagged support vessel. |
| WHALES PEARL | DesignationExecutive Order 13902 (Iran: petroleum and petrochemical sectors); SDN tag [IRAN-EO13902] | Nationality: United Arab EmiratesIdentifier: IMO 9483114Identifier: MMSI 470034000Identifier: built 2008 | Identified under E.O. 13902 as blocked property in which Whales Shipping Line LLC, its registered owner, has an interest. A small UAE-flagged support vessel. |
| Moxing Cartoon | RemovalNorth Korea Sanctions Regulations, 31 CFR part 510; SDN tag [DPRK3] | Registration number: 310104000572013 (China)Identifier: Unified Social Credit Code 913101040936933514Address: 901-7, No. 439 Yishan Road, Xuhui District, Shanghai, China | Removed from the SDN List on 21 October 2026; OFAC gave no reason. The entry was linked to SEK Studio, North Korea's state animation studio, which OFAC had designated for taking work from foreign customers. Listed under the a.k.a. Shanghai Moxing Cultural Media Co Ltd. |
| Lu Hezheng | RemovalNorth Korea Sanctions Regulations, 31 CFR part 510; SDN tag [DPRK3] | Date of birth: 6 Apr 1974Place of birth: Shanghai, ChinaNationality: ChinaNational ID: 31010619740406283X (China)Address: Room 810, No. 760, Qinzhou Road, Xuhui District, Shanghai, China; Guangzhou, Guangdong, China | Removed from the SDN List on 21 October 2026; OFAC gave no reason. The entry was linked to SEK Studio, North Korea's state animation studio, which OFAC had designated for taking work from foreign customers. |
| Shanghai Hongman Cartoon and Animation Design Studio | RemovalNorth Korea Sanctions Regulations, 31 CFR part 510; SDN tag [DPRK3] | Registration number: 310104000570122 (China)Identifier: Unified Social Credit Code 91310104093794515HAddress: Room 705, Floor 7, Building 1, No. 1919 Zhongshan West Road, Xuhui District, Shanghai, China | Removed from the SDN List on 21 October 2026; OFAC gave no reason. The entry was linked to SEK Studio, North Korea's state animation studio, which OFAC had designated for taking work from foreign customers. Linked on the list to Lu Hezheng. |
| Andrei Alekseevich Rybakov | RemovalBelarus sanctions programme; SDN tag [BELARUS] | Date of birth: 11 Jul 1976Place of birth: Mahilyow, BelarusNationality: BelarusAddress: Minsk, Belarus | Removed from the SDN List on 21 October 2026; OFAC gave no reason. He remains listed by the European Union under its Belarus regime, which records an Andrei Aliakseevich Rybakou born 11 July 1976 in Mogilev as Director General of OAO Belaruskali and a former chairman of the Belneftekhim state concern. |
What this means for your organisation
- 01
Load the 18 designations today: Add the five individuals, four entities and nine vessels with their passport, cedula, RUC, business and IMO numbers, and run a retrospective screen across customers, counterparties and payments.
- 02
Screen ships on IMO number, not name: DESTINY (IMO 9385491) and HARMONY (IMO 9449522) share names with Iran-related vessels already on the SDN List; a name hit alone cannot tell them apart, and an IMO hit should not be cleared on a name mismatch.
- 03
Look through nominee directors and agents: Search company registers and KYC files for Karnakis and Karnakis, its Panama and Piraeus addresses and the five named people as director, secretary or registered agent, and escalate any match for enhanced due diligence.
- 04
Respect the wind-down limits: General Licenses GG and HH run to 12:01 a.m. EST on 20 November for the law firm and for Roxette and its seven ships only; any payment to a blocked person goes to a blocked account, and Amigoz and Whales have no licence.
- 05
Process the four removals carefully: Release US-only alerts for the three Shanghai parties, but keep Andrei Alekseevich Rybakov flagged wherever EU law applies, because the EU still lists him.
Where this issue came from
The map plots the sources Youverify monitors. The pulsing markers are the one authorities cited in this issue: US-OFAC. Hover any marker to name the sources read there.
Method statement
Every entry is read word for word from OFAC's Recent Actions notice of 21 October 2026 and confirmed in the SDN data file of 22 October; the four removals are matched to the SDN file of 19 October. Grounds are taken from the Treasury press release of the same day and the licence terms from the OFAC General License texts. Every name and IMO number was searched on the UK, EU, UN and Swiss lists.
Corrections
No corrections issued for this issue. Corrections are published on the issue they affect, dated, with the original text retained.Cite this issue
Vyra from Youverify. "Washington Sanctions a Panama Law Firm That Built Iran's Shadow Fleet Shells." Youverify Sanctions Monitor, issue 152, 22 October 2026. https://youverify.co/en/sanctions/2026-10-22. Accessed 22 October 2026.