OFAC lists a Panama and Piraeus law firm it says registered Iran shadow fleet owners

The US Office of Foreign Assets Control (OFAC) on 21 October designated Karnakis and Karnakis, a law firm with offices in Panama City and Piraeus, together with five individuals linked to it, a Panama-registered ship operator, nine vessels and two shipping agents in Singapore and Dubai, under Executive Order 13902 on Iran, according to the OFAC recent action notice. The listings carry the programme tag IRAN-EO13902. Two Iran-related general licences issued the same day allow wind-down dealings until 12:01 a.m. eastern standard time on 20 November 2026.

Treasury says the firm has for years used its legal practice to register shipping companies that own vessels in Iran's shadow fleet, and that some of its employees served as directors and officers of those companies to conceal their beneficial owners, Seatrade Maritime reported. Treasury also says the firm had a role in establishing the corporate structure of the shipping business of Seyed Asadoollah Emamjomeh, whom it describes as an Iranian LPG magnate. The firm had been approached for comment, Riviera Maritime Media reported on 22 October.

Who is listed

The notice lists five individuals, all with addresses in Panama: Sofianos, Konstantinos and Ioanis Karnakis Kosmas, the first two also listed with Greek nationality, and Pedro and Roberto Ortega Jones. Each entry is linked to Karnakis and Karnakis. The firm itself is listed at the Global Plaza Building in Panama City and at an address in Piraeus, with its activity given as legal activities and its establishment date as 13 March 2006. According to Treasury, as reported by Seatrade, Sofianos and Konstantinos Karnakis Kosmas founded and own the firm, while Ioanis Karnakis Kosmas and Pedro Ortega Jones are employees.

Roxette Maritime Shipping and Trading S.A., registered in Panama in January 2023 with an office in Piraeus, is listed with seven Panama-flagged ships: the general cargo vessels ANEMOS, DESTINY and HARMONY and the bulk carriers FLAMINGO 1, GLORIS, PRIDE and PRINCE. Treasury says Karnakis and Karnakis is Roxette's corporate agent and that the company operates and manages vessels that carried Iranian-origin cargoes over the past year, according to Riviera's report. Roxette was designated for operating in Iran's petrochemical sector, Seatrade reported.

The two agents are Amigoz Singapore Pte. Ltd. and Whales Shipping Line LLC of Dubai, which the OFAC notice links to Amigoz. Two UAE-flagged crew and supply vessels, WHALES DIAMOND and WHALES PEARL, are listed as linked to Whales Shipping Line. Treasury says Amigoz acted as agent for a light crude shipment overseen by Sepehr Energy Jahan Nama Pars Company and supplied bunkers to a shadow fleet vessel, and that Whales Shipping Line acted as shipping agent for Sparrow Trading FZE, a Dubai company already under US sanctions, Seatrade reported.

The wind-down terms

General License GG authorises transactions ordinarily incident and necessary to winding down dealings with Karnakis and Karnakis and entities it owns 50 per cent or more, including dealings with blocked individuals acting only as its officers or employees. Any payment to a blocked person must go into a blocked account, the licence text says.

General License HH covers Roxette and its seven vessels. It allows docking and departing at ports outside Iran and Russia, crew safety, emergency repairs and environmental mitigation, and the offloading of cargo that is not of Iranian origin and was loaded on or before 21 October, provided it is not delivered to an Iranian or Russian port. Vessel management, crewing, bunkering, insurance, classification and salvage services are covered for those purposes, the licence states. It does not authorise new commercial contracts involving blocked property. The two UAE-flagged vessels and the two agents are not named in either licence.

Context

The action follows OFAC's 15 October listings of Iraq's International Development Bank and other parties in Iran's financial networks, reported in our earlier piece, and the shadow fleet designations recorded in the first Sanctions and Enforcement Ledger. According to Riviera, Treasury said Karnakis and Karnakis had previously been involved in setting up three shipping companies already designated by OFAC over vessels in the Iranian petroleum trade. Riviera also reported that Treasury said the Financial Crimes Enforcement Network is working with European partners, including Greece, on an investigation into an unnamed Greek bank's potential ties to Iran and its proxies, and that Greece's Ministry of National Economy and Finance said Greece implements the applicable sanctions.

For banks, registered agents and corporate service providers in Panama, the UAE and Singapore that deal with US persons or in US dollars, the point is that the two licences cover only the law firm, Roxette, entities each owns 50 per cent or more, the seven Roxette vessels and individuals acting solely for those entities. A designation is an administrative measure, not a finding by a court. The next fixed date is 20 November 2026, when General Licenses GG and HH expire.