US Sanctions Law Firm, Nine Ships; FinCEN Subpoenas Greek Bank

Analysis

The US Treasury on October 21 sanctioned a law firm operating in Panama and Greece, five individuals, three shipping companies and nine vessels linked to Iran's international commodity trade. At the same time, its financial-crimes bureau opened a new front: an investigation into a Greek bank's potential connections to Iran.

The action is part of Operation Economic Outcast, launched by Treasury Secretary Scott Bessent on August 24 to restrict the Iranian government's access to export revenue and financial services.

What Treasury targeted

A law firm at the center of the network. Treasury says Karnakis and Karnakis registered shipping companies and supplied corporate officers who obscured the companies' beneficial owners. The firm also helped establish companies connected to Iranian liquefied petroleum gas (LPG) exports. OFAC designated the firm under Executive Order 13902.

Five individuals. OFAC designated Sofianos, Konstantinos and Ioanis Karnakis Kosmas, along with Pedro and Roberto Ortega Jones, for acting on behalf of the firm.

Three shipping businesses. The designated companies are Roxette Maritime Shipping and Trading S.A. in Panama and Greece, Amigoz Singapore PTE. Ltd. and Whales Shipping Line LLC in Dubai.

Nine vessels. The OFAC list identifies seven Panama-flagged cargo and bulk vessels—ANEMOS, DESTINY, FLAMINGO 1, GLORIS, HARMONY, PRIDE and PRINCE—and two UAE-flagged supply vessels, WHALES DIAMOND and WHALES PEARL.

The designations block the targets' property and interests in property under US jurisdiction and generally prohibit US persons from dealing with them. OFAC also issued General Licenses GG and HH for specified wind-down, safety, environmental and cargo-offloading transactions.

Why the Greek bank matters

The Financial Crimes Enforcement Network ( FinCEN ) announced its first administrative subpoena under 31 U.S.C. 5318(k). It is seeking records as part of an investigation into an unnamed Greek bank's potential connections to Iran and its proxies.

The provision reaches beyond US borders. A foreign bank that maintains a US correspondent account—an account used to access the American banking system—can be compelled to produce records held overseas. Under the statute , failure to comply can ultimately lead Treasury to require a US bank to terminate that correspondent relationship within ten business days.

The subpoena is an investigative step, not a finding that the Greek bank violated the law. Its importance is the reach of the enforcement tool: banks outside the United States may face a direct choice between producing records and protecting access to US correspondent banking.

The economic consequence

Washington is attacking two layers of Iran's trading system at once: the corporate structures and vessels that move commodities, and the banking connections that help settle the transactions.

A shadow fleet uses opaque ownership and changing flags or operating companies to keep cargo moving despite sanctions. Designating vessels can make port services, insurance and payments more difficult. Investigating a foreign bank adds pressure on the financial intermediaries that enable the trade.

The networks can adapt by changing service providers, ownership structures and routes. The decisive question is whether sustained enforcement makes those substitutions more costly and less reliable.

What we're watching

Whether FinCEN takes further action involving the Greek bank or other correspondent accounts.

Whether the nine designated ships change operators, flags or trading patterns.

Whether the next sanctions rounds reach additional corporate-service firms and shipping agents.

Sources

US Treasury announcement, October 21 .

FinCEN announcement, October 21 .

OFAC designations and general licenses, October 21 .

31 U.S.C. 5318(k) .