Treasury Sanctions a Greek Law Firm Behind Iran Shadow Fleet Ships as FinCEN Issues Its First Subpoena to a European Bank

The Treasury Department sanctioned a Greek and Panamanian law firm on October 21, 2026, for registering the shipping companies behind Iran’s shadow fleet. The same day it disclosed that FinCEN had used its Bank Secrecy Act subpoena power for the first time to dig into a Greek bank’s possible ties to Iran.

Both moves are part of Operation Economic Outcast, the campaign Treasury launched on August 24 to cut Iran off from the financial system. Treasury Secretary Scott Bessent put the message bluntly: “if you are supporting the Iranian regime, we will find you and sanction you.”

A law firm as the target

The Office of Foreign Assets Control designated nine people and companies under Executive Order 13902, which covers Iran’s petroleum and petrochemical sectors. The center of the action is Karnakis and Karnakis, a firm based in Panama and Greece. Treasury says it “has for years leveraged its legal practice to register shipping companies that own shadow fleet vessels.”

Treasury ties the firm to the network of Seyed Asadoollah Emamjomeh, an Iranian liquefied petroleum gas magnate. Several of his firms were designated earlier. Treasury says his network has shipped hundreds of millions of dollars’ worth of Iranian LPG and crude oil. Karnakis and Karnakis served as the corporate agent for many of Emamjomeh’s companies. Firms tied to it also moved Iranian steel, petroleum and petrochemicals.

Photo: Cristo Vlahos, CC BY-SA 4.0 via Wikimedia Commons

Three Karnakis family members were listed with the firm. So were two Panamanian employees, Pedro Ortega Jones and Roberto Ortega Jones. Treasury says Roberto serves as a director and officer of many of the companies the firm registers, which hides who really owns them.

Three companies round out the list. Roxette Maritime Shipping and Trading operates and manages seven Panama-flagged cargo ships, with the law firm as its corporate agent. Amigoz Singapore, a shipping agent, handled a light crude cargo overseen by an Iranian oil company and dealt with shadow fleet operators linked to the shipping empire of Mohammad Hossein Shamkhani. Whales Shipping Line, based in Dubai, was the shipping agent for Sparrow Trading FZE, a front company already under sanctions.

OFAC identified nine ships as blocked property: Roxette’s ANEMOS, GLORIS, PRIDE, DESTINY, FLAMINGO 1, HARMONY and PRINCE, and Whales Shipping’s WHALES DIAMOND and WHALES PEARL. It issued General License GG to let counterparties wind down dealings with the law firm, and General License HH for wind-down, limited safety and environmental transactions and offloading cargo from the blocked ships.

Shadow fleets run on paperwork: shell owners, flag registrations, agents who sign for cargoes. With this round, Treasury went after the firm that produced the paperwork as well as the ships it covered.

FinCEN’s new tool, used on Greece

The second half of the announcement may matter more. Treasury said FinCEN, its financial intelligence unit, is working with European partners, including Greece. As part of that, it issued “its first administrative subpoena pursuant to 31 U.S.C. § 5318(k) of the Bank Secrecy Act” to advance an investigation into “a Greek bank’s potential ties to Iran and its proxies.” Treasury didn’t name the bank. FinCEN has also sent banks several requests for information about their relationships with Iranian financial institutions under OFAC sanctions.

Section 5318(k) lets the Treasury Secretary or the Attorney General subpoena any foreign bank that keeps a correspondent account in the United States. The subpoena can reach records of that account and of other accounts at the foreign bank, including records held overseas. A bank that doesn’t comply faces civil penalties of up to $50,000 a day. Treasury or Justice can also order US banks to close its correspondent account within 10 business days. For a European bank, losing dollar clearing is the real threat.

Greece’s finance ministry said on October 22 that it had taken note of the Treasury statement, that it applies existing Iran sanctions, and that “all available information is being evaluated.”

This follows OFAC’s October 15 action against Iranian offshore banks and exchange houses, also under Operation Economic Outcast. That round went after Iran’s own banks. This one reaches into an EU member’s banking system.

A Russia license on the same day

OFAC used the same release for an unrelated Russia step. It issued General License 131K, which replaces 131J of September 18 and runs to 12:01 a.m. Eastern time on November 21, 2026. It lets parties negotiate and sign contracts to sell Lukoil International GmbH, the oil company’s foreign arm, and keep that business running in the meantime. Any sale contract has to be expressly contingent on separate OFAC authorization. The license doesn’t unblock property or allow transfers of funds into Russia. It’s the latest in a string of Lukoil license extensions since the company was sanctioned in October 2025.

On Iran, Bessent framed the choice for third countries in one line: “Either you are with us or against us.”