Operation Economic Outcast Targets Iran’s Shadow Fleet Networks

Law Firms, Shipping Agents, and Vessels Helped Conceal and Transport Iranian Commodities

WASHINGTON-Today, as part of Operation Economic Outcast, the U.S. Department of the Treasury sanctioned Panama- and Greece-based law firm Karnakis and Karnakis, which has supported illicit Iranian shipping activity for years, indirectly aiding Tehran's ability to generate revenue to fund its military, weapons, and nuclear programs. Throughout Operation Economic Outcast, Treasury has continued to coordinate with counterparts in Europe and around the world to sever the Iranian regime's remaining economic lifelines.

"Whether you are conducting illegal oil transfers at sea or sitting in the corner office of a law firm, if you are supporting the Iranian regime, we will find you and sanction you," said Secretary of the Treasury Scott Bessent. "Iran's facilitators must make a choice: Either you are with us or against us. We know who you are, we know what you're doing, and we will continue to take action."

Treasury today also sanctioned Singapore- and UAE-based shipping agents that directly aid Iranian shadow fleet operations. Today's actions strike not only the legal and maritime facilitators that sustain Iran's sanctions-evasion networks, but also a fleet of cargo vessels that has helped generate substantial revenue for the Iranian regime.

The designations imposed today are being taken pursuant to Executive Order (E.O.) 13902, which targets the Iranian petroleum and petrochemical sectors, among other key sectors of the Iranian economy.

FinCEN is acting in close coordination with European partners, including in Greece, and leveraging existing legal authorities, such as its first issuance of an administrative subpoena pursuant to 31 U.S.C. § 5318(k) of the Bank Secrecy Act, to advance its investigation into a Greek bank's potential ties to Iran and its proxies. Additionally, FinCEN has issued multiple requests for information concerning banks' relationships with OFAC-designated Iranian financial institutions.

OPERATION ECONOMIC OUTCAST IS ISOLATING THE IRANIAN REGIME

Announced by Secretary Bessent on August 24, 2026 and dubbed Economic D-Day, Operation Economic Outcast is severing the remaining economic lifelines that sustain the Iranian regime. Treasury has mapped the networks, facilitators, and financial channels that Iran uses to smuggle oil, evade sanctions, and fund terror. Working with partners across the U.S. government, the European Union, United Kingdom, Gulf partners, and others, Treasury is targeting any source of the regime's illicit revenue, as well as its sanctions evasion schemes to move funds.

Operation Economic Outcast significantly expanded sanctions risk for those who continue to choose to do business with Iran. Treasury warned that any entity facilitating money laundering or sanctions evasion on behalf of Iran risks being cut off from the U.S. financial system. Operation Economic Outcast also expanded sanctions exposure for non-U.S. persons who continue doing business with the Iranian regime and will accelerate the pace of U.S. enforcement. More information on Operation Economic Outcast is available here.

LAW FIRM ESTABLISHING SHADOW FLEET ARCHITECTURE

Through Operation Economic Outcast, Treasury is targeting law firms and corporate service providers that establish shell and front companies for persons trading in sanctioned Iranian products, an essential service needed for any such malign actor to evade sanctions or regulatory compliance. Panama- and Greece-based law firm Karnakis and Karnakis has for years leveraged its legal practice to register shipping companies that own shadow fleet vessels responsible for shipping hundreds of millions of dollars' worth of Iranian steel, petroleum, and petrochemicals, among other goods. The firm previously set up the companies Skyros Maritime and Trading S.A., Corfu Maritime and Trading S.A., and Elias Shipping and Trading Group S.A., among others, all of which OFAC has previously designated for their ownership of vessels active in the trade of Iranian petroleum and petroleum products.

Elias Shipping and Trading SA, the owner of the RAMONA 1 (IMO: 9233222), served as a front company for the Al-Qatirji Company, a Syrian firm responsible for selling millions of barrels of Iranian oil for the benefit of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Houthis. The Al-Qatirji Company at the time of its designation was one of the main financial channels for the IRGC-QF, enabling the terrorist group to generate and access hundreds of millions of dollars a year in revenue gained from the sale of Iranian oil.

Karnakis and Karnakis played a particularly critical role in establishing the corporate architecture for the shipping empire of Iranian liquified petroleum gas (LPG) magnate Seyed Asadoollah Emamjomeh (Emamjomeh), which is collectively responsible for shipping 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 firms, including several that were ultimately designated for their role in shipping Iranian petroleum products.

Karnakis and Karnakis was founded, and is currently owned, by dual Panamanian-Greek nationals Sofianos Karnakis Kosmas and Konstantinos Karnakis Kosmas, with Panamanian-Greek national Ioanis Karnakis Kosmas and Panamanian national Pedro Ortega Jones serving as employees of the law firm. Karnakis and Karnakis employees, including Panamanian national Roberto Ortega Jones, act as directors and officers of many of the companies they register in order to obfuscate the true beneficial owners of these companies.

Karnakis and Karnakis is being designated pursuant to E.O. 13902 for operating in the petroleum and petrochemical sectors of the Iranian economy. Sofianos Karnakis Kosmas, Konstantinos Karnakis Kosmas, Pedro Ortega Jones, Roberto Ortega Jones, and Ioanis Karnakis Kosmas are being designated pursuant to E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Karnakis and Karnakis.

CARGO FLEET VESSELS

Iran relies on seemingly legitimate cargo vessels to move Iranian petrochemicals and other products, including steel. Panama- and Greece-based Roxette Maritime Shipping and Trading S.A. (Roxette), for which Karnakis and Karnakis serves as the corporate agent, is the operator and ship manager of the Panama-flagged vessels ANEMOS (IMO 9205952), GLORIS (IMO 9449510), and PRIDE (IMO 9487407), all of which have shipped various cargos of Iranian-origin goods within the past year, including petrochemicals and steel products. In addition, Roxette is the ship manager and operator of the Panama-flagged cargo vessels DESTINY (IMO 9385491), FLAMINGO 1 (IMO 9474199), HARMONY (IMO 9449522), and PRINCE (IMO 9548316).

Roxette Maritime Shipping and Trading S.A. is being designated pursuant to E.O. 13902 for operating in the petrochemical sector of the Iranian economy. ANEMOS, GLORIS, PRIDE, DESTINY, FLAMINGO 1, HARMONY, and PRINCE are being identified pursuant to E.O. 13902 as blocked property in which Roxette Maritime Shipping and Trading S.A. has an interest.

SHIPPING AGENTS AIDING SHADOW FLEET

Shipping agents play a critical role in shadow fleet operations by aiding the transit of illicit Iranian cargo through ports, including oil, petroleum, and other commodities. Treasury is taking action against two shipping agents that have helped Iran transport its products to buyers around the world.

• Amigoz Singapore PTE. Ltd. (Amigoz) is a Singapore-based full-range shipping agency that provides port agency services. Amigoz acted as the agent for a shipment of light crude oil overseen by Sepehr Energy Jahan Nama Pars Company, which oversees a network of front companies that supports the allocation of billions of dollars' worth of commodities to Iranian military entities. As of 2026, Amigoz has been associated with a range of dark fleet actors, including some affiliated with the shipping empire of Mohammad Hossein Shamkhani, and provided bunkering services to the Iranian shadow fleet vessel ZIXUAN (IMO 9317298).
• Whales Shipping Line LLC (Whales), a Dubai-based maritime and logistics company, acted as the shipping agent for Sparrow Trading FZE, a sanctioned Dubai-based front company that organized the purchase of tens of millions of dollars' worth of Iranian petrochemicals in coordination with Persian Gulf Petrochemical Industry Commercial Co. Whales has also conducted business worth hundreds of thousands of dollars with Amigoz. Whales is the registered owner of two UAE-flagged small support vessels: WHALES DIAMOND (IMO 9375032) and WHALES PEARL (IMO 9483114).

Amigoz Singapore PTE. Ltd. is being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy. Whales Shipping Line LLC is being designated pursuant to E.O. 13902 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Amigoz Singapore PTE. Ltd. WHALES DIAMOND and WHALES PEARL are being identified as blocked property in which Whales Shipping Line LLC has an interest.

SANCTIONS IMPLICATIONS

As a result of today's action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC's regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.

Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC's Economic Sanctions Enforcement Guidelines provide more information regarding OFAC's enforcement of U.S. economic sanctions. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person. Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Individuals located in the U.S. or abroad who provide information about sanctions violations to FinCEN's whistleblower incentive program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities with designated or otherwise blocked persons.

Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions. OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.

The power and integrity of OFAC sanctions derive not only from OFAC's ability to designate and add persons to the Specially Designated Nationals and Blocked Persons List (SDN List), but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC's guidance on Filing a Petition for Removal from an OFAC List.

Click here for more information on the persons designated today.

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