The U.S. Department of the Treasury, acting on Wednesday, 21 October, under Operation Economic Outcast, designated Panama- and Greece-based law firm Karnakis and Karnakis, Singapore-based shipping agent Amigoz Singapore PTE. Ltd., Dubai-based Whales Shipping Line LLC, Panama- and Greece-based Roxette Maritime Shipping and Trading S.A., five associated individuals, and nine vessels linked to Iranian petroleum, petrochemical and steel movements. Treasury’s Office of Foreign Assets Control listed the persons and hulls pursuant to Executive Order 13902. OFAC also issued Iran-related General License GG, a wind-down authorisation for Karnakis and Karnakis through 12:01 a.m. eastern standard time on 20 November, and Iran-related General License HH, a wind-down, safety, environmental and cargo-offload authorisation for the seven Roxette hulls through the same clock. The working primaries are Treasury press release sb0664, OFAC’s 21 October recent-actions notice, and the two numbered general licences signed by OFAC Director Bradley T. Smith.
Wednesday is a named-IMO SDN increment plus two dated wind-down licences. It is not a rewrite of Treasury’s 8 October 22-tanker package, not Energy Secretary Chris Wright’s 19 October case-by-case remarks, and not a Hormuz transit-rule change. The useful facts for a DPA, a commercial manager, a port agent and a bank are the nine IMOs, the E.O. 13902 tag, General License GG’s Karnakis clock, General License HH’s Roxette annex, and the fact that Amigoz, Whales and the two UAE support vessels are not on those annexes. Do not brief Wright’s idle-tanker conversion remarks as this instrument, and do not brief Wednesday as a general licence for the 8 October 17 Treasury tankers.
What Treasury actually listed
Operation Economic Outcast was announced by Treasury Secretary Scott Bessent on 24 August. Wednesday’s notice is a facilitator-and-cargo increment, not the start of the campaign and not a naval blockade order. E.O. 13902 is the petroleum-and-petrochemical sector authority used for the whole 21 October Iran block. Screen that tag. A ship identified as blocked property in which a designated operator has an interest is still blocked. A company owned 50 percent or more, individually or in aggregate, by one or more blocked persons is still blocked even if it is not separately named.
Karnakis and Karnakis is printed with addresses at Global Plaza Building, Calle 50, Floor 21, Panama City, and at 158 II Merachias and Alkiviadou, Piraeus 185 35, Greece, organisation established 13 March 2006, RUC 921299-2-23411. Treasury says the firm registered shipping companies that own shadow-fleet vessels, including previously designated Skyros Maritime and Trading S.A., Corfu Maritime and Trading S.A., and Elias Shipping and Trading Group S.A., the last of those named as owner of RAMONA 1, IMO 9233222, and as a front for the already-designated Al-Qatirji Company. Treasury also says the firm served as corporate agent for companies in the shipping network of Iranian LPG trader Seyed Asadoollah Emamjomeh. Sofianos Karnakis Kosmas, Konstantinos Karnakis Kosmas, Ioanis Karnakis Kosmas, Pedro Ortega Jones and Roberto Ortega Jones are designated for having acted for the firm. Those five names belong on the KYC screen. They are not a substitute for the company SDN line.
Roxette Maritime Shipping and Trading S.A. is printed Panama and Piraeus, 5th Floor, 90 Iroon Politechneiou Avenue, established 3 January 2023, RUC 155731846-2-2023, IMO company number 6385886. Karnakis and Karnakis is described as its corporate agent. OFAC identifies seven Panama-flag cargo hulls as blocked property in which Roxette has an interest: ANEMOS, general cargo, IMO 9205952, MMSI 352898798, year built 1999; DESTINY, general cargo, IMO 9385491, MMSI 370662000, year built 2009; FLAMINGO 1, bulk carrier, IMO 9474199, MMSI 352002503, year built 2010; GLORIS, bulk carrier, IMO 9449510, MMSI 352003155, year built 2010; HARMONY, general cargo, IMO 9449522, MMSI 352003307, year built 2010; PRIDE, bulk carrier, IMO 9487407, MMSI 352003589, year built 2011; and PRINCE, bulk carrier, IMO 9548316, MMSI 352005105, year built 2010. Treasury’s narrative puts Iranian-origin petrochemicals and steel on ANEMOS, GLORIS and PRIDE in the past year. That cargo colour is a designation narrative, not a bill of lading. A renamed or reflagged hull with one of those IMOs is still in.
Amigoz Singapore PTE. Ltd. is printed at 2 Leng Kee Road, #02-10, Thye Hong Centre, Singapore 159086, established 27 November 2019, business number 201940121Z. Treasury says the agency acted for a light-crude shipment overseen by Sepehr Energy Jahan Nama Pars Company and, as of 2026, provided bunkering to ZIXUAN, IMO 9317298. ZIXUAN is already on the dedicated 8 October 22-tanker list. Wednesday is not a second listing of that IMO. It is a listing of the agent Treasury says stemmed it. Whales Shipping Line LLC is printed Dubai, Al Qusais, IMO company number 6417176, designated as having provided support to Amigoz. OFAC identifies two UAE-flag crew/supply vessels as blocked property in which Whales has an interest: WHALES DIAMOND, IMO 9375032, MMSI 470132000, year built 2006; and WHALES PEARL, IMO 9483114, MMSI 470034000, year built 2008. Those two IMOs are support craft, not the seven Roxette cargo hulls.
What the two general licences actually authorise
General License GG authorises, through 12:01 a.m. EST on 20 November 2026, transactions prohibited by the Iranian Transactions and Sanctions Regulations that are ordinarily incident and necessary to the wind-down of any transaction involving Karnakis and Karnakis, or any entity in which that firm owns, directly or indirectly, a 50 percent or greater interest. Payments to a blocked person must be made into a blocked account. Officers, employees or authorised representatives of those Karnakis entities, acting solely in that official capacity, may be involved only to effectuate that wind-down. Paragraph (c) is the limit that matters for a fixture: GG does not authorise transactions involving any other blocked person unless separately authorised. Roxette, Amigoz, Whales and the nine hulls are not a GG annex.
General License HH authorises, through the same 20 November 12:01 a.m. EST clock, five classes of activity involving the blocked persons and blocked vessels listed in its annex: wind-down of financial transactions; safe docking, anchoring and departure, excluding ports in Iran or the Russian Federation or under the control of those governments; preservation of crew health or safety; emergency repairs or environmental mitigation; and delivery and offloading of cargo that is not of Iranian origin, was loaded on or before 21 October 2026, and is not delivered at an Iranian or Russian port or a port under those governments’ control. Note 1 to paragraph (a) includes vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification and salvage. Paragraph (b) does not authorise new commercial contracts except as authorised by paragraph (a), and it does not authorise otherwise prohibited Iran, Government of Iran, or Iranian-origin goods or services. The annex is Roxette Maritime Shipping and Trading S.A. and the seven IMOs: 9205952, 9449510, 9487407, 9385491, 9474199, 9449522 and 9548316. It does not list Amigoz, Whales, WHALES DIAMOND or WHALES PEARL.
Keep Wednesday’s licences off the dedicated 8 October Samudra clock. General License EE remains a wind-down only for Samudra Marine Services Private Limited, or any entity Samudra owns 50 percent or more, through 12:01 a.m. eastern daylight time on 23 October. That clock is still running on Thursday morning and is not extended by GG or HH. There is still no published GL on this week’s file for the 17 Treasury tankers from 8 October, for SSPL, Hessonite, Horizon or One Plus, or for Wright’s idle-fleet conversion remarks. Russia-related General License 131K, on Lukoil International GmbH contingent-sale talks, sits on the same 21 October SDN notice. It is not an Iran shipping licence. FinCEN’s statement that it has issued an administrative subpoena under 31 U.S.C. § 5318(k) in an investigation of a Greek bank’s potential ties to Iran is enforcement colour, not a vessel list.
What Wednesday is not
Wednesday is not a delisting. HAKUNA MATATA, IMO 9354167, and PINOCCHIO, IMO 9400112, remain the 8 October container-ship removals after sale to non-sanctioned operators. They are not on this increment and are not a licence for ANEMOS or ZIXUAN. Panama’s AMP restriction and ex-officio deregistration of BITU, IMO 9531765, STARWAY, IMO 9273246, and MACKEREL, IMO 9234628, under Executive Decree No. 512 remains in process on its unused sheet. Wednesday does not complete those cancellations. Wright’s 19 October Citadel Securities remarks remain the dedicated 20 October 11:30 case-by-case piece. GG and HH are named general licences, which that piece said were missing, but they are Karnakis and Roxette wind-down paper. They are not a published approval checklist for buying idle SDN tankers into lawful crude trades, and they are not a blanket SDN wipe.
Keep Wednesday off Japan’s dedicated Foreign Exchange Act 35-IMO resident-services permit and off the UK’s dedicated 1 October LNG specifications. Those are a Japan-resident services ban identified by IMO only, and a UK shipping-and-trade specification on named hulls. Wednesday’s nine are U.S. SDN vessels under 13902. Do not merge the screens. Keep it off the dedicated Hormuz kinetic files. A designation is not a UKMTO warning, a JMIC naming, or a CENTCOM boarding. IMO’s Thursday 120-count naming of Soyia and Chloe is a separate instrument on this desk.
Operational implications
An SDN law-firm and agency list is a payments, port-agency, bunkering, class, flag and P&I problem before it is a routing debate. U.S. persons, and transactions that transit the United States, are prohibited from dealing in the property of the designated persons unless licensed or exempt. Foreign financial institutions that knowingly conduct or facilitate a significant transaction for a designated person risk correspondent-account secondary sanctions. The 50 percent rule blocks unnamed subsidiaries. A Panama brass plate, a Piraeus office and a Singapore or Dubai agency appointment do not remove the IMO from the filter.
Operators who still have the seven Roxette hulls on a voyage charter, a time charter, an STS program, a bunker stem, a class entry, a flag registration or a hull/P&I line should assume the fixture is now a blocked-property problem unless it fits HH. HH is a 20 November wind-down and safety valve, not a trading holiday. Cargo already afloat on those hulls is offloadable under HH only if it is not Iranian-origin, was loaded on or before 21 October, and is not going into Iran or Russia. New commercial contracts are out. Crew safety, emergency repairs and environmental mitigation are in. Amigoz appointments, Whales port calls and the two UAE support craft have no published GL on this action. Treat those names as blocked from Wednesday. Do not wait for a further OFAC FAQ before freezing new instructions.
Banks, traders and Greek, Panamanian, Singapore and UAE service providers who have used Karnakis as a corporate agent have a dated exit. 12:01 a.m. EST on 20 November is the end of the published Karnakis wind-down, not a holiday. Payments still have to hit a blocked account. A cargo already afloat on ANEMOS does not become clean because discharge is in Asia. A rename after 21 October does not become clean because the press release used “cargo vessels” rather than tankers. ZIXUAN remains the 8 October tanker; Amigoz is the new agent line against that existing IMO.
Do not brief Wednesday as a completed Iranian-export stop, a worldwide port ban, a Hormuz reopen, a Wright conversion licence, or a substitute for the 8 October 22-tanker screen. The confirmed facts are nine vessels, one law firm, two shipping agents, one operator, two numbered general licences to 20 November, and no published GL for Amigoz, Whales or the 8 October Treasury tankers.
What Operators Should Note
- Screen nine IMOs from 21 October, and keep the 8 October 22 on a separate filter. Roxette / GL HH annex: 9205952 ANEMOS, 9449510 GLORIS, 9487407 PRIDE, 9385491 DESTINY, 9474199 FLAMINGO 1, 9449522 HARMONY, 9548316 PRINCE. Whales, no HH annex: 9375032 WHALES DIAMOND, 9483114 WHALES PEARL. ZIXUAN 9317298 is already on the 8 October list; Wednesday adds the Amigoz agency line, not a second tanker designation. A renamed hull with one of those numbers is still in.
- Map E.O. 13902 and the 50 percent rule before you write a licence request. Wednesday’s Iran block is 13902, not State’s 13846 stack from 8 October. Secondary-sanctions risk on foreign banks attaches to significant transactions with designated persons. Unnamed entities owned 50 percent or more, individually or in aggregate, are blocked. Karnakis, Roxette, Amigoz, Whales and the five named individuals belong on the KYC screen even where a fixture never touches the nine hulls.
- Treat General License GG as a Karnakis clock, not a fleet holiday. Wind-down of transactions involving Karnakis and Karnakis, or any entity it owns 50 percent or more, through 12:01 a.m. EST 20 November 2026. Payments to blocked persons must go to a blocked account. GG does not authorise Roxette, Amigoz, Whales or any other blocked person unless separately licensed.
- Treat General License HH as a Roxette safety and offload valve through the same clock. Annex is the seven Panama cargo IMOs only. Authorised: financial wind-down; docking and departure excluding Iran/Russia; crew health and safety; emergency repairs and environmental mitigation; offload of non-Iranian-origin cargo loaded on or before 21 October, not at Iran/Russia ports. Note 1 covers management, crewing, bunkering, piloting, flag, class, insurance and salvage. No new commercial contracts. No Iranian-origin cargo. No published HH cover for the two Whales support craft.
- Do not confuse Wednesday with Wright, Samudra or Panama AMP. Wright’s 19 October remarks remain the dedicated case-by-case specific-licence piece; GG/HH are not that conversion checklist. General License EE for Samudra still ends 12:01 a.m. EDT 23 October and is not extended. AMP’s BITU / STARWAY / MACKEREL cancellations remain in process. HAKUNA MATATA and PINOCCHIO remain the 8 October delistings, not a clearance for this increment.
- Do not merge this list with Tokyo’s 35 IMOs, London’s eight named LNG hulls, or Thursday’s IMO 120-count. Japan’s resident-services permit and the UK specifications are separate filters. Soyia and Chloe on the IMO highlighted-incidents board are a kinetic naming, not an SDN action. Do not recast Wednesday as a Hormuz reopen, a completed Iranian-export stop, or a CENTCOM boarding.
Regulas Shipping will keep lining Wednesday’s nine IMOs and the 20 November GG/HH clocks against the 8 October 22-tanker screen and Wright’s case-by-case remarks so operators can treat this Outcast increment as a live SDN and payments file, not as a renamed-hull holiday or a dark-fleet conversion licence.
