On October 21, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) added Karnakis and Karnakis, Roxette Maritime Shipping and Trading S.A., Whales Shipping Line LLC and nine vessels to the Specially Designated Nationals and Blocked Persons List under Executive Order 13902, and issued Iran General License GG, Iran General License HH and Russia-related General License 131K. See the OFAC recent action of October 21, 2026.
US banks and USD correspondent banks, shipowners, charterers and P&I clubs of bulk and general-cargo vessels, commodity traders of petrochemicals and steel with an Iran nexus, buyers and advisers on a sale of Lukoil International GmbH, and marine insurers, classification societies and port agents of the named vessels must immediately block the October 21, 2026 SDN names and vessels and reject new dealings with them. Any Karnakis wind-down, and any safety or cargo offload of the vessels covered by Iran General License HH, must stay inside those licenses through 12:01 a.m. eastern standard time on November 20, 2026. Talks on Lukoil International GmbH must stay inside contingent contracts and maintenance under Russia-related General License 131K through 12:01 a.m. eastern standard time on November 21, 2026. Otherwise, property of the designated persons is blocked, US persons must reject dealings with them, IEEPA civil penalties attach on a strict-liability basis, and a foreign financial institution that clears a prohibited transaction risks secondary sanctions.
Who did OFAC add to the SDN List on October 21, 2026?
OFAC designated five individuals linked to Karnakis and Karnakis (Ioanis, Konstantinos and Sofianos Karnakis Kosmas, and Pedro and Roberto Ortega Jones) and four entities under IRAN-EO13902: Karnakis and Karnakis, Roxette Maritime Shipping and Trading S.A. (IMO company number 6385886), Whales Shipping Line LLC (Arabic name وايلس شيبينغ لاين ذ م م, IMO company number 6417176) and Amigoz Singapore Pte. Ltd., plus the nine vessels below.
The same release removed the DPRK3 entries for Shanghai Moxing Cultural Media Co Ltd, Shanghai Hongman Animation Design Studio and Lu Hezheng, and the Belarus entries for Andrei Alekseevich Rybakov.
| Vessel | Type and flag | IMO | Linked to | In GL HH annex |
|---|---|---|---|---|
| ANEMOS | General cargo, Panama | 9205952 | Roxette Maritime | Yes |
| DESTINY | General cargo, Panama | 9385491 | Roxette Maritime | Yes |
| FLAMINGO 1 | Bulk carrier, Panama | 9474199 | Roxette Maritime | Yes |
| GLORIS | Bulk carrier, Panama | 9449510 | Roxette Maritime | Yes |
| HARMONY | General cargo, Panama | 9449522 | Roxette Maritime | Yes |
| PRIDE | Bulk carrier, Panama | 9487407 | Roxette Maritime | Yes |
| PRINCE | Bulk carrier, Panama | 9548316 | Roxette Maritime | Yes |
| WHALES DIAMOND | Crew and supply, UAE | 9375032 | Whales Shipping Line LLC | No |
| WHALES PEARL | Crew and supply, UAE | 9483114 | Whales Shipping Line LLC | No |
What may continue under Iran General License GG and General License HH?
Iran General License GG, dated October 21, 2026, authorizes transactions prohibited by the Iranian Transactions and Sanctions Regulations, 31 CFR part 560, that are ordinarily incident and necessary to wind down any transaction involving Karnakis and Karnakis, or any entity it owns at 50 percent or more, through 12:01 a.m. eastern standard time on November 20, 2026. Any payment to a blocked person must go into a blocked account. The license does not cover other persons blocked under the ITSR.
Iran General License HH uses the same cutoff, but only for Roxette Maritime and the seven Panama-flag vessels in its annex, plus entities they own at 50 percent or more. It covers a financial wind-down, docking outside Iran and the Russian Federation, crew safety, emergency repairs, and offload of non-Iranian cargo loaded on or before October 21, 2026. Note 1 includes insurance and classification. Whales Diamond and Whales Pearl are not in the annex.
What does Russia-related General License 131K allow for Lukoil International GmbH?
Russia-related General License 131K, effective October 21, 2026, replaces General License 131J of September 18, 2026. Through 12:01 a.m. eastern standard time on November 21, 2026, it authorizes E.O. 14024 transactions to negotiate contingent contracts with Lukoil or its affiliates for a sale of Lukoil International GmbH, or an entity it owns at 50 percent or more. Performance must wait for a separate OFAC authorization. The same window covers maintenance of those entities. Funds may not move to a person or account in the Russian Federation.
What follows if a dealing falls outside those licenses?
An SDN's property is blocked, and a US person may not deal in it outside a license. IEEPA civil penalties, 50 U.S.C. 1701 to 1706, attach without proof of intent. A foreign financial institution that clears a prohibited payment faces secondary-sanctions risk. Add the October 21, 2026 names and nine IMO numbers, apply the 50 percent rule to Karnakis and Karnakis and to Roxette Maritime, and delete only the Belarus and North Korea entries the release removed.
Obsidian monitors OFAC recent actions and general licenses per jurisdiction as they publish, so a sanctions desk sees a new SDN batch and its wind-down window together.
Match each counterparty and vessel to the October 21, 2026 SDN additions before the next payment or fixture. Keep a Karnakis wind-down inside General License GG, and a Roxette safety or cargo offload inside General License HH, through 12:01 a.m. eastern standard time on November 20, 2026, and Lukoil International GmbH talks inside contingent contracts under General License 131K through 12:01 a.m. eastern standard time on November 21, 2026. Brief screening and chartering on the two cutoff hours.
