Compliance Brief - October 28, 2026 - Global RADAR
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Compliance Brief – October 28, 2026

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Edition 22 · Wednesday, October 28, 2026

What’s new in compliance. Why it matters. What it means for your operations.

In This Edition

Treasury Sanctions a Law Firm for Building Iran’s Shadow Fleet

From the Founder
Treasury just sanctioned a law firm for setting up shell companies, and FinCEN used a new subpoena power on a bank. Enforcement now reaches the lawyers who build the structure and the banks that hold the accounts. Compliance officers, ask your board and general counsel whether onboarding checks the corporate agent behind a customer.
Dominic Suszek · Founder and CEO, Global RADAR
30-Second Read
  • Treasury sanctions law firm Karnakis and Karnakis for building Iran shadow fleet shell companies
  • FinCEN issues its first section 5318(k) subpoena, in a Greek bank probe
  • FATF plenary runs October 28 to 30; Lukoil license now runs to November 21

1. Top story of the week

Treasury sanctions a law firm for building Iran’s shadow fleet. On October 21, OFAC designated Panama- and Greece-based Karnakis and Karnakis, its two owners and three employees. Treasury says the firm registered the companies that own shadow fleet vessels and that its staff served as directors, hiding the true owners. OFAC also blocked nine vessels and two shipping agents. FinCEN separately used its first Bank Secrecy Act section 5318(k) subpoena in a probe of a Greek bank.

Why This Matters

Designating a law firm puts corporate service providers on notice: building the structure is now sanctionable conduct. FinCEN’s subpoena shows regulators are also following the accounts behind those structures.

Operational Implications

Three steps by November 4:

  1. Screen Karnakis and Karnakis, its five designated people, Roxette, Amigoz and Whales against customer, vendor and payee files, and document results for your sanctions committee.
  2. Add registered agent and formation provider names to onboarding screening for shipping and trading customers; I expect that to become a standard data field.
  3. Brief relationship managers on the November 20 wind-down date before any exposure is closed out.

2. Enforcement and penalties

  • OFAC, October 21: Designated Karnakis and Karnakis, Roxette Maritime, and shipping agents Amigoz and Whales under E.O. 13902; nine vessels blocked.
  • FinCEN, October 21: Issued its first section 5318(k) subpoena in an investigation of an unnamed Greek bank’s potential Iran ties.
  • FinCEN, October 19: Identified about $270 million in suspicious activity tied to federal student aid fraud and referred it to authorities.
Why This Matters

Both actions follow the money upstream: from vessels to the lawyers behind their owners, and from payments to the banks holding the accounts. Penalty risk now attaches to intermediaries.

Operational Implications

Three steps by November 6:

  1. Pull correspondent and shipping finance exposure to Greek and Panamanian counterparties and document enhanced due diligence for your compliance committee.
  2. Name an owner for 5318(k) subpoena and information request responses in your regulatory inquiry procedure; building that after a request arrives is too late.
  3. Add the Karnakis fact pattern, officers who act as directors for many companies, to your investigator training.

3. New guidance and rulemaking

  • November 21: OFAC General License 131K replaces 131J, extending Lukoil International GmbH sale-contract and wind-down authority.
  • November 20: General Licenses GG and HH end wind-down dealings with Karnakis and Karnakis and Roxette.
  • October 26: OFAC issued amended FAQs on blocking and rejecting transactions and filing reports with OFAC.
  • October 21: OFAC delisted Belarus’s Andrei Rybakov and North Korea program targets Lu Hezheng and two China-based studios.
Why This Matters

Wind-down dates and amended FAQs change what you must block, reject and report. Missing a license expiry turns a permitted payment into a violation overnight.

Operational Implications

Three steps by November 13:

  1. Diary the November 20 and 21 license expiries in your sanctions case system and assign an owner to each open exposure.
  2. Compare OFAC’s amended blocking and reporting FAQs against your report templates, and update any citing superseded language.
  3. Re-run customer files against the October 21 delistings; clearing stale matches cuts false positives, and I would do it weekly.
Theme of the Week
Treasury sanctioned the lawyers who set up three shipping companies it had already listed, and FinCEN reached for its first 5318(k) subpoena. Enforcement is moving up the chain, from vessel to registered agent to bank. Screening that stops at the vessel owner or listed director, without checking the corporate agent behind it, is structurally behind.

4. Global watch

  • EU, October 21: Russian energy sanctions stay until the war ends; 22nd package in preparation.
  • AMLA, November 3: Public hearing on draft standards for a central EU AML/CFT database.
  • Australia, October: Sanctioned two North Korean companies and two individuals over fraudulent IT worker schemes.
  • China, October: Commerce Ministry opposed US PAIPA sanctions and threatened countermeasures.

5. Coming up in the next 30 days

Date Event or deadline
October 28 to 30, 2026 FATF plenary under UK presidency; watch grey list outcomes.
October 30, 2026 OFAC General License FF wind-down for Iraq-based IDB ends at 12:01 a.m. EDT.
November 3, 2026 AMLA public hearing on central AML/CFT database standards, 14:00 to 16:00 CET.
About November 12, 2026 Bank of America’s 30-day deadline to propose its monitoring consultant to FinCEN.
November 14, 2026 Wind-down activity for Cuba’s BICSA ends under OFAC FAQ 1276.
November 15, 2026 Comments due on China’s proposed export restrictions on 40 technologies.
November 20, 2026 Wind-down ends for Karnakis and Karnakis and Roxette under General Licenses GG and HH.
November 21, 2026 OFAC General License 131K for Lukoil International GmbH expires.

Next Wednesday

Next Wednesday: FATF plenary outcomes, the November 3 AMLA hearing, and what the November 20 and 21 license expiries mean for your payments.

Want a 30-minute review of the Karnakis designation against your current screening of shipping and corporate-structure customers? Book a call with a Global RADAR compliance specialist.

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Best regards,
Dominic Suszek
Founder and CEO, Global RADAR
globalradar.com