Iran’s shadow-fleet lawyers, six curbed UK lenders and SPK’s Tera case

The FinCrime Wire
Weekly Wire No. 3 · 19–25 October 2026
By the FinCrime Wire Reporting Desk
Sources checked 25 October 2026 · 7 minute read

Editor’s note. This full-week edition replaces the early version of No. 3 published on 20 October. The week’s thread is the gatekeeper: a law firm that registered ships, lenders whose controls did not satisfy their supervisor, and brokerage houses named in a market-abuse case. Next week belongs to the FATF in Paris.

The week in 60 seconds

Treasury targets Iran’s shadow-fleet lawyers. OFAC designated a Panama and Greece law firm, five individuals, three companies and nine vessels, and FinCEN used a new subpoena power on a Greek bank (21 October).
FCA curbs six UK lenders over AML controls. Six lenders registered only for money laundering supervision accepted limits on new business (23 October).
SPK files complaints against 48 people. Türkiye’s capital markets board referred trading in two shares to prosecutors and banned Tera group firms from trading them (22 October).
FATF sets its plenary agenda. The Paris plenary on 28–30 October will discuss the US and Mexico evaluations and the grey list (20 October).

Number of the week

1,462

Arrests in INTERPOL’s Operation Serengeti III against cyber-enabled fraud in 21 African countries (announced 22 October).

Top stories

Treasury targets the law firm behind Iran’s shadow-fleet companies (21 October)

What happened. OFAC designated Karnakis and Karnakis, a law firm based in Panama and Greece, under Executive Order 13902. It also designated five individuals, Roxette Maritime Shipping and Trading S.A., Amigoz Singapore Pte. Ltd. and Dubai-based Whales Shipping Line LLC, and identified nine vessels as blocked property. Treasury says the firm registered shipping companies whose vessels carried Iranian steel, petroleum and petrochemicals, and that its employees acted as directors, hiding the true owners. FinCEN, working with European partners including Greece, issued its first administrative subpoena under 31 U.S.C. § 5318(k) in an investigation of a Greek bank’s potential ties to Iran.

Why it matters. The target is a gatekeeper, not a tanker owner. Banks, ship registries, port agents and marine insurers in Europe, Singapore, the UAE and Panama are exposed, as are correspondent banks clearing dollar payments for shipping clients. Section 5318(k) lets FinCEN demand records from a foreign bank that holds a US correspondent account.

What to do. Screen the nine vessels by IMO number and the nine designated persons across shipping, trade-finance and correspondent files. Flag ship-owning customers whose directors work for the same law firm or corporate agent.

Our read. Using the correspondent-account subpoena on a European bank suggests FinCEN will follow Iran-linked flows into allied banking systems, not only Asian and Gulf ones.

FCA restricts six UK lenders over money laundering controls (23 October)

What happened. The FCA said six Annex 1 lenders accepted restrictions on their business: Kingscrown Finance Ltd, MOMSB Ltd, Momentus Capital Ltd, Grosvenor Funding Ltd, Grosvenor Funding (North West) Ltd and Abbital Ltd. The restrictions were imposed between 21 April and 15 October 2026 at each firm’s request. Five firms must commission an independent review of their AML framework, and Kingscrown must wind down its loan book in an orderly way. The FCA has sent an information request to around 900 registered Annex 1 firms.

Why it matters. Annex 1 firms are unregulated lenders that register with the FCA only for money laundering supervision, so AML supervision is the main lever over them. Banks that provide accounts or funding lines to such lenders share the risk.

What to do. Identify Annex 1 lenders among your customers and counterparties. Ask whether they received the FCA’s request and how they answered.

Our read. With about 900 firms questioned, we expect more restrictions to follow.

Türkiye’s SPK refers two share cases to prosecutors and bans Tera group firms (22 October)

What happened. In Bulletin 2026/73 the Capital Markets Board (SPK) filed criminal complaints over trading in Altınkılıç Gıda (ALKLC) and Anel Elektrik (ANELE) shares: 8 people for ALKLC and 48 for ANELE, with all eight also named in the ANELE case. It imposed two-year trading bans in those shares on the individuals and on Tera Portföy Yönetimi, Tera Yatırım Menkul Değerler, Tera Yatırım Bankası, Tera Yatırım Holding and Century City Securities. For the first three firms the ban covers own-account trading only. The licences of 5 people (ALKLC) and 28 (ANELE) are cancelled for the length of the ban. Those referred can settle under the effective repentance route by paying twice the benefit obtained, at least TRY 500,000, within 15 days.

Why it matters. A criminal complaint is an allegation; no court has ruled. Even so, a regulator naming a bank and a brokerage in a market-abuse case is a customer-risk trigger for banks, brokers and custodians in Türkiye and for their foreign counterparties. Two days earlier the SPK suspended three other brokers, Alnus Yatırım, Bulls Yatırım and Pusula Yatırım Menkul Değerler, from 21 October without stating the facts.

What to do. Refresh risk ratings for the named firms and their counterparties. Review client positions and trading in ALKLC and ANELE shares.

FATF Week opens in Paris on Monday (published 20 October)

What happened. The FATF said FATF Week begins on 26 October and the plenary runs from 28 to 30 October 2026, the first under the UK presidency of Giles Thomson. Delegates expect to discuss the US and Mexico mutual evaluations, review jurisdictions under increased monitoring (the grey list) and continue the fraud roadmap. Barbados, Namibia and Thailand attend for the first time as guests. Outcomes follow at a virtual press conference on 30 October at 17:00 Paris time.

Why it matters. Grey-list changes feed enhanced due diligence and correspondent decisions in every region. A US evaluation will also be read closely by banks with dollar exposure.

What to do. Set aside time on 30–31 October to update country risk ratings. Check current listings on our FATF grey list tracker.

Correction (25 October 2026): our early edition gave the plenary dates as 26–30 October. FATF Week starts on 26 October; the plenary itself runs from 28 to 30 October.

Around the world

Global bodies

Basel Committee shares AML/CFT supervisory findings. Its newsletter summarises a stocktake of AML/CFT data and risk-assessment methods across 19 jurisdictions and a workshop on AI and machine learning in transaction monitoring (19 October).

Americas

OFAC’s first PAIPA listings. OFAC added five entities linked to MiraclePlus and Shanghai Zhisuan Technology to its Non-SDN Menu-Based Sanctions List under the Protecting American Intellectual Property Act, with a wind-down licence to 19 January 2027 (19 October).
Student aid fraud. Treasury said FinCEN data showed about $270 million in suspicious activity linked to federal student aid fraud, across more than 20,000 transactions since February 2026 (19 October).
EminiFX orders. In a CFTC case, a New York federal court ordered Eddy Alexandre and EminiFX Inc. to pay $228,576,962 in restitution and a $45,148,500 civil penalty over a crypto and forex Ponzi scheme (19 October).
Crypto-scam extradition. The DOJ said Chinese national Zheng Zhao was extradited from the Netherlands, charged with conspiracy to launder more than $36.9 million in crypto-scam proceeds sent to one Deltec Bank account in the Bahamas. He is presumed innocent (23 October).
FINTRAC’s year. FINTRAC reported 35 notices of violation and more than C$247 million in penalties for 2025–26, over C$198 million of it against nine money services businesses (22 October).

Europe and UK

Coinbase Ireland fined. The Central Bank of Ireland fined Coinbase Ireland Limited €3,252,618 for e-money safeguarding and outsourcing breaches from November 2020 to August 2025. The firm admitted the breaches; the sanction needs High Court confirmation (22 October).
Swiss Bitcoin ETF. FINMA approved Switzerland’s first Bitcoin ETF and warned that Bitcoin investments “remain highly risky” (20 October).

Sub-Saharan Africa

Operation Serengeti III. INTERPOL’s operation (29 June–31 August) led to 1,462 arrests across 21 countries and recovered more than USD 105 million. Linked losses exceed USD 385 million; Angola shut two illegal crypto-mining centres (22 October).

Rotating spotlight: Southeast Asia

Deepfake warning from Singapore. INTERPOL launched its deepfake-scam awareness campaign, “Wait. Validate. Don’t take the bait.”, from Singapore (19 October). Singapore-based port agency Amigoz Singapore was among this week’s Iran designations.

Regional spotlight

Pakistan. No new AML/CFT item from the SBP, FMU or PVARA: SBP press releases show nothing after 17 October, and the FMU’s latest circular is dated 28 July. The SBP issued two prudential circular letters on banks’ equity investments (No. 22 and No. 21, 23 October), and the SECP opened a cybersecurity operations centre (20 October). See our Pakistan guide.

Gulf. Dubai-based Whales Shipping Line and two UAE-flagged support vessels were among Treasury’s Iran designations. Nothing new confirmed from the DFSA, VARA, the UAE Capital Market Authority or Saudi Arabia’s CMA. We could not check the CBUAE, UAE FIU, SAMA, SAFIU, QCB or CBB this week, so we do not say they issued nothing. See our UAE guide.

Türkiye. The SPK actions above are the week’s main item. The SPK also fined HSBC Yatırım Menkul Değerler TRY 354,803.96 over checks on time-barred cash and securities (20 October). MASAK has posted nothing new since 16 October. See our Türkiye guide.

Red flag of the week

The same staff appear as directors of many ship-owning companies. Treasury says employees of the sanctioned law firm acted as directors and officers of companies it registered, hiding their true owners. In practice, look for vessel owners whose directors are lawyers or agents of one corporate service provider and share an address with many other shipowners. Learn more in Sanctions Compliance in Practice.

What we couldn’t confirm

The Basel Committee said on 1 October that a summary of its AML/CFT survey would follow “later this month”. Its 19 October newsletter summarises a stocktake across 19 jurisdictions, but we could not confirm that this is the promised summary.
GAFILAT has published its first regional risk assessment on proliferation financing, but its page shows no date, so we could not confirm it falls in this week.

Dates to watch

26 OctFATF Week begins, Paris.
28–30 OctFATF plenary, Paris; press conference 30 October, 17:00 Paris time. See our FATF grey list tracker.
16–20 NovEAG working groups and plenary (FATF calendar).
22–26 NovMENAFATF working groups and plenary (to be confirmed).
22–27 NovGIABA plenary and ministerial committee.
8–11 DecMONEYVAL plenary, Strasbourg.
19 Jan 2027PAIPA General Licence 2 wind-down ends.

Your Monday checklist

Screen: the nine vessels by IMO number and the nine persons designated on 21 October.
Map: ship-owning customers to their corporate agents and nominee directors.
Ask: list Annex 1 lenders among your UK customers and ask about the FCA’s information request.
Re-rate: review risk ratings for the Tera group firms and the three suspended Turkish brokers.
Plan: book time on 30–31 October to apply the FATF plenary outcomes.

Quick quiz

For reflection only · No grade or course credit.

What did FinCEN use for the first time on 21 October?
1. A section 311 special measure
2. An administrative subpoena under 31 U.S.C. § 5318(k)
3. A geographic targeting order
4. A section 9714 order
How many arrests did Operation Serengeti III produce?
1. 365
2. 900
3. 1,462
4. 10,909
Trading in which two shares led to the SPK’s criminal complaints?
1. ALKLC and ANELE
2. Tera Yatırım and Century City
3. Alnus and Bulls
4. HSBC Yatırım and Pusula

Show answers

1. B. FinCEN issued its first administrative subpoena under 31 U.S.C. § 5318(k), aimed at a Greek bank with a US correspondent account. 2. C. INTERPOL reported 1,462 arrests across 21 African countries. 3. A. The complaints concern trading in Altınkılıç Gıda (ALKLC) and Anel Elektrik (ANELE) shares; the Tera firms were banned from trading them.

For the specialists: identifiers and legal bases

Iran, 21 October (E.O. 13902). Vessels: ANEMOS (IMO 9205952), GLORIS (9449510), PRIDE (9487407), DESTINY (9385491), FLAMINGO 1 (9474199), HARMONY (9449522), PRINCE (9548316), all Panama-flagged; WHALES DIAMOND (9375032) and WHALES PEARL (9483114), UAE-flagged. Individuals: Sofianos, Konstantinos and Ioanis Karnakis Kosmas; Pedro and Roberto Ortega Jones (OFAC).
Same OFAC action. Iran General Licences GG (wind-down with Karnakis and Karnakis) and HH (wind-down, safety and offloading of cargo); Russia-related GL 131K (Lukoil International GmbH sale contracts); FAQs 1224 and 1225 amended. Removed: three DPRK3 entries linked to SEK Studio and one Belarus entry (Andrei Rybakov).
PAIPA, 19 October. Entities: Qiji Chuangtan Beijing Investment Management Co Ltd (MiraclePlus), Miracle Plus RMB Funds I and II, Beijing Qiji Chuangtan Zhiyuan Enterprise Management Center LP, Shanghai Zhisuan Technology Co Ltd. General Licence 2 covers the four MiraclePlus entities, not Shanghai Zhisuan (OFAC).
SPK legal bases. Complaints under Law 6362 Art. 107/1; effective repentance Art. 107/3; trading bans Art. 101/1 and Communiqué V-101.1 Arts. 5/2 and 6/2; licence cancellations Art. 17/1 (Bulletin 2026/73).
FCA restriction dates. Kingscrown 21 April and 25 September; MOMSB and Momentus 7 October; Grosvenor Funding and Grosvenor Funding (North West) 9 October; Abbital 15 October (FCA).

Sources

Compiled from official and public sources by the FinCrime Wire Reporting Desk. This brief is general information, not legal advice. Last updated 25 October 2026.