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By: Danielle Hatch

The US Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory reminding the civil aviation industry of potential exposure to US Government enforcement actions and sanctions involving Iranian airlines. Engaging in, or supporting unauthorized transfers of aircraft or related goods, technology, or services to Iran or any designated Iranian airline is prohibited by the current sanctions on Iran.

“The Iranian regime uses commercial airlines to further the destabilizing agenda of terror groups like the Islamic Revolutionary Guards Corps (IRGC) and its Qods Force (IRGC-QF), and to fly fighters from their proxy militias across the region.  The international civil aviation industry, including service providers like general sales agents, brokers, and title companies, need to be on high alert to ensure they are not complicit in Iran’s malign activities,” said Sigal Mandelker, Under Secretary of the Treasury for Terrorism and Financial Intelligence.

The advisory uses Mahan Air as an example of a company that is sanctioned. Since 2018 the US has imposed sanctions on 11 entities and individuals that have provided support to, acted on behalf of, and provided financial services to Mahan Air.

The advisory specifically lists the following as potentially sanctionable activities, when conducted for or on behalf of a designated person, to include:

  • Financial services
  • Reservations and ticketing
  • Freight booking and handling
  • Procurement of aircraft parts and equipment
  • Maintenance Airline ground services
  • Catering
  • Interline transfer and codeshare agreements
  • Refueling contracts

Full Advisory: