US targets Iranian aviation as it imposes fresh sanctions

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) yesterday designated nine individuals and entities procuring export-controlled US-origin goods for sanctioned Iranian airlines.

The Department imposed fresh sanctions on some Iranian and Turkish companies and individuals and a number of aircraft in a move aimed at four carriers targeting procurement networks and 31 aircraft associated with Mahan Air and other Iranian carriers.

Companies were said to provide support and have links to Mahan Air and Meraj Air, the department said in a statement, while it was also targeting a number of their aircraft, and aircraft from Caspian Airlines and Pouya Air.

The US said the carriers had transported weapons, fighters and money to proxies in Syria and Lebanon and also threatened sanctions against those granting landing rights and providing services to the aircraft.

US Treasury Secretary Steven Mnuchin said in a statement: “The facilitators designated by the Treasury today have been procuring parts and providing services for the fleets of sanctioned Iranian airlines, including Mahan Air, Caspian Air, Meraj Air, and Pouya Air.

“In so doing, they extend a lifeline to the IRGC-QF and enable the Iranian regime to transport weapons, fighters, and money to its proxies, including Hizballah, and to prop up the brutal Assad regime.

“Countries and companies around the world should take note of the risks associated with granting landing rights and providing aviation services to the airlines used by Iran to export terrorism throughout the region.

“The deceptive practices these airlines employ to illegally obtain services and US goods is yet another example of the duplicitous ways in which the Iranian regime has operated.”

Iranian carriers were already subjected to sanctions by the US. The new sanctions targeting Iran’s aviation industry are the latest in the US’ strategy to hit the country economically. It withdrew from 2015 nuclear accord earlier in May.

The Treasury also said in a document that Mahan Air in particular, has played a critical role in exporting the Iranian regime’s malign influence and has “ferried IRGC-QF operatives, weapons, equipment, and funds to international locations in furtherance of Iranian state-sponsored terror operations”.

The Treasury added: “Mahan Air has also transported weapons and personnel for Hizballah and regional armed groups promoting conflict and regional instability. Since the onset of the Syrian civil war, Mahan Air and designated Iranian commercial airlines have routinely flown fighters and materiel to Syria to prop up the Assad regime. Iran’s military support for Assad has contributed to mass atrocities in the country and the displacement of millions across the region.

“Designated Iranian airlines rely heavily on front companies across the world who illicitly procure the parts and services required to sustain their fleets. Front companies like those being designated today employ deceptive measures to illegally obtain controlled US parts from suppliers.

“Additionally, we are identifying a number of aircraft associated with designated Iranian airlines Mahan Air, Caspian Air, Meraj Air, and Pouya Air, giving notice to those who grant landing rights and provide general services to these aircraft that they could be exposed to US sanctions.

“The aviation community is also alerted to the sanctions risk for those maintaining commercial relationships with Mahan Air and other designated Iranian airlines, including Caspian Air, Meraj Air, and Pouya Air. Persons operating in the civil aviation industry should implement appropriate controls to ensure compliance with their legal requirements.

“Potentially sanctionable activities include, but are not limited to: procurement of aircraft parts and equipment, maintenance contracts, airline ground services and catering, interline transfer and codeshare agreements, general sales agent services, ticketing services and sales, marketing services, cargo cooperation agreements, cargo sales agent services and agreements, and freight forwarding services and agreements.

“Today’s actions are the result of a US Government-wide effort to prevent the procurement of U.S.-export controlled goods by designated Iranian airlines through individuals and entities in third countries, demonstrating the United States’ commitment to enforcing existing sanctions and to targeting those that support terrorism.”

Turkey-based procuremnt network

The Treasury has also targeted a Turkey-based procurement network and said it is designating Turkish citizen Gulnihal Yegane and a network of Istanbul-based firms, including Trigron Lojistik, RA Havacilik, and 3G Lojistik, for “enabling designated Iranian airline Mahan Air to secure key aviation goods and services and sustain its fleet of Western-manufactured aircraft”.

The Treasury said: “Trigron Lojistik is being designated pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Mahan Air, as well as for being owned or controlled by Gulnihal Yegane.

“Trigron Lojistik collects consignments of aviation parts, including export-controlled, U.S.­origin items that are shipped from foreign vendors to companies in Istanbul, and forwards those cargoes to Mahan Air in Tehran.

“OFAC also is designating 3G Lojistik and RA Havacilik pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Mahan Air. Both 3G Lojistik and RA Havacilik purchase aviation parts, including export-controlled, US-origin parts, from foreign vendors on behalf of Mahan Air, which are then delivered to Istanbul and forwarded to Tehran by Trigron Lojistik.

“As a result of today’s actions, Gulnihal Yegane, Trigron Lojistik, 3G Lojistik, and RA Havacilik are subject to secondary sanctions pursuant to the Iranian Financial Sanctions Regulations (IFSR), which implement, among other authorities, the Comprehensive Iran Sanctions and Divestment Act of 2010 (CISADA).”

Blue Airways and Otik Aviation

OFAC is also designating two entities, Iran-based Blue Airways and Istanbul-based Otik Aviation, in connection with Mahan Air.

Blue Airways is being designated for providing material support to, and for acting for or on behalf of, Mahan Air, primarily through the procurement and provision of aircraft parts from abroad.

The Treasury said Blue Airways, which is co-located with Mahan Air, is a Mahan Air-operated shell company with no aircraft or discernable assets, adding: “To disguise Mahan Air as the actual buyer and final recipient of prohibited US goods, Blue Airways often is listed on commercial documents in place of Mahan Air. This tactic is used by Mahan Air to procure goods from neighboring countries, China and Europe.”

Otik Aviation is being designated by the Treasury for providing material support to Mahan Air, and regularly supplying the Iranian airline with export-controlled, US-origin aircraft parts.

The Treasury said: “Over the last several years, Otik Aviation has procured and delivered millions of dollars in aviation-related spare and replacement parts for Mahan Air, some of which are procured from the United States and the European Union.

“As recently as 2017, Otik Aviation continued to provide Mahan Air with replacement parts worth well over $100,000 per shipment, such as aircraft brakes. Representatives of Otik Aviation wittingly ship the aviation-related goods that they procure for Mahan Air to Blue Airways.

“As a result of today’s actions, Blue Airways and Otik Aviation are subject to secondary sanctions pursuant to the IFSR.”