The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) says it has designated nine individuals and entities as Specially Designated Global Terrorists (SDGTs) for procuring export-controlled, US-origin goods for onward supply to sanctioned Iranian airlines.

“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 Airlines, Meraj Air, and Pouya Air Lines. In so doing, they extend a lifeline to the Islamic Revolutionary Guard Corps-Qods Force (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,” Treasury Secretary Steven T. Mnuchin said. “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.”

The US government claims the four carriers in general, and Mahan Air in particular, have played a critical role in supporting the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). It alleges that Mahan Air has ferried IRGC-QF operatives, weapons, equipment, and funds to international locations such as Syria (to assist the Assad regime) and Lebanon (to assist Hizbollah).

Among the individuals, OFAC has designated include Turkish citizen Gulnihal Yegane and a network of Istanbul-based firms, including Trigron Lojistik, RA Havacilik, and 3G Lojistik, for enabling Mahan Air to secure key aviation goods and services and sustain its fleet of Western-manufactured aircraft.

OFAC also designated two entities, Iran-based Blue Airways and Turkey-based Otik Aviation, again for their alleged ties with Mahan Air. Both are accused of procuring and providing Mahan Air with aircraft parts from abroad. Blue Airways, which is co-located with Mahan Air, is a Mahan Air-operated shell company with no aircraft or discernable assets. OFAC said that to disguise Mahan Air as the actual buyer and final recipient of prohibited US goods, Blue Airways is often listed on commercial documents in place of Mahan Air.

For its part, Otik Aviation is also accused of providing material support to Mahan Air, and of regularly supplying the Iranian airline with export-controlled, US-origin aircraft parts. OFAC claimed that 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 USD100,000 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.

OFAC also designated two Iranian individuals - Iraj Ronaghi and Touraj Zanganeh - for acting for or on behalf of Meraj Air, as well as one Iran-based company that is owned or controlled by these individuals and that acts for or on behalf of Meraj Air. Meraj Air was designated as an Iranian government airline that has been used to ferry cargo, including weapons, from Tehran to the Syrian regime since at least 2013.

Finally, Dena Airways (Tehran Mehrabad) has been designated for being owned or controlled by Ronaghi and Zanganeh, and for acting for or on behalf of Meraj Air. Meraj Air transferred VIP flight operations for the Government of Iran to Dena Airways in November 2017.

Also added to the embargo are a number of aircraft associated with Mahan Air, Caspian Airlines, Meraj Air, and Pouya Air. This, OFAC said, serves as a warning to those who grant landing rights and provide general services to these aircraft that they could be exposed to US sanctions.

The sanctioned aircraft include:

  • Meraj Air: A320-200s EP-AJC (msn 530), EP-AJH (msn 1353), and EP-AJI (msn 1300).

  • Caspian Air: B737-400s EP-CAP (msn 26466), EP-CAQ (msn 26467), and EP-CAR (msn 26451); MD-83s EP-CPU (msn 53223), EP-CAS (msn 53623), EP-CPD (msn 53188), EP-CPV (msn 49938), EP-CPX (msn 53463), and EP-CPZ (msn 53464).

  • Pouya Air: E145s ER-LDA (msn 145025) and EP-LDC (msn 145026)

  • Mahan Air: A340-300s EP-MMA (msn 20), EP-MMB (msn 56), and EP-MMC (msn 282); A310-300s EP-MMJ (msn 526), and EP-MNF (msn 547); ARJ-85s EP-MOP (msn E2257), EP-MOQ (msn E2261), EP-MOR (msn E2392), EP-MOS (msn E2347); BAe 146-200 EP-MMV (msn E2079); BAe 146-300s EP-MOD (msn E3162) and EP-MOM (msn 3165); An-74s EP-PUA (msn 3654701211055) and EP-PUM (msn 3654701211059) both linked to Pouya Air; Il-76 EP-PUL (msn 33448393) linked to Pouya Air; and A300-600s EP-SIF (msn 762) and EP-EP-SIG (msn 750) both linked to Meraj Air.

"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 Airlines, Meraj Air, and Pouya Air," OFAC warned. "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."