The Department of Commerce’s Bureau of Industry and Security (BIS) and the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against several persons and entities determined to be supporting Iran’s Mahan Air in violation of U.S. sanctions toward Iran. According to both agencies, the involved companies have provided key parts and logistics services for Mahan Air, which was first sanctioned in March 2008 for providing support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and has subsequently been found to provide transportation for other illicit purposes.

OFAC Designations

On August 19, 2020, OFAC designated UAE-based Parthia Cargo and Delta Parts Supply FZC for their “material support” of Mahan Air, while also designating Iranian national Amin Mahdavi for owning or controlling Parthia Cargo. According to an OFAC press release, “[t]he services provided by Parthia Cargo and Delta Parts Supply FZC help Mahan Air sustain its fleet of western-manufactured aircraft and allow it to support the Iranian regime’s destabilizing agenda through activities that include the transportation of terrorists and lethal cargo to Syria to prop up the murderous Assad regime, as well as the more recent transportation of Iranian technicians and technical equipment to Venezuela to support the illegitimate Maduro regime’s efforts to revive energy production ruined by corruption and mismanagement.”

As a result of this action, these entities and have been placed on OFAC’s Specially Designated Nationals (SDN) List and all property and interests in property of these entities/person that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. Further, any foreign financial institution that knowingly facilitates a significant financial transaction or provides significant financial services for these persons could be subject to U.S. correspondent account sanctions or payable-through account sanctions.

BIS Temporary Denial Order

On August 21, 2020, BIS issued a Temporary Denial Order (TDO) against six parties in Indonesia for operating an international procurement network of aircraft parts suppliers and repair facilities to acquire and repair U.S.-origin goods for Mahan Air. Named in the TDO are: (1) Sunarko Kuntjoro, (2) Satrio Wihargo Sasmito, (3) Triadi Senna Kuntjoro, (4) PT MS Aero Support, (5) PT Antasena Kreasi, and (6) PT Kandiyasa Energi Utama. BIS has determined that each has been involved “in operating an international procurement scheme to illegally obtain and repair U.S.-origin aircraft parts on behalf of Mahan Air and Mustafa Oveici (Oveici), an Iranian executive for Mahan Air.”

Under the TDO, each person and entity has been denied export privileges to prevent an imminent or ongoing export control violation. The TDOs are issued for a renewable 180-day period and prohibit persons from exporting or reexporting any item subject to the Export Administration Regulations (EAR) to or on behalf of the denied person. It also prohibits the denied person from themselves dealing in items subject to the EAR, and prohibits the denied persons from negotiating, storing, forwarding, or engaging in other dealings related to items subject to the EAR.