OFAC TIGHTENS SANCTIONS ON IRANIAN AVIATION SECTOR
October 8, 2026
Eckert Seamans has prepared the information in this update for educational purposes only. It does not constitute legal advice nor substitute for legal advice. Neither your receipt of information from this website nor your use of this website to contact Eckert Seamans or one of its attorneys creates an attorney-client relationship, as the firm may, for example, already represent another party involved in your matter. Accordingly, you should not provide confidential information to Eckert Seamans. Persons seeking legal advice should consult a licensed professional attorney in their state. The firm’s Terms of Use, Legal Notice, and Disclaimer detailed herein are expressly incorporated into the Aviation Regulatory Update.
On September 8, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) indefinitely suspended General License J-1, which had permitted certain non-Iranian air carriers to operate temporary sojourns (“TS”) to Iran subject to specified conditions. A TS is a limited authorization allowing an otherwise restricted aircraft to enter Iran temporarily and depart within a specified period. The authorization was particularly significant for foreign airlines operating aircraft containing substantial U.S.-controlled content, including many Boeing and Airbus aircraft. With the suspension of J-1, foreign air carriers can no longer rely on the TS authorization to operate qualifying aircraft to Iran, significantly constraining international commercial air service to the country.
OFAC also suspended other aviation-related authorizations, including a prior authorization permitting certain payments associated with overflights of Iranian airspace or emergency landings in Iran. Separately, OFAC sanctioned 27 Iranian air carriers (the list of carriers can be found here) for supporting Iran’s aviation sector, including through activities involving sanctioned entities such as Mahan Air. The sanctions further isolate these carriers from the international aviation industry and prohibit U.S. persons from transacting with them. Non-U.S. persons and entities should also exercise heightened caution when conducting aircraft transfers, performing cargo services, or providing air transportation because transactions involving sanctioned entities in Iran’s aviation sector may create secondary sanctions risks. As the international aviation industry works to comply with the latest sanctions activity targeting Iran, OFAC has issued a temporary license allowing the wind-down of certain previously authorized transactions through September 23, 2026. Recent OFAC sanctions activity will significantly increase scrutiny of aviation stakeholders. Accordingly, U.S. and non-U.S. persons should closely evaluate any activity with a potential Iranian nexus, including route networks, codeshare agreements, aircraft transfers, and cargo arrangements. To further strengthen compliance, the Financial Crimes Enforcement Network has issued an alert identifying red flags that the commercial aviation industry should consider in light of recent Iranian efforts to procure aircraft parts in violation of U.S. sanctions.
This Aviation Regulatory Update is intended to keep readers current on developments in the law. It is not intended to be legal advice. If you have any questions or require additional information, please contact Evelyn D. Sahr at 202.659.6622 or esahr@eckertseamans.com; Drew M. Derco at 202.659.6665 or dderco@eckertseamans.com; Xander B. Silva at 412.566.6069 or xsilva@eckertseamans.com, Tyler R. Myers at 202.659.6642 or trmyers@eckertseamans.com; or any other attorney at Eckert Seamans with whom you have been working.
Share This Post
Authors
