OFAC ISSUES IRAN-RELATED AVIATION INDUSTRY ADVISORY
August 14, 2019
On July 23, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Iran-Related Civil Aviation Industry Advisory to emphasize to the civil aviation industry the risk of enforcement actions or economic sanctions for U.S. and non-U.S. companies doing business in Iran or with Iranian interests.
According to the advisory, the Iranian government routinely relies on certain commercial airlines to supply fighters and material to militias and the government of Syria in support of President Bashar al-Assad. The advisory highlighted Mahan Air, which was blacklisted by the U.S. in 2011, alleging that the airline has played a role in providing financial, material and technological support to the Islamic Revolutionary Guard. The U.S. designated the Islamic Revolutionary Guard Corps as a terrorist organization in April.
The advisory also warns of Iran’s “deceptive practices” with respect to the use of aviation entities to evade sanctions. These practices include but are not limited to the use of shell companies, pass-through entities and third-party suppliers. According to OFAC, Iran has also misrepresented the acquisition of licenses to business partners and sought to engage firms located in free trade zones that do not ordinarily deal in aviation goods.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com or 202-659-6622); Drew Derco (dderco@eckertseamans.com or 202-659-6665), or Alexander Matthews (amatthews@eckertseamans.com or 202-659-6633).
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