OFAC TARGETS U.S. MAINTENANCE PROVIDER FOR DEALING WITH MAHAN AIR, A SANCTIONED ENTITY

January 27, 2020

On December 12, 2019, the U.S. Department of the Treasury’s Office of Foreign Asset Control (OFAC) announced a Finding of Violation against Aero Sky Aircraft Maintenance, Inc. (“Aero Sky”), for allegedly violating the U.S.’s global terrorism sanctions.  Aero Sky has been dissolved in bankruptcy; but if it were still operating, OFAC stated that the company would be subject to a significant monetary penalty for its conduct.

Specifically, in 2016, Aero Sky entered into contracts for repair services with the Iranian carrier Mahan Air, despite the fact that the airline was a specially designated national (SDN) under U.S. sanctions regulations and listed on OFAC’s SDN list.  Aero Sky mistakenly believed that the transactions qualified for an exemption under an OFAC general license in effect at the time of the deal.  However, this was not the case.  OFAC stated that Aero Sky’s conduct showed reckless disregard of the law and failure to exercise a minimal degree of care in dealing with Mahan Air.

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).

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Authors

Evelyn D. Sahr Photo Washington, D.C.

Evelyn D. Sahr

Member - Washington, D.C.

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Drew M. Derco Photo Washington, D.C.

Drew M. Derco

Member - Washington, D.C.

See full bio