The Mother of All TDO’s: Mahan Airways


The saga of export enforcement actions against Iran’s first private airline continues with the May 5 renewal of the temporary denial order (TDO) against Mahan Airways and associated persons first issued in March 2008.    

  • The Commerce Department’s Office of Export Enforcements April 2023 renewal request outlines open source evidence showing Mahan continues to operate sanctioned aircraft on flights into and out of Iran from/to Guangzhou, China, Kabul, Afghanistan, and Moscow, Russia, respectively, without the requisite authorization.
  • Additionally, national security and foreign policy concerns are raised by open source reports regarding Mahan’s intention to start direct flights from Iran to Minsk, Belarus, which reportedly began on April 18, 2023.
  • Lastly, publicly available information shows that Russian airline Aeroflot, which is currently subject to its own TDO, has begun sending its aircraft to Mahan for repairs and/or maintenance.

BIS has repeatedly updated sanctions against Mahan Air and related persons for a pattern of export violations that began fourteen years ago

The May 13, 2022 renewal order also cited OFAC’s administrative enforcement action Australian freight forwarder Toll Group, resulting in a $6,131,855 civil penalty, which revolved, in part, around 327 payments from Mahan that were processed through US Banks.

The November 8, 2022 order detailed Mahan Air’s continued violation of the TDO and Regulations, including the Russia-related export controls set out in section 746.8 of the Regulations. On September 19, 2022, BIS publicly identified one of Mahan’s aircraft for its unlicensed reexport to Russia in apparent violation of section 746.8 of the Regulations Additionally, open source evidence showed that Mahan continues to operate other sanctioned aircraft on flights into and out of Iran from/to Moscow, Russia, and Dubai, United Arab Emirates, respectively, without the requisite authorization

BIS took a related enforcement action against Venezuela- based cargo airline Empresa de Transporte Aéreocargo del Sur, S.A, a/k/a EMTRASUR for acquiring custody and/or control from Mahan Air of a U.S.-origin Boeing 747 aircraft bearing manufacturer’s serial number 23413 in violation of the TDO.59 In or around October 2021, Mahan Air transferred custody and control of the jumbo jet to EMTRASUR’s parent company, CONVIASA,  through an intermediary.

Our coverage of the May 2022 TDO renewal chronicles the entire saga.  

FR Doc. 2023-0992 [TDO Renewal Order]


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