OFAC sanctions Kazakh, Turkish and UAE firms linked to Mahan Air in Iran airlines sweep

The US Treasury sanctioned 36 targets on 8 September in what it called an action against all of Iran's remaining airlines. The Office of Foreign Assets Control (OFAC) designated 27 Iranian airlines under Executive Order 13902 and nine non-Iranian persons under counter-terrorism authority, according to the Treasury release. The nine include Kazakhstan-based Tour Invest LLC, which the release says "has served as a general sales agent for Mahan Air", alongside three Turkish companies, two UAE companies and a UAE-based individual, a UK company and a Malaysian company.

OFAC's notice lists Tour Invest at an address on Ulitsa Makataeva in Almaty and gives its establishment date as 18 March 2014. The entries for the nine carry a secondary sanctions risk notation. Mahan Air itself was designated earlier, in October 2011, according to FinCEN.

The intermediaries

By location, the OFAC entries and the release describe the nine as follows:

• UAE: ECT Aviation Support LLC (Sharjah) and Aerobravo Airplane Management and Operation LLC (Dubai), together with Ibrahim Ali Mohamed Mohamed Mahran, an Egyptian national based in the UAE. Treasury describes Mahran as the founder and owner of ECT Aviation Support UAE, and Aerobravo as the operator of aircraft that the company owns.
• United Kingdom: ECT Aviation Support Ltd, which Treasury says is wholly owned by the UAE company. OFAC gives a London address and a 21 February 2024 establishment date.
• Türkiye: Sky Phoenix Hava Yollari Tasimaciligi Ticaret Limited Sirketi (Izmir), described as an intermediary in the aircraft transfer scheme, and S Sistem Lojistik Hizmetler Anonim Sirketi and Mes Cargo (both Istanbul). The release says S Sistem coordinated shipments that included unmanned aerial vehicle components and industrial equipment destined for Iran.
• Kazakhstan: Tour Invest LLC, Almaty.
• Malaysia: Icargo SDN BHD, which the release says has served as a general sales agent for Mahan Air.

Treasury says Mahan Air received at least three B-777 aircraft that were "diverted through the United Arab Emirates (UAE) and Oman". Each originated from a retired fleet before passing through ECT Aviation Support UAE, where it received a temporary registration, the release says, and the route closely mirrored earlier sanctions evasion operations for the airline.

What FinCEN told banks

FinCEN issued a separate alert, FIN-2026-Alert006, the same day. It says Iran uses commercial airlines to support the Islamic Revolutionary Guard Corps and its proxies, including by shipping weapons and sensitive technologies and moving gold and hard currency. Iranian airlines buy aircraft, parts and services through front companies in Europe, the Middle East, Africa and Asia, the alert says, and aircraft are often re-registered several times and moved between jurisdictions, including in Central Asia, before they reach Iran. It names Türkiye and the UAE as transshipment jurisdictions for controlled items.

Among its red flags are a general trading company in a free trade zone or high-risk jurisdiction that does not normally deal in aviation goods but seeks US or Western aircraft parts, and sale documents that show long storage periods, frequent re-registrations or unusual moves between jurisdictions, particularly in Central Asia. The alert asks institutions to include the key term "FIN-2026-IRANAIR" in suspicious activity reports.

Consequences for foreign firms

OFAC is suspending three Iran-related aviation authorisations, including those that allowed overflights and those that allowed non-US airlines to fly US-origin or US-controlled commercial aircraft into Iran, the release says. It will consider aviation safety requests case by case. The notice shows Iran General License J-1, on the re-exportation of certain civil aircraft to Iran on temporary sojourn, suspended as of 8 September, and General License DD authorising the wind-down of certain civil aviation-related transactions. Counter Terrorism General License 37 covers the wind-down of transactions involving persons blocked on 8 September.

The release warns that foreign financial institutions that take part in transactions with the designated persons "may risk the imposition of secondary sanctions", and that OFAC can prohibit or impose strict conditions on opening or maintaining a correspondent account in the United States. Treasury Secretary Scott Bessent said: "Let this be a warning to anyone doing business with Iran's remaining airlines". The action builds on an aviation sector determination under Executive Order 13902 that Treasury issued on 24 August.