Report on Airports used by Mahan Air

The U.S. Department of the Treasury designated Iranian airline Mahan Air as a Specially Designated Global Terrorist pursuant to Executive Order 13224 on October 12, 20111for providing financial, military equipment, and technological support to the Islamic Revolutionary Guard Corps-Qods Force. Based in Tehran, Mahan Air provides transportation, funds transfers, and personnel travel services to the Islamic Revolutionary Guard Corps-Qods Force. Since the onset of the Syrian civil war, Mahan Air and other designated Iranian commercial airlines have routinely flown fighters and military equipment to Syria to aid the Assad regime’s attacks against its own people.

As a result of U.S. sanctions against Mahan Air, individuals and entities maintaining commercial relationships with Mahan Air and other designated Iranian airlines are themselves at risk of being designated under Executive Order 13224 for providing support to an Specially Designated Global Terrorist. In addition to general sales agent services such as reservation and ticketing services, potentially sanctionable activities—when conducted for or on behalf of a designated person—include procurement of aircraft parts and equipment, maintenance contracts, provision of airline ground services, catering, interline transfer and codeshare agreements, refueling contracts, cargo cooperation agreements, cargo sales agent services and agreements, and freight forwarding services.2 It is incumbent on all persons operating in the civil aviation industry to implement appropriate controls to ensure compliance with legal requirements and sanctions.

Of the 42 destinations Mahan Air serviced between October 2016 and October 2018, 15 of those airports conduct Last Point of Departure operations to the United States.

Mahan Air Operations

In 2011, the U.S. Department of the Treasury designated Mahan Air a Specially Designated Global Terrorist (SDGT)3 for providing financial, material, or technological support for the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Since the onset of the Syrian civil war, Mahan Air and other designated Iranian commercial airlines have routinely flown fighters and military equipment to Syria. As a result of U.S. sanctions against Mahan Air, individuals and entities maintaining commercial relationships with Mahan Air and other designated Iranian airlinesare themselves at risk of being designated under Eexecutive Order (E.O.) 13224 for providing support to an SDGT.

In 2018, the United States designated 11 entities supporting Mahan Air’s activities, including front companies4 procuring spare aircraft parts for Mahan and general sales agents (GSAs) providing services to Mahan in Malaysia5 and Thailand.6 As a result of U.S. diplomatic outreach and the credible threat of U.S. sanctions, several companies have stopped working with Mahan Air, and some countries have denied Mahan Air landing rights.

The Department of Homeland Security (DHS), U.S. Department of Transportation (DOT), U.S. Department of State (DOS), U.S. Department of the Treasury, and the Director of National Intelligence (DNI) have been in close coordination with regard to monitoring Mahan Air activities, recommending designation of companies that do business with Mahan Air, and enhancing international aviation security. In the summer of 2017, TSA undertook a series of initiatives designed to raise the global aviation security baseline to establish a common view of the threat and enhance aviation security throughout the world. This initiative continues throughout 2018 and into 2019 as TSA works with its international and domestic stakeholders to push new countermeasures to mitigate emerging risks to the aviation network.

Below is a list of airports at which “aircraft owned or controlled by Mahan Air” have landed during the past two years.

Mahan Air Destinations from September 2016 to October 2018