Treasury Cracks Down on Global Networks Enabling Iran’s Mahan Air and IRGC

Mahan Air serves as a critical conduit for the IRGC’s movement of weapons, operatives, and military equipment worldwide.

WASHINGTON—Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating six entities and individuals in China, India, Russia, and Iran, including multiple companies serving as general sales agents for the U.S.- and European Union‑sanctioned Iranian airline Mahan Air.  Although Mahan Air presents itself as a civilian carrier, it has long played a central role in enabling the Islamic Revolutionary Guard Corps (IRGC), providing travel services for IRGC‑Qods Force personnel, facilitating military training, and supporting Iran’s procurement and transport of unmanned aerial vehicle (UAV) systems and weapons. 

“Those who provide financial services, logistics, or commercial support to the IRGC or Mahan Air are helping sustain a terrorist enterprise,” said Secretary of the Treasury Scott Bessent.  “Treasury will continue to identify them, expose them, and cut them off from the U.S. financial system.”

By sanctioning entities that help sustain Mahan Air’s global operations, today’s action further disrupts the network underpinning Iran’s destabilizing activities across the region.  This action advances Treasury’s efforts to intensify economic pressure on the Iranian regime and the IRGC, particularly in response to its reckless attacks against regional states and commercial vessels in the Strait of Hormuz. OFAC is also sanctioning an IRGC‑affiliated front company that has supported Iran’s kinetic targeting during the ongoing conflict.

OFAC is taking this action pursuant to Executive Order (E.O.) 13224, as amended, which targets terrorist groups, their supporters, and those who aid acts of terrorism, and in furtherance of the President’s National Security Presidential Memorandum 2 (NSPM-2), which directs the U.S. government to deny the IRGC access to assets and resources that sustain its destabilizing activities.  On October 12, 2011, OFAC designated Mahan Air pursuant to E.O. 13224 for providing financial, material, and technological support to Iran’s IRGC-Qods Force (IRGC-QF), which OFAC designated pursuant to E.O. 13224 in October 2007 for providing material support to multiple terrorist organizations. The U.S. Department of State designated the IRGC itself pursuant to the counterproliferation authority E.O. 13382 in 2007, and OFAC designated the IRGC pursuant to E.O. 13224 in October 2017 for providing support to the IRGC-QF. 

GENERAL SALES AGENTS SUPPORTING MAHAN AIR 

While it masquerades as a civilian airline, Mahan Air has provided travel services to IRGC-QF personnel for military training, as well as facilitated Iran’s procurement and transport of unmanned aerial vehicle (UAV) systems and weapons to and from Iran. OFAC is taking action today against persons, including general sales agents, providing support to Mahan Air. A general sales agent provides a given airline with sales and customer support services and communicates with freight forwarders and shippers on the airline’s behalf. 

China-based Shanghai Wings International Logistics Co (Shanghai Wings) is serving as a

general sales agent for Mahan Air and has coordinated the transport of electronics from China to Iran. China‑based Tang Xin is the managing director of Shanghai Wings and has coordinated travel for Mahan Air. Tang Xin is the executive director and 50 percent owner of China-based Shanghai Elite International Travel Co (Shanghai Elite), which also represents Mahan Air in China.  India-based Skiez Travels and Logistics Private Limited (Skiez Travels) and Russia-based Air Cargo Pro Limited (Air Cargo Pro) also serve as general sales agents for Mahan Air in India and Russia, respectively.

Shanghai Wings, Tang Xin, Skiez Travels, and Air Cargo Pro are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mahan Air.  Shanghai Elite is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for on behalf of, directly or indirectly, Tang Xin.

IRGC-AFFILIATED FRONT COMPANY

Today, OFAC is also designating DadeNegar Startup Studio (DadeNegar).  DadeNegar is a front company affiliated with Iran’s IRGC, supporting military targeting through the use of a website.  DadeNegar solicited locations of American and Israeli equipment to support Iranian military targeting.  In coordination with the IRGC, DadeNegar received strike requests for U.S. targets in the Middle East.

DadeNegar is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods and services to or in support of, the IRGC.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.  In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.  Unless authorized by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons. 

Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons.  OFAC may impose civil penalties for sanctions violations on a strict liability basis.  OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions.  In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons.  The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.  Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions.  Individuals located in the U.S. or abroad who provide information about sanctions violations to FinCEN’s whistleblower incentive program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000.  In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities with designated or otherwise blocked persons.

Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions.  OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law.  The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.  For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC’s guidance on Filing a Petition for Removal from an OFAC List.

Click here for more information on the persons designated today.

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