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3/19/2020

Treasury Designates Iran’s Foreign Fighter Militias in Syria along with a Civilian Airline Ferrying Weapons to Syria | U.S. Department of th…

Treasury Designates Iran’s Foreign Fighter Militias in Syria along
with a Civilian Airline Ferrying Weapons to Syria
January 24, 2019

WASHINGTON – Today, the U.S. Department of the Treasury’s O ice of Foreign Assets Control
(OFAC) took action against two Syria-based, Iran-backed militias composed of foreign nationals,
an Iranian airline linked to designated Iranian airline Mahan Air and Iran’s Islamic Revolutionary
Guard Corps-Qods Force (IRGC-QF), and an Armenian general sales agent (GSA) providing
services to Mahan Air. The Fatemiyoun Division, composed of Afghan nationals, and the
Zaynabiyoun Brigade, consisting of Pakistani nationals, are IRGC-QF-led, Syria-based militias
whose fighters are recruited by the Islamic Revolutionary Guard Corps (IRGC) and its Basij
militia mostly from Afghan and Pakistani refugees and migrants residing in Iran. On October 16,
2018, OFAC designated the Basij militia, along with its vast network of 20 corporations and
financial institutions, for recruiting fighters, including child soldiers, for the IRGC-QF’s
operations in Syria.
The Fatemiyoun Division and Zaynabiyoun Brigade are being designated for providing material
support to the IRGC-QF. OFAC is designating Qeshm Fars Air for being owned or controlled by
Mahan Air, and for providing material support to the IRGC-QF, and Armenia-based Flight Travel
LLC for acting for or on behalf of Mahan Air. Mahan Air plays an integral role supporting the
IRGC-QF and its proxies in Syria by transporting personnel and weapons.
“The brutal Iranian regime exploits refugee communities in Iran, deprives them of access to
basic services such as education, and uses them as human shields for the Syrian conflict,” said
Treasury Secretary Steven Mnuchin. “Treasury’s targeting of Iran-backed militias and other
foreign proxies is part of our ongoing pressure campaign to shut down the illicit networks the
regime uses to export terrorism and unrest across the globe.”
“This is a regime that preys on the most vulnerable — coercing children as young as 14 years old
to fight in Syria under the direction of the IRGC-QF, and perpetuating widespread su ering and
displacement,” said Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker.
“Iran continues to leverage Mahan Air and its commercial aviation sector to transport
individuals and weapons needed to carry out this tragic campaign and to fuel sectarian conflict
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throughout the region. We are aggressively targeting those who continue to provide
commercial support to Mahan Air and other designated airlines, and any who fail to heed our
warnings expose themselves to severe sanctions risk.”
The Fatemiyoun Division, Zaynabiyoun Brigade, Qeshm Fars Air, and Flight Travel LLC are being
designated under Executive Order (E.O.) 13224, a counter-terrorism authority. Additionally, the
IRGC-QF, the Fatemiyoun Division, and the Zaynabiyoun Brigade are also being designated
under E.O. 13553, an authority that targets serious human rights abuses by the Government of
Iran.

FATEMIYOUN AND ZAYNABIYOUN: IRGC-QF-LED MILITIAS
PREYING ON AFGHAN AND PAKISTANI REFUGEES AND
MIGRANTS, INCLUDING CHILDREN
The Fatemiyoun Division is an IRGC-QF-led militia that preys on the millions of undocumented
Afghan migrants and refugees in Iran, coercing them to fight in Syria under threat of arrest or
deportation. Several hundred Fatemiyoun Division fighters, including children as young as 14
years old, have died fighting Iran’s war in Syria, and the bodies of slain Afghan fighters have
been flown back to Iran on board Mahan Air flights from Syria.

In addition to transporting weapons and fighters for the IRGC-QF, Mahan Air has been used by
the IRGC to transport bodies of Fatemiyoun Division fighters who are killed fighting in Syria back
to several airports in Iran (Pictures obtain from Iran’s Mashregh News and Quds Online).

Many Afghans from Iran have joined the wave of refugees arriving in Europe, including a number
who have fled the IRGC’s forced recruitment. Former Fatemiyoun Division fighters have
reported being arrested by Iranian security forces and o ered a choice between prison,
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deportation, or “volunteering” to train and fight in Syria with the promise of legal residency.
Afghan recruits receive little training prior to deployment to Syria, where many are thrust into
dangerous front-line combat roles, resulting in significant casualties. The Zaynabiyoun Brigade
is another Syria-based, IRGC-QF-led militia, composed of Pakistani fighters mainly recruited
from among undocumented and impoverished Pakistani Shiite immigrants living in Iran.
The Fatemiyoun Division and Zaynabiyoun Brigade are being designated pursuant to
E.O. 13224, which targets terrorists and those providing support to terrorists or acts of
terrorism. OFAC is designating the Fatemiyoun Division and Zaynabiyoun Brigade for assisting,
sponsoring, or providing financial, material, or technological support for, or financial or other
services to or in support of, the IRGC-QF. The IRGC-QF was designated pursuant to E.O. 13224 on
October 25, 2007.
As a part of today’s action, the IRGC-QF, the Fatemiyoun Division, and the Zaynabiyoun Brigade
are also being designated pursuant to E.O. 13553, which targets serious human rights abuses by
the Government of Iran. The IRGC-QF is being designated for being owned or controlled by, or
acting or purporting to act for or on behalf of, the IRGC, which was designated pursuant to E.O.
13553 in 2011 for engaging in serious human rights abuses, including the violent crackdowns on
protesters in Iran in 2009. The Fatemiyoun Division and the Zaynabiyoun Brigade are being
designated pursuant to E.O. 13553 for having materially assisted, sponsored, or provided
financial, materials, or technological support for, or goods or services to or in support of, the
IRGC-QF.

QESHM FARS AIR: ANOTHER COMMERCIAL IRANIAN
AIRLINE PROVIDING AIRLIFT TO THE IRGC-QF

Since the onset of the Syrian civil war, Iran has routinely relied upon Iranian airlines such as
Mahan Air to fly fighters and materiel to Syria to prop up the Assad regime. Mahan Air has
transported IRGC-QF operatives, weapons, equipment, and funds abroad in support of the IRGCQF’s destabilizing regional operations. Mahan Air has also transported IRGC-QF Commander
Qassem Soleimani, who is sanctioned under United Nations Security Council Resolution 2231
and therefore covered by a travel ban.

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Qeshm Fars Air, which originally operated as a commercial airline between 2006 and 2013,
restarted operations in 2017, and its fleet of two B747 aircra have operated regular cargo
flights to Damascus, delivering cargo, including weapons shipments, on behalf of the IRGC-QF.
Mahan Air employees fill Qeshm Fars Air management positions, and Mahan Air provides
technical and operational support for Qeshm Fars Air, facilitating the airline’s illicit operations.
The delivery of lethal materiel by Qeshm Fars Air enables Iran’s military support for the Assad
regime, prolonging the brutal conflict and the su ering of millions of Syrians, and has resulted
in the displacement of millions across the region.

Qeshm Fars Air is being designated pursuant to E.O. 13224 for being owned or controlled by
Mahan Air, as well as for assisting in, sponsoring, or providing financial, material or
technological support for, or financial or other services to or in support of, the IRGC-QF.

OFAC is also identifying two B747 aircra as property in which Qeshm Fars Air has an interest:
EP-FAA and EP-FAB. These identifications serve to warn those who provide support to these
aircra that they could be exposed to U.S. sanctions.

FLIGHT TRAVEL LLC: ARMENIA-BASED GSA GENERATING
REVENUE FOR MAHAN AIR
Flight Travel LLC, located in Yerevan, Armenia is being designated pursuant to E.O. 13224 for
acting for or on behalf of Mahan Air by serving as a Mahan Air GSA in Armenia. A GSA is a third
party that provides services to an airline under the airline’s brand, including sales and
marketing, administrative services, and financial services. Flight Travel LLC has refused to heed
warnings about the risk of sanctions exposure due to commercial support to Mahan Air, and it is
now the third company sanctioned by Treasury for acting for or on behalf of Mahan Air as a GSA
in the last seven months. In July 2018, OFAC designated a Malaysia-based Mahan Air GSA, and in
September 2018, OFAC designated a Thailand-based Mahan Air GSA.
The designation of Flight Travel LLC demonstrates the U.S. Government’s commitment to
denying foreign support for Mahan Air and other designated Iranian airlines, and reinforces
multiple warnings to the aviation community of the sanctions risk for individuals and entities
maintaining commercial relationships with these airlines. In addition to GSA services such as
reservation and ticketing services, the civil aviation industry should conduct due diligence for
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other potentially sanctionable activities that may arise when conducted for or on behalf of a
designated person. Sanctionable activities may include marketing services, procurement of
aircra parts and equipment, maintenance contracts, airline ground services, catering, interline
transfer and codeshare agreements, and refueling contracts.

SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of these entities that are in
the United States or in the possession or control of U.S. persons are blocked and must be
reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within
(or transiting) the United States that involve any property or interests in property of blocked or
designated persons.
In addition, persons that engage in certain transactions with the entities designated today may
themselves be exposed to designation. Furthermore, any foreign financial institution that
knowingly facilitates a significant transaction or provides significant financial services for any of
the entities designated today could be subject to U.S. correspondent account or payablethrough sanctions.
Identifying information on the entities designated today.

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