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9/21/2020

Treasury Designates Key Actors in Mahan Air Illicit Procurement Operations | U.S. Department of the Treasury

Treasury Designates Key Actors in Mahan Air Illicit Procurement
Operations
August 19, 2020

WASHINGTON – Today, the U.S. Department of the Treasury’s O ice of Foreign Assets Control
(OFAC) is designating UAE-based Parthia Cargo and Delta Parts Supply FZC for their material
support of Iranian airline Mahan Air. OFAC is also designating UAE-based Iranian national
Amin Mahdavi for owning or controlling Parthia Cargo. Together, these companies have
provided key parts and logistics services for Mahan Air, which is designated under
counterterrorism authorities for support to Iran’s Islamic Revolutionary Guard Corps-Qods
Force (IRGC-QF), as well as under a counter proliferation authority that targets weapons of
mass destruction proliferators and their supporters.
“The Iranian regime uses Mahan Air as a tool to spread its destabilizing agenda around the
world, including to the corrupt regimes in Syria and Venezuela, as well as terrorist groups
throughout the Middle East,” said Secretary Steven T. Mnuchin. “The United States will
continue to take action against those supporting this airline.”
The services provided by Parthia Cargo and Delta Parts Supply FZC help Mahan Air sustain its
fleet of western-manufactured aircra and allow it to support the Iranian regime’s
destabilizing agenda through activities that include the transportation of terrorists and lethal
cargo to Syria to prop up the murderous Assad regime, as well as the more recent
transportation of Iranian technicians and technical equipment to Venezuela to support the
illegitimate Maduro regime’s e orts to revive energy production ruined by corruption and
mismanagement. Concurrent with OFAC’s designations, the U.S. Attorney’s O ice for the
District of Columbia filed criminal charges against Parthia Cargo and Amin Mahdavi related to
the alleged unlicensed re-export of U.S.-export controlled aircra parts to Iran in violation of
the International Emergency Economic Powers Act.
Mahan Air has transported IRGC-QF operatives, weapons, equipment, and funds abroad in
support of the terrorist group’s regional operations, and has also moved weapons and
personnel for Hizballah. Since the onset of the Syrian civil war, Mahan Air has routinely flown
fighters and materiel to Syria to prop up the Assad regime, which has contributed to the
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9/21/2020

Treasury Designates Key Actors in Mahan Air Illicit Procurement Operations | U.S. Department of the Treasury

regime’s atrocities and displacement of civilians. In December 2019, the Department of State
designated Mahan Air pursuant to E.O. 13382, a counter proliferation authority targeting
weapons of mass destruction proliferators and their supporters.
Dubai-based Parthia Cargo serves as a freight forwarding agent of Mahan Air and has
regularly forwarded consignments of aircra parts, including U.S.-origin parts, from UAE
directly to Mahan Air in Tehran, as well as to Mahan Air front companies in Istanbul. Parts
have typically been shipped aboard regularly scheduled Mahan Air flights between Dubai
and Tehran. Several additional Iranian airlines and aviation firms have also relied on Parthia
Cargo to forward U.S.-origin aircra parts to Tehran.
Dubai-based Delta Parts Supply FZC has sold key aviation goods, including U.S.-origin parts,
directly to Mahan Air or its front companies. Aircra part orders have shipped aboard the
regularly scheduled Mahan Air flights from Dubai, and have utilized the freight forwarding
services of Parthia Cargo.
Parthia Cargo and Delta Parts Supply FZC 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.
UAE-based Iranian national Amin Mahdavi is the CEO and owner of Parthia Cargo, and has
directly coordinated the shipment of parts on behalf of Mahan Air. Amin Mahdavi is being
designated pursuant to E.O. 13224, as amended, for owning or controlling Parthia Cargo.
Today’s action follows recent actions targeting Mahan Air general sales agents (GSA) outside
of Iran, and provides another warning to the international aviation community of the
sanctions risk for individuals and entities that choose to maintain commercial relationships
with Mahan Air and other designated airlines. Those in the airline industry should conduct
due diligence to avoid performing services for or on behalf of a designated person, which
may be sanctionable. Such activities may include freight booking, reservation and ticketing
services, procurement of aircra parts and equipment, maintenance contracts, airline
grounds services, catering, interline transfer or codeshare agreements, and refueling
contracts.
On July 23, 2019, OFAC issued an advisory

to inform the civil aviation industry of potential

exposure to U.S. government economic sanctions for providing unauthorized support to or
for designated Iranian airlines, many of which, including Mahan Air, are involved in facilitating
the Iranian regime’s support to proxy militias and groups it supports.
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Treasury Designates Key Actors in Mahan Air Illicit Procurement Operations | U.S. Department of the Treasury

SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of Parthia Cargo, Delta
Parts Supply FZC, and Amin Mahdavi that are in the United States or in the possession or
control of U.S. persons must be blocked and 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 interest in property of blocked or designated persons, unless licensed or
exempt.
In addition, persons that engage in certain transactions with Parthia Cargo, Delta Parts
Supply FZC, or Amin Mahdavi may themselves be exposed to designation. Furthermore, any
foreign financial institution that knowingly conducts or facilitates a significant transaction or
provides significant financial services for individuals and entities designated in connection
with Iran’s support for international terrorism or any Iranian person on OFAC’s List of
Specially Designated Nationals and Blocked Persons could be subject to U.S. correspondent
account or payable-through account sanctions.
View identifying information on the entities and individual listed today.
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