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3/19/2020

Treasury Targets Thai Company Supporting Iranian Airline Mahan Air | U.S. Department of the Treasury

Treasury Targets Thai Company Supporting Iranian Airline
Mahan Air
September 14, 2018

Washington – Today, the U.S. Department of the Treasury’s O ice of Foreign Assets Control
(OFAC) designated Thailand-based My Aviation Company Limited for acting for or on behalf of
Mahan Air, an Iranian airline previously designated for supporting Iran’s terrorism activities. The
action today was taken pursuant to Executive Order (E.O.) 13224, which targets terrorists and
those providing support to terrorists or acts of terrorism.
“Mahan Air continues to fly into Syria every week, even as millions of innocent civilians in Idlib
province are under threat of imminent attack from the murderous Assad regime and its backers
in Iran and Russia. Treasury is cutting o yet another service provider acting on behalf of Mahan
Air, a sanctioned airline that transports soldiers and supplies to Assad and fuels terrorist
activities across the region,” said Secretary of the Treasury Steven T. Mnuchin. “This Thailandbased company has disregarded numerous U.S. warnings, issued publicly and delivered
bilaterally to the Thai government, to sever ties with Mahan Air. This action should serve as a
warning that the U.S. is intent on ensuring that the aviation industry ceases providing services
to, and profiting from, this terrorist-a iliated airline.”
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 mass atrocities in the country and
the displacement of millions of innocent civilians. Mahan Air continues to operate a regular
schedule of three weekly flights to Syria, with additional flights periodically observed, totaling
more than 170 flights since September 2017.

MY AVIATION
My Aviation Company Limited (My Aviation), headquartered in Bangkok, Thailand, is being
designated for acting for or on behalf of Mahan Air by serving as a Mahan Air General Sales
Agent (GSA) in Thailand. A GSA is a third party that provides services to an airline under the
airline’s brand. There are several types of services and support that GSAs typically o er airlines,

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Treasury Targets Thai Company Supporting Iranian Airline Mahan Air | U.S. Department of the Treasury

including sales and marketing, freight reception and handling, airport warehouse and ramp
supervision, administration services, and financial services.
My Aviation provides cargo services to Mahan Air, to include freight booking, and works with
local freight forwarding entities to ship cargo aboard regularly scheduled Mahan Air flights to
Tehran, Iran. My Aviation has also provided Mahan Air with passenger booking services.
The designation of this GSA reinforces Treasury’s notice to the international aviation community
of the sanctions risk for individuals and entities maintaining commercial relationships with
Mahan Air and other designated Iranian airlines. In addition to GSA services such as freight
booking and handling, the civil aviation industry should conduct due diligence for other
activities that, when conducted for or on behalf of a designated person, are potentially
sanctionable. Such activities may include reservation and ticketing services, procurement of
aircra parts and equipment, maintenance contracts, airline grounds services, catering,
interline transfer and codeshare agreements, and refueling contracts.
Treasury also identified Mihan Travel & Tourism SDN BHD as an alias for Mahan Travel and
Tourism SDN BHD, which Treasury designated on July 9, 2018 for acting for or on behalf of
Mahan Air as its GSA in Malaysia.
As a result of today’s actions, all property and interests in property under U.S. jurisdiction of My
Aviation Company Limited are blocked, and U.S. persons are generally prohibited from
engaging in transactions with it. Additionally, My Aviation Company Limited is subject to
secondary sanctions pursuant to the Iranian Financial Sanctions Regulations (IFSR), which
implement, among other authorities, the Comprehensive Iran Sanctions and Divestment Act of
2010 (CISADA). Pursuant to the IFSR, OFAC can prohibit or impose strict conditions on the
opening or maintaining in the United States of a correspondent account or a payable-through
account by a foreign financial institution that knowingly facilitates a significant transaction for
designated agents or a iliates of Iran’s Islamic Revolutionary Guard Corps (IRGC) or persons
designated pursuant to E.O. 13224 in connection with Iran’s support for international terrorism
or E.O. 13382 in connection with Iran’s proliferation of weapons of mass destruction and their
means of delivery.

MAHAN AIR BACKGROUND
Mahan Air was designated in October 2011 pursuant to E.O. 13224 for providing financial,
material, or technological support for or to Iran’s Islamic Revolutionary Guard Corps-Qods Force
(IRGC-QF), which was itself designated pursuant to E.O. 13224 on October 25, 2007 for its
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Treasury Targets Thai Company Supporting Iranian Airline Mahan Air | U.S. Department of the Treasury

support to numerous terrorist groups. Mahan Air has transported IRGC-QF operatives, weapons,
equipment, and funds abroad in support of the IRGC-QF’s destabilizing regional operations.
Mahan Air has routinely facilitated the movement of IRGC-QF personnel, fighters, and material,
between Iran and Syria for military training, and has facilitated the movement of IRGC-QF
members by bypassing normal security protocols and flight manifests. The airline also has
moved weapons and personnel for Hizballah and regional armed groups whose actions fuel
conflict and exacerbate regional instability. Hizballah was designated by the Department of
State as a Foreign Terrorist Organization in October 1997 and as a Specially Designated Global
Terrorist pursuant to E.O. 13224 in October 2001. It was listed in January 1995 in the Annex to
E.O. 12947, which targets terrorists who threaten to disrupt the Middle East peace process, and
also designated in August 2012 pursuant to E.O. 13582, which targets the Government of Syria
and its supporters.
Today’s actions demonstrate the U.S. Government’s continued commitment to enforcing
existing sanctions and to targeting those that provide support to terrorism.
As a reminder, due to President Trump’s May 8, 2018 decision to cease the United States’
participation in the Joint Comprehensive Plan of Action (JCPOA), following the 180-day winddown period ending on November 4, 2018, all U.S. nuclear-related sanctions that had been li ed
under the JCPOA will be re-imposed and in full e ect.
Identifying information on the entities designated today.
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