Overview
On September 8, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a significant sanctions action targeting Iran’s aviation sector as part of Operation Economic Outcast. As a part of this action, OFAC sanctioned 36 targets, including 27 Iranian airlines, as well as foreign intermediaries, cargo service providers, general sales agents and companies allegedly involved in facilitating the transfer of U.S.-origin aircraft and aviation-related goods to Iran. Simultaneously, the Financial Crimes Enforcement Network (FinCEN) issued an alert intended to assist financial institutions in identifying and reporting procurement networks supporting Iran’s aviation industry.
According to OFAC, the Iranian regime uses the aviation sector to move weapons, personnel and other cargo while relying on front companies, foreign intermediaries and transshipment routes to obtain U.S.-origin aircraft and sensitive technology. OFAC also announced the suspension of three Iran-related aviation authorizations, including authorizations relating to overflights and the operation of U.S.-origin or U.S.-controlled commercial aircraft into Iran. OFAC additionally stated that aviation safety-related requests will continue to be considered on a case-by-case basis.
Background
The sanctions action forms part of Operation Economic Outcast, Treasury’s campaign to identify and disrupt the financial networks, facilitators and revenue streams supporting the Iranian regime. Announced on August 24, 2026, the initiative is intended to target revenue sources, sanctions evasion mechanisms and financial channels used by Iran to access the international financial system. OFAC has stated that entities facilitating money laundering or sanctions evasion on behalf of Iran risk losing access to the U.S. financial system and may face increased secondary sanctions exposure. We previously posted about the operation last month.
According to OFAC, Iran’s commercial aviation sector has long supported the regime’s activities, including using ostensibly private airlines to procure and transport weapons and ferry personnel. OFAC specifically highlighted Mahan Air, which OFAC designated in 2011 pursuant to Executive Order (E.O.) 13224 for providing financial, material and technological support to the Islamic Revolutionary Guard Corps-Qods Force. The U.S. Department of State subsequently designated Mahan Air in 2019 pursuant to E.O. 13382.
OFAC designations targeting Iranian airlines
As part of the action, OFAC designated 27 Iranian airlines pursuant to E.O. 13902 for operating in the aviation sector of the Iranian economy. OFAC described these as its inaugural airline designations under the aviation-sector determination issued on August 24, 2026. Notable designated carriers include Iran Aseman Airlines, Iran Air Tour, Qeshm Air, Kish Airlines, Karun Airlines Company, Saha Airlines, Taban Airlines and Zagros Airlines. For a complete list of designated airlines, refer to OFAC’s recent actions page.
OFAC designations targeting aircraft procurement facilitators
OFAC also targeted several entities and individuals that it alleges facilitated the transfer of U.S.-origin aircraft to Mahan Air through third-country jurisdictions. According to OFAC, Mahan Air received at least three Boeing 777 aircraft during summer 2026 that were diverted through the United Arab Emirates and Oman. OFAC alleged that UAE-based ECT Aviation Support LLC and Türkiye-based Sky Phoenix Hava Yollari Tasimaciligi Ticaret Limited Sirketi served as intermediaries in the transfer scheme and that the transfer route mirrored previous sanctions evasion operations involving Mahan Air.
OFAC additionally designated Ibrahim Ali Mohamed Mohamed Mahran, whom OFAC identified as the founder, owner, managing director and chief executive officer of ECT Aviation Support LLC. OFAC also designated UK-based ECT Aviation Support LTD, which OFAC stated is wholly owned by ECT Aviation Support UAE, and UAE-based Aerobravo Airplane Management and Operation LLC, which allegedly acted as the operator for aircraft owned by ECT Aviation Support UAE.
According to OFAC, ECT Aviation Support UAE and Sky Phoenix were designated pursuant to E.O. 13224 for allegedly providing support to Mahan Air. Mahran, ECT Aviation Support UK and Aerobravo Airplane Management were similarly designated under E.O. 13224 based on their alleged relationships with designated parties or support activities.
OFAC designations targeting cargo service providers and general sales agents
OFAC also designated several cargo service providers and general sales agents that OFAC alleges supported Mahan Air’s international operations. General sales agents typically provide sales, customer support and freight coordination services on behalf of airlines.
According to OFAC, Türkiye-based S Sistem Lojistik Hizmetler Anonim Sirketi coordinated shipments on behalf of Mahan Air, including shipments involving unmanned aerial vehicle components and industrial equipment destined for Iran. OFAC also designated Türkiye-based Mes Cargo Transportation Tourism and Foreign Trade Limited Company, which OFAC identified as a general sales agent for Mahan Air.
In addition, OFAC designated Malaysia-based Icargo SDN BHD and Kazakhstan-based Tour Invest LLC. OFAC stated that both companies served as general sales agents for Mahan Air and alleged that Icargo coordinated shipments of U.S.-origin parts to Iran on the airline’s behalf.
OFAC designated S Sistem, Mes Cargo, Icargo and Tour Invest pursuant to E.O. 13224 for allegedly providing material support to Mahan Air.
FinCEN alert on Iranian aviation procurement networks
In parallel with OFAC’s sanctions action, FinCEN issued an alert intended to help financial institutions identify, prevent and report suspicious activity connected to Iranian aviation procurement networks. According to FinCEN, Iran employs deceptive schemes to procure U.S.- and Western-origin aircraft and aircraft parts through front companies and intermediaries located in Europe, the Middle East, Africa and Asia.
FinCEN further stated that front companies posing as technology, aviation, logistics or trading firms may purchase aircraft components and related dual-use items for subsequent export to Iran. The alert provides typologies and red flag indicators designed to help financial institutions detect procurement activity where Iranian involvement may not be readily apparent from transaction details. FinCEN encouraged financial institutions to remain vigilant for suspicious activity potentially connected to Iranian aviation-sector procurement networks and to report such activity to FinCEN.
Key takeaways
This action expands OFAC’s sanctions pressure on Iran’s aviation sector through a combination of Specially Designated National (SDN) designations, sector-based sanctions under E.O. 13902 and additional compliance measures directed at aircraft procurement and aviation-related services.
The action further highlights OFAC’s continuing focus on third-country parties that allegedly facilitate Iranian access to aircraft, aviation-related goods and international transportation services. Companies involved in aircraft sales, leasing, aviation management, cargo operations, logistics, freight forwarding and related services should consider whether their counterparties, customers or transaction flows present direct or indirect exposure to sanctioned Iranian airlines or associated procurement networks.
We also note that financial institutions should generally review FinCEN’s alert regarding Iranian aviation procurement networks, including the typologies and red flag indicators described therein. OFAC’s simultaneous issuance of sanctions and anti-money-laundering guidance demonstrates a coordinated effort to increase scrutiny of financial activity connected to Iran’s aviation sector.
Separately, OFAC’s suspension of three Iran-related aviation authorizations signals additional restrictions affecting certain aviation-related activities involving Iran, although OFAC indicated that aviation safety-related requests will continue to be considered on a case-by-case basis. We are closely monitoring updates surrounding Operation Economic Outcast and will continue to provide updates on this topic.
Disclaimer
The articles published on this website, current at the dates of publication set out above, are for reference purposes only. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action.