Guidance

Today, OFAC added a person:

KHEDRI, Abdolhossein (a.k.a. KHEDRI, Abdolhossein Heid; a.k.a. KHEDRI, Abdul Hossein; a.k.a. KHODRI, Abed Al Hsein Heid), Iran; DOB May 1971; POB Bushehr Province, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).

and some entities:

GATEWICK LLC (a.k.a. GATEWICK AVIATION SERVICES; a.k.a. GATEWICK FREIGHT AND CARGO; a.k.a. “GATEWICK”), Office No. M22, 1st Floor Dnata Building Freight Gate No. 4, Dubai Airport Free Zone, United Arab Emirates; Freight Gate 3, DAFZA, Dubai, United Arab Emirates; P.O. Box 52404, United Arab Emirates; P.O. Box 120597, United Arab Emirates; Website http://www.gatewick.com; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 222112 (United Arab Emirates) [SDGT] [IFSR] (Linked To: MAHAN AIR). 

 

GOMEI AIR SERVICES CO., LTD., 3/F, The Strand, 49 Bonham Strand, Sheung Wan, Hong Kong; B-1,2, Tower1, 120Liuhua Rd Dongfang Hotel, Guangzhou, China; Room 1403B, Pearl River Int’l Building, 112 Yuehua Road, YueXiu District, Guangzhou, China; Email Address cargores@gomei.com.hk; alt. Email Address cargores@gzgomei.cn; alt. Email Address mahan-gz@m3eliteclub.com; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: MAHAN AIR). 

 

JAHAN DESTINATIONS TRAVEL AND TOURISM LLC, G/F, Falcon Tower, Riggat Al Buteen, Deira, P.O. Box 125327, Dubai, United Arab Emirates; Office No. 4, Riqat Albutain, Deira, Dubai, United Arab Emirates; Additional Sanctions Information – Subject to Secondary Sanctions; Tourism License No. 585026 (United Arab Emirates); Registration Number 110323 (United Arab Emirates) [SDGT] [IFSR] (Linked To: MAHAN AIR). 

 

KHEDRI JAHAN DARYA CO (a.k.a. KHEDRI JAHAN DARYA SHIPPING PORT COMMERCIAL COMPANY), 1st Floor No. 11 Before Davood Eslami Street Junction Gilane Gharbi Street, 2nd Boostan Street, Pasdaran Street, Tehran, Tehran Province 1664867853, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Identification Number IMO 4213219 [SDGT] [IFSR] (Linked To: KHEDRI, Abdolhossein). 

 

MARITIME SILK ROAD LLC, Muscat, Oman; Additional Sanctions Information – Subject to Secondary Sanctions; Commercial Registry Number 1096241 (Oman) [SDGT] [IFSR] (Linked To: KHEDRI, Abdolhossein).

and 2 vessels:

GENAVA 11 (f.k.a. GOSTARESH SW 8301) (EPDE7) Iran flag; Additional Sanctions Information – Subject to Secondary Sanctions; Vessel Registration Identification IMO 9804617 (vessel) [SDGT] [IFSR] (Linked To: KHEDRI JAHAN DARYA CO). 

 

GENAVA 12 (EPDA4) Iran flag; Additional Sanctions Information – Subject to Secondary Sanctions; Vessel Registration Identification IMO 9776523 (vessel) [SDGT] [IFSR] (Linked To: KHEDRI JAHAN DARYA CO).

to its Iran sanctions program. It also put a bunch of Mahan Air aircraft under secondary sanctions more clearly (by adding the verbiage to the listings), and/or added them to the non-proliferation program (NPWMD) – and updated the Mahan Air listing, to boot:

EK-30064; Aircraft Construction Number (also called L/N or S/N or F/N) 464; Aircraft Manufacture Date 17 May 1988; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EK-30064; Aircraft Construction Number (also called L/N or S/N or F/N) 464; Aircraft Manufacture Date 17 May 1988; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MHA; Aircraft Construction Number (also called L/N or S/N or F/N) 160; Aircraft Manufacture Date 17 Sep 1981; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHA; Aircraft Construction Number (also called L/N or S/N or F/N) 160; Aircraft Manufacture Date 17 Sep 1981; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MHF; Aircraft Construction Number (also called L/N or S/N or F/N) 55; Aircraft Manufacture Date 01 Mar 1978; Aircraft Model A300B4-103; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHF; Aircraft Construction Number (also called L/N or S/N or F/N) 55; Aircraft Manufacture Date 01 Mar 1978; Aircraft Model A300B4-103; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MHG; Aircraft Construction Number (also called L/N or S/N or F/N) 204; Aircraft Manufacture Date 29 Jul 1982; Aircraft Model A300B4-203; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHG; Aircraft Construction Number (also called L/N or S/N or F/N) 204; Aircraft Manufacture Date 29 Jul 1982; Aircraft Model A300B4-203; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MHJ; Aircraft Construction Number (also called L/N or S/N or F/N) 857; Aircraft Manufacture Date 18 Jun 1998; Aircraft Model A320-232; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHJ; Aircraft Construction Number (also called L/N or S/N or F/N) 857; Aircraft Manufacture Date 18 Jun 1998; Aircraft Model A320-232; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MHL; Aircraft Construction Number (also called L/N or S/N or F/N) 175; Aircraft Manufacture Date 02 Feb 1982; Aircraft Model A300B4-203; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHL; Aircraft Construction Number (also called L/N or S/N or F/N) 175; Aircraft Manufacture Date 02 Feb 1982; Aircraft Model A300B4-203; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MHM; Aircraft Construction Number (also called L/N or S/N or F/N) 90; Aircraft Manufacture Date 05 Nov 1980; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHM; Aircraft Construction Number (also called L/N or S/N or F/N) 90; Aircraft Manufacture Date 05 Nov 1980; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MHO; Aircraft Construction Number (also called L/N or S/N or F/N) 488; Aircraft Manufacture Date 13 Jan 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHO; Aircraft Construction Number (also called L/N or S/N or F/N) 488; Aircraft Manufacture Date 13 Jan 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MHP; Aircraft Construction Number (also called L/N or S/N or F/N) 244; Aircraft Manufacture Date 09 Mar 1983; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MHP; Aircraft Construction Number (also called L/N or S/N or F/N) 244; Aircraft Manufacture Date 09 Mar 1983; Aircraft Model A300B2K-3C; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MMA; Aircraft Manufacture Date 08 Sep 1993; Aircraft Model A340-311; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 20; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMA; Aircraft Manufacture Date 08 Sep 1993; Aircraft Model A340-311; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 20; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MMB; Aircraft Manufacture Date 07 Dec 1994; Aircraft Model A340-311; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 56; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMB; Aircraft Manufacture Date 07 Dec 1994; Aircraft Model A340-311; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 56; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MMC; Aircraft Manufacture Date 18 Jun 1999; Aircraft Model A340-313X; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 282; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMC; Aircraft Manufacture Date 18 Jun 1999; Aircraft Model A340-313X; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 282; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MMJ; Aircraft Manufacture Date 05 Oct 1989; Aircraft Model A310-304; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 526; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMJ; Aircraft Manufacture Date 05 Oct 1989; Aircraft Model A310-304; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 526; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MMV; Aircraft Manufacture Date 12 Aug 1987; Aircraft Model BAe 146-200; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2079; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MMV; Aircraft Manufacture Date 12 Aug 1987; Aircraft Model BAe 146-200; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2079; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNA; Aircraft Construction Number (also called L/N or S/N or F/N) 811; Aircraft Manufacture Date 18 Feb 1993; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 24383 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNA; Aircraft Construction Number (also called L/N or S/N or F/N) 811; Aircraft Manufacture Date 18 Feb 1993; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 24383; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNB; Aircraft Construction Number (also called L/N or S/N or F/N) 740; Aircraft Manufacture Date 20 Jul 1989; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 24363 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNB; Aircraft Construction Number (also called L/N or S/N or F/N) 740; Aircraft Manufacture Date 20 Jul 1989; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 24363; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNC; Aircraft Construction Number (also called L/N or S/N or F/N) 973; Aircraft Manufacture Date 12 Apr 1993; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 26879 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNC; Aircraft Construction Number (also called L/N or S/N or F/N) 973; Aircraft Manufacture Date 12 Apr 1993; Aircraft Model B.747-422; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 26879; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNE; Aircraft Construction Number (also called L/N or S/N or F/N) 641; Aircraft Manufacture Date 14 Apr 1986; Aircraft Model B747-3B3; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 23480 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNE; Aircraft Construction Number (also called L/N or S/N or F/N) 641; Aircraft Manufacture Date 14 Apr 1986; Aircraft Model B747-3B3; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 23480; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNF; Aircraft Manufacture Date 07 Aug 1990; Aircraft Model A310-304; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 547; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MNF; Aircraft Manufacture Date 07 Aug 1990; Aircraft Model A310-304; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 547; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNG; Aircraft Construction Number (also called L/N or S/N or F/N) 401; Aircraft Manufacture Date 02 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNG; Aircraft Construction Number (also called L/N or S/N or F/N) 401; Aircraft Manufacture Date 02 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNH; Aircraft Construction Number (also called L/N or S/N or F/N) 405; Aircraft Manufacture Date 03 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNH; Aircraft Construction Number (also called L/N or S/N or F/N) 405; Aircraft Manufacture Date 03 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNI; Aircraft Construction Number (also called L/N or S/N or F/N) 408; Aircraft Manufacture Date 23 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNI; Aircraft Construction Number (also called L/N or S/N or F/N) 408; Aircraft Manufacture Date 23 Feb 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNJ; Aircraft Construction Number (also called L/N or S/N or F/N) 380; Aircraft Manufacture Date 31 Dec 1986; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNJ; Aircraft Construction Number (also called L/N or S/N or F/N) 380; Aircraft Manufacture Date 31 Dec 1986; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNK; Aircraft Construction Number (also called L/N or S/N or F/N) 618; Aircraft Manufacture Date 04 Sep 1991; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNK; Aircraft Construction Number (also called L/N or S/N or F/N) 618; Aircraft Manufacture Date 04 Sep 1991; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNL; Aircraft Construction Number (also called L/N or S/N or F/N) 623; Aircraft Manufacture Date 23 Oct 1991; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNL; Aircraft Construction Number (also called L/N or S/N or F/N) 623; Aircraft Manufacture Date 23 Oct 1991; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNM; Aircraft Construction Number (also called L/N or S/N or F/N) 773; Aircraft Manufacture Date 13 Nov 1986; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNM; Aircraft Construction Number (also called L/N or S/N or F/N) 773; Aircraft Manufacture Date 13 Nov 1986; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNN; Aircraft Construction Number (also called L/N or S/N or F/N) 701; Aircraft Manufacture Date 17 May 1993; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNN; Aircraft Construction Number (also called L/N or S/N or F/N) 701; Aircraft Manufacture Date 17 May 1993; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNO; Aircraft Construction Number (also called L/N or S/N or F/N) 595; Aircraft Manufacture Date 30 Aug 1991; Aircraft Model A310-308; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNO; Aircraft Construction Number (also called L/N or S/N or F/N) 595; Aircraft Manufacture Date 30 Aug 1991; Aircraft Model A310-308; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNP; Aircraft Construction Number (also called L/N or S/N or F/N) 620; Aircraft Manufacture Date 08 Nov 1991; Aircraft Model A310-308; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNP; Aircraft Construction Number (also called L/N or S/N or F/N) 620; Aircraft Manufacture Date 08 Nov 1991; Aircraft Model A310-308; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNQ; Aircraft Construction Number (also called L/N or S/N or F/N) 553; Aircraft Manufacture Date 08 Dec 1989; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNQ; Aircraft Construction Number (also called L/N or S/N or F/N) 553; Aircraft Manufacture Date 08 Dec 1989; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNR; Aircraft Construction Number (also called L/N or S/N or F/N) 411; Aircraft Manufacture Date 27 Mar 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNR; Aircraft Construction Number (also called L/N or S/N or F/N) 411; Aircraft Manufacture Date 27 Mar 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNS; Aircraft Construction Number (also called L/N or S/N or F/N) 414; Aircraft Manufacture Date 17 Apr 1987; Aircraft Model A300B4-603; alt. Aircraft Model MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNS; Aircraft Construction Number (also called L/N or S/N or F/N) 414; Aircraft Manufacture Date 17 Apr 1987; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNT; Aircraft Construction Number (also called L/N or S/N or F/N) 546; Aircraft Manufacture Date 06 Nov 1989; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNT; Aircraft Construction Number (also called L/N or S/N or F/N) 546; Aircraft Manufacture Date 06 Nov 1989; Aircraft Model A300B4-603; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNU; Aircraft Construction Number (also called L/N or S/N or F/N) 608; Aircraft Manufacture Date 10 Apr 1991; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNU; Aircraft Construction Number (also called L/N or S/N or F/N) 608; Aircraft Manufacture Date 10 Apr 1991; Aircraft Model A300B4-605R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNV; Aircraft Construction Number (also called L/N or S/N or F/N) 567; Aircraft Manufacture Date 03 Jan 1991; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNV; Aircraft Construction Number (also called L/N or S/N or F/N) 567; Aircraft Manufacture Date 03 Jan 1991; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MNX; Aircraft Construction Number (also called L/N or S/N or F/N) 564; Aircraft Manufacture Date 22 Nov 1990; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MNX; Aircraft Construction Number (also called L/N or S/N or F/N) 564; Aircraft Manufacture Date 22 Nov 1990; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOA; Aircraft Construction Number (also called L/N or S/N or F/N) 216; Aircraft Manufacture Date 18 Feb 1993; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3216 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOA; Aircraft Construction Number (also called L/N or S/N or F/N) 216; Aircraft Manufacture Date 18 Feb 1993; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3216; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOB; Aircraft Construction Number (also called L/N or S/N or F/N) 212; Aircraft Manufacture Date 31 Jul 1992; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3212 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOB; Aircraft Construction Number (also called L/N or S/N or F/N) 212; Aircraft Manufacture Date 31 Jul 1992; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3212; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOC; Aircraft Construction Number (also called L/N or S/N or F/N) 158; Aircraft Manufacture Date 18 May 1990; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3158 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOC; Aircraft Construction Number (also called L/N or S/N or F/N) 158; Aircraft Manufacture Date 18 May 1990; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3158; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOD; Aircraft Manufacture Date 12 Nov 1990; Aircraft Model BAe 146-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3162; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOD; Aircraft Manufacture Date 12 Nov 1990; Aircraft Model BAe 146-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3162; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOE; Aircraft Construction Number (also called L/N or S/N or F/N) 129; Aircraft Manufacture Date 24 May 1989; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3129 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOE; Aircraft Construction Number (also called L/N or S/N or F/N) 129; Aircraft Manufacture Date 24 May 1989; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3129; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOF; Aircraft Construction Number (also called L/N or S/N or F/N) 149; Aircraft Manufacture Date 19 Dec 1989; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3149 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOF; Aircraft Construction Number (also called L/N or S/N or F/N) 149; Aircraft Manufacture Date 19 Dec 1989; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3149; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOG; Aircraft Construction Number (also called L/N or S/N or F/N) 165; Aircraft Manufacture Date 12 May 1990; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3165 (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-MOG; Aircraft Construction Number (also called L/N or S/N or F/N) 165; Aircraft Manufacture Date 12 May 1990; Aircraft Model B.146-300; Aircraft Operator MAHAN AIR; Aircraft Manufacturer’s Serial Number (MSN) 3165; Additional Sanctions Information – Subject to Secondary Sanctions(aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOM; Aircraft Manufacture Date 12 May 1990; Aircraft Model BAe 146-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3165; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOM; Aircraft Manufacture Date 12 May 1990; Aircraft Model BAe 146-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3165; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOP; Aircraft Manufacture Date 14 Mar 1995; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2257; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOP; Aircraft Manufacture Date 14 Mar 1995; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2257; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOQ; Aircraft Manufacture Date 24 Mar 1995; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2261; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOQ; Aircraft Manufacture Date 24 Mar 1995; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2261; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOR; Aircraft Manufacture Date 20 Nov 2001; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2392; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOR; Aircraft Manufacture Date 20 Nov 2001; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2392; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-MOS; Aircraft Manufacture Date 15 Mar 1999; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2347; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- EP-MOS; Aircraft Manufacture Date 15 Mar 1999; Aircraft Model BAe RJ85; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 2347; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EP-VIP; Aircraft Construction Number (also called L/N or S/N or F/N) 499; Aircraft Manufacture Date 20 Apr 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EP-VIP; Aircraft Construction Number (also called L/N or S/N or F/N) 499; Aircraft Manufacture Date 20 Apr 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EX-301; Aircraft Construction Number (also called L/N or S/N or F/N) 524; Aircraft Manufacture Date 27 Sep 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EX-301; Aircraft Construction Number (also called L/N or S/N or F/N) 524; Aircraft Manufacture Date 27 Sep 1989; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

EX-35011; Aircraft Construction Number (also called L/N or S/N or F/N) 838; Aircraft Manufacture Date 28 Aug 2002; Aircraft Model A300B4-622R; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- EX-35011; Aircraft Construction Number (also called L/N or S/N or F/N) 838; Aircraft Manufacture Date 28 Aug 2002; Aircraft Model A300B4-622R; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

F-OJHH; Aircraft Construction Number (also called L/N or S/N or F/N) 586; Aircraft Manufacture Date 29 Mar 1991; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- F-OJHH; Aircraft Construction Number (also called L/N or S/N or F/N) 586; Aircraft Manufacture Date 29 Mar 1991; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

F-OJHI; Aircraft Construction Number (also called L/N or S/N or F/N) 537; Aircraft Manufacture Date 19 Jan 1990; Aircraft Model A310-304; Aircraft Operator MAHAN AIR (aircraft) [SDGT] (Linked To: MAHAN AIR). -to- F-OJHI; Aircraft Construction Number (also called L/N or S/N or F/N) 537; Aircraft Manufacture Date 19 Jan 1990; Aircraft Model A310-304; Aircraft Operator MAHAN AIR; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

MAHAN AIR (a.k.a. MAHAN AIR CO.), No. 21, Mahan Air Tower, Azadegan Street, Jenah Expressway, Beginning of Sheykh Fazlollah Exp. Way, First of Karaj High Way, Tehran, Tehran 1481655761, Iran; Mahan Air Tower, 21st Floor, Azadeghan Street, Karaj Highway, P.O. Box 14515-411, Tehran, Tehran, Iran; Mahan Air Tower, Azadegan St., Karaj Highway, P.O. Box 411-14515, Tehran, Tehran 1481655761, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [IFSR]. -to- MAHAN AIR (a.k.a. MAHAN AIR CO.), No. 21, Mahan Air Tower, Azadegan Street, Jenah Expressway, Beginning of Sheykh Fazlollah Exp. Way, First of Karaj High Way, Tehran, Tehran 1481655761, Iran; Mahan Air Tower, 21st Floor, Azadeghan Street, Karaj Highway, P.O. Box 14515-411, Tehran, Tehran, Iran; Mahan Air Tower, Azadegan St., Karaj Highway, P.O. Box 411-14515, Tehran, Tehran 1481655761, Iran; Additional Sanctions Information – Subject to Secondary Sanctions [SDGT] [NPWMD] [IFSR]. 

 

MSN 164; Aircraft Manufacture Date 1997; Aircraft Model Airbus A340-313X; Previous Aircraft Tail Number G-VAIR; Aircraft Manufacturer’s Serial Number (MSN) 164; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 164; Aircraft Manufacture Date 1997; Aircraft Model Airbus A340-313X; Previous Aircraft Tail Number G-VAIR; Aircraft Manufacturer’s Serial Number (MSN) 164; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

MSN 371; Aircraft Manufacture Date 2001; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAC; Aircraft Manufacturer’s Serial Number (MSN) 371; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 371; Aircraft Manufacture Date 2001; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAC; Aircraft Manufacturer’s Serial Number (MSN) 371; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

MSN 376; Aircraft Manufacture Date 2001; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAB; Aircraft Manufacturer’s Serial Number (MSN) 376; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 376; Aircraft Manufacture Date 2001; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAB; Aircraft Manufacturer’s Serial Number (MSN) 376; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

MSN 383; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAA; Aircraft Manufacturer’s Serial Number (MSN) 383; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 383; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAA; Aircraft Manufacturer’s Serial Number (MSN) 383; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

MSN 391; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Aircraft Manufacturer’s Serial Number (MSN) 391; Aircraft Tail Number EP-MMH; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 391; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Aircraft Manufacturer’s Serial Number (MSN) 391; Aircraft Tail Number EP-MMH; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

MSN 416; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAD; Aircraft Manufacturer’s Serial Number (MSN) 416; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 416; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAD; Aircraft Manufacturer’s Serial Number (MSN) 416; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

MSN 449; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAE; Aircraft Manufacturer’s Serial Number (MSN) 449; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 449; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number YI-NAE; Aircraft Manufacturer’s Serial Number (MSN) 449; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

MSN 550; Aircraft Manufacture Date 1995; Aircraft Model Airbus A321-131; Previous Aircraft Tail Number 2-WGLP; Aircraft Manufacturer’s Serial Number (MSN) 550; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 550; Aircraft Manufacture Date 1995; Aircraft Model Airbus A321-131; Previous Aircraft Tail Number 2-WGLP; Aircraft Manufacturer’s Serial Number (MSN) 550; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

MSN 615; Aircraft Manufacture Date 2004; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number G-VSSH; Aircraft Manufacturer’s Serial Number (MSN) 615; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). -to- MSN 615; Aircraft Manufacture Date 2004; Aircraft Model Airbus A340-642; Previous Aircraft Tail Number G-VSSH; Aircraft Manufacturer’s Serial Number (MSN) 615; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR). 

 

UR-CJW; Aircraft Construction Number (also called L/N or S/N or F/N) 358; Aircraft Manufacture Date 12 Sep 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Manufacturer’s Serial Number (MSN) 3358 (aircraft) [SDGT] [IFSR]. -to- UR-CJW; Aircraft Construction Number (also called L/N or S/N or F/N) 358; Aircraft Manufacture Date 12 Sep 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Manufacturer’s Serial Number (MSN) 3358; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR]. 

 

UR-CKF; Aircraft Construction Number (also called L/N or S/N or F/N) 341; Aircraft Manufacture Date 20 Dec 1998; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3341 (aircraft) [SDGT] [IFSR]. -to- UR-CKF; Aircraft Construction Number (also called L/N or S/N or F/N) 341; Aircraft Manufacture Date 20 Dec 1998; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3341; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR]. 

 

UR-CKG; Aircraft Construction Number (also called L/N or S/N or F/N) 362; Aircraft Manufacture Date 16 Nov 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3362 (aircraft) [SDGT] [IFSR]. -to- UR-CKG; Aircraft Construction Number (also called L/N or S/N or F/N) 362; Aircraft Manufacture Date 16 Nov 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3362; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR]. 

 

UR-CKJ; Aircraft Construction Number (also called L/N or S/N or F/N) 343; Aircraft Manufacture Date 04 Sep 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3343 (aircraft) [SDGT] [IFSR]. -to- UR-CKJ; Aircraft Construction Number (also called L/N or S/N or F/N) 343; Aircraft Manufacture Date 04 Sep 1999; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3343; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR]. 

 

UR-CKY; Aircraft Construction Number (also called L/N or S/N or F/N) 146; Aircraft Manufacture Date 08 Jan 1990; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3146 (aircraft) [SDGT] [IFSR]. -to- UR-CKY; Aircraft Construction Number (also called L/N or S/N or F/N) 146; Aircraft Manufacture Date 08 Jan 1990; Aircraft Model BAe-146 Avro RJ100; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 3146; Additional Sanctions Information – Subject to Secondary Sanctions (aircraft) [SDGT] [NPWMD] [IFSR].

And, finally, it issued the following 2 new Frequently Asked Questions (FAQs):

810. On December 11, 2019, the State Department announced that it would designate the Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping Limited (“E-Sail”) under Executive Order (E.O.) 13382, effective June 8, 2020. IRISL and E-Sail are already listed on the SDN List. What will be the impact of the State Department’s designation of these entities under E.O. 13382?

On November 5, 2018, OFAC identified IRISL and E-Sail on the SDN List with the [IRAN] tag to indicate that they are entities meeting the definition of the Government of Iran whose property and interests in property are blocked pursuant to E.O. 13599.

Following their designation by the State Department under E.O. 13382 on June 8, 2020, OFAC will add the [NPWMD] and [IFSR] tags to the entries for IRISL and E-Sail on the SDN List. As a result, transactions by U.S. persons or within (or transiting) the United States involving IRISL and E-Sail will be subject to the prohibitions in the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544 (WMDPSR), in addition to the prohibitions in E.O. 13599 implemented through the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Non-U.S. persons that knowingly engage in certain transactions with IRISL or E-Sail risk exposure to sanctions under additional authorities. [12-11-2019]


811. Can I ship agricultural commodities, food, medicine, and medical devices to Iran via IRISL or E-Sail on or after June 8, 2020?

The United States maintains broad authorizations and exceptions under U.S. sanctions that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran by U.S. and non-U.S. persons (see, e.g., FAQ 637). However, these authorizations and exceptions generally do not apply to transactions with persons designated pursuant to E.O. 13382.

Following the designations of IRISL and E-Sail under E.O. 13382 on June 8, 2020, transactions by U.S. persons involving IRISL or E-Sail will be subject to the prohibitions in the WMDPSR, in addition to the prohibitions in the ITSR. This means that, effective June 8, 2020, unless authorized under the WMDPSR or exempt, U.S. persons will be prohibited from engaging in transactions involving IRISL or E-Sail, including transactions for the sale of agricultural commodities, food, medicine, or medical devices by U.S. persons or from the United States that are authorized under the general licenses set forth in, or specifically licensed pursuant to, sections 560.530, 560.532, or 560.533 of the ITSR.

In addition, non-U.S. persons that knowingly engage in certain transactions with IRISL or E-Sail, even for the sale to Iran of agricultural commodities, food, medicine, or medical devices, risk exposure to sanctions under additional authorities.

To avoid sanctions risks, U.S. and non-U.S. persons should ensure that transactions for the sale of agricultural commodities, food, medicine, or medical devices involving IRISL or E-Sail are concluded no later than June 8, 2020, when the designations of IRISL and E-Sail pursuant to E.O. 13382 come into effect. [12-11-2019]

Personally, Mr. Watchlist would like more detail on FAQ 810 – what does “risk exposure under additional authorities” mean in a practical sense?

Links:

OFAC Notice

New FAQs

On Monday, OFAC added the following 2 Frequently Asked Questions (FAQs) under its Venezuela sanctions program:

808. Do I need a specific license from OFAC to file a suit in U.S. court against a person designated or blocked pursuant to Venezuela-related sanctions? Does a U.S. court, or its personnel, need a specific license from OFAC to hear such a case?

No. A specific license from OFAC is not ordinarily required to initiate or continue U.S. legal proceedings against a person designated or blocked pursuant to OFAC’s Venezuela sanctions program, or for a U.S. court, or its personnel, to hear such a case. However, a specific license from OFAC is required for the entry into a settlement agreement or the enforcement of any lien, judgment, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property blocked pursuant to the Venezuela Sanctions Regulations (31 C.F.R. Part 591). This includes the purported creation or perfection of any legal or equitable interests (including contingent or inchoate interests) in blocked property. While terminology may vary in different jurisdictions and proceedings, a specific license from OFAC would be required for measures such as:

•Taking Possession (Actual or Constructive)

•Seizing

•Levying Upon

•Attaching 

•Encumbering 

•Pledging

•Conveying

•Selling (Final or Contingent)

•Freezing 

•Assuming or Maintaining Custody

•Sequestering

For additional information, see 31 C.F.R. §§ 591.309, 591.310, 591.407 and 591.506. [12-09-2019]


809. I hold a writ of attachment on shares of a Government of Venezuela entity whose property and interests in property are blocked pursuant to the Venezuela Sanctions Regulations. Am I authorized to prepare for and hold an auction or other sale of the shares, contingent upon the winning bidder obtaining a license from OFAC?

No. Parties who have attached shares of an entity whose property and interests in property are blocked pursuant to the Venezuela Sanctions Regulations (31 C.F.R. Part 591) must obtain a specific license from OFAC prior to conducting an auction or other sale, including a contingent auction or other sale, or taking other concrete steps in furtherance of an auction or sale. More generally, OFAC urges caution in proceeding with any step in furtherance of measures which might alter or affect blocked property or interests in blocked property. OFAC would consider license applications seeking to authorize such activities on a case-by-case basis. For additional information, see 31 C.F.R. §§ 591.309, 591.310, 591.407 and 591.506. [12-09-2019]

Link:

OFAC Notice

New FAQs

Last Wednesday, OFAC updated Frequently Asked Question (FAQ) #303:

303. Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA’s section 1246(a)(1)? 

A number of insurance activities are subject to sanctions under IFCA, including knowingly providing insurance, reinsurance, or underwriting services to or for Iranian persons on the SDN List to or for any person designated in connection with Iran’s support for international terrorism or WMD proliferation, or for activities with respect to Iran for which sanctions have been imposed (e.g., knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran). However, the provision of insurance, reinsurance, or underwriting services to non-Iranian persons on the SDN List is generally not sanctionable under section 1246(a)(1) of IFCA if the provision of insurance, reinsurance or underwriting services is not to or for an Iranian person on the SDN List, to or for any person designated in connection with Iran’s support for international terrorism or WMD proliferation, or for any activity with respect to Iran for which sanctions have been imposed. [11-27-2019]

and FAQ 804:

804. Do sanctions on COSCO Shipping Tanker (Dalian) Co. and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. apply to their corporate parent and affiliates?

COSCO Shipping Tanker (Dalian) Co. and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. were determined by the Secretary of State on September 25, 2019, to meet the criteria for the imposition of sanctions under Executive Order (E.O.) 13846, and the Secretary of State imposed certain sanctions, including blocking, on these entities. The blocking sanctions apply only to these listed entities and any entities in which they own, individually or in the aggregate, a 50 percent or greater interest. Sanctions do not apply to these entities’ ultimate parent, COSCO Shipping Corporation Ltd. (COSCO). Similarly, sanctions do not apply to COSCO’s other subsidiaries or affiliates (e.g., COSCO Shipping Holdings), provided that such entities are not owned 50 percent or more in the aggregate by one or more blocked persons. U.S. persons, therefore, are not prohibited from dealing with COSCO, its non-blocked subsidiaries, or non-blocked affiliates to the extent the proposed dealings do not involve any blocked person, or any other activities prohibited pursuant to any OFAC sanctions authorities.

In addition, on October 24, 2019, OFAC issued General License K that authorizes through its expiration date all transactions and activities prohibited pursuant to section 5 of E.O. 13846 that are ordinarily incident and necessary to the maintenance or wind down of transactions involving COSCO Shipping Tanker (Dalian) Co., subject to certain conditions specified in the license and described in FAQ 806. 

With respect to transactions involving non U.S. persons outside of U.S. jurisdiction, please see FAQ 805. [11-27-2019]

and added three new ones:

805. Are non-U.S. persons exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846?

No, non-U.S. persons are generally not exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846. 

However, please note that non-U.S. persons should ensure that the provision of goods or services to, or other transactions with such non-Iranian persons do not involve: (1) prohibited transactions by U.S. persons (including U.S. financial institutions) or U.S.-owned or -controlled foreign entities, unless the transaction is exempt from regulation, or authorized by OFAC; (2) the knowing provision of significant support to an Iranian person on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List); or (3) the knowing facilitation of a significant transaction for a person on the SDN List that has been designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, including designated Iranian financial institutions or the Islamic Revolutionary Guard Corps (IRGC), or other activity for which sanctions have been imposed with respect to Iran (e.g., knowingly engaging in a significant transaction for the purchase of petroleum from Iran). 

For information about persons sanctioned by State Department pursuant to Section 3 of E.O. 13846, please see the relevant State press statement or Federal Register Notice. [11-27-2019] 


806. What types of activities are considered “maintenance” as the term is used in General License K?

As a general matter, the authorization for “maintenance” in General License K includes all transactions ordinarily incident to the continuity of operations by U.S. persons involving COSCO Shipping Tanker (Dalian) Co., Ltd. or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Co., Ltd., other than COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. (hereinafter, “General License K Covered Entities”). Additionally, for the purposes of General License K, the authorization for “maintenance” generally includes all transactions and activities ordinarily incident to performing under a contract or agreement in effect prior to September 25, 2019, provided that the level of performance is consistent with the terms of the general license and consistent with past practices that existed between the party and the General License K Covered Entities prior to September 25, 2019. Notwithstanding the absence of a contract or agreement in effect prior to September 25, 2019, the authorization for “maintenance” also generally includes all transactions and activities ordinarily incident to obtaining goods or services from, or providing goods or services to, General License K Covered Entities in a manner consistent with the terms of the general license and consistent with past practices that existed between the party, or any intermediary party, and the General License K Covered Entities prior to September 25, 2019. OFAC will consider the transaction history between the party, or any intermediary party, and the General License K Covered Entities prior to September 25, 2019 in assessing whether activity is consistent with past practices. The authorization for “maintenance” also generally includes authorization to enter into contingent contracts for transactions and activities consistent with the above, extending beyond the current expiration of General License K where any performance after the expiration of the general license is contingent on such performance either not being prohibited or being authorized by OFAC. 

For example, transactions and activities authorized by General License K could include issuing or accepting purchase orders (including for sales of fuel to General License K Entities) and making or receiving shipments (including undertaking new charters or voyages) that were initiated after September 25, 2019 involving General License K Entities, if such activity is ordinarily incident and necessary to contracts in effect prior to September 25, 2019 (provided the purchase and shipment amounts are consistent with past practices, as demonstrated by transaction history). Similarly, transactions and activities that are not within the framework of a preexisting agreement may be considered “maintenance” if such activity is consistent with the transaction history between the person and General License K Entities prior to September 25, 2019. Conversely, General License K would not authorize purchase orders and shipments involving the General License K Entities where there was no preexisting relationship between a person and a blocked entity or where the contemplated activity exceeds past practices that existed between the party and the General License K Entities prior to September 25, 2019 as demonstrated by transaction history. Stockpiling inventory, for example, would not be authorized unless transaction history indicates that the scope and extent of maintaining inventory is consistent with past practice. [11-27-2019] 


807. Can U.S. financial institutions process transactions involving COSCO Shipping Tanker (Dalian) Co., Ltd. under Iran General License K if the U.S. financial institution is the only U.S. person involved in the transaction?

Yes, provided the transaction is ordinarily incident and necessary to the maintenance or wind down of transactions involving, directly or indirectly, COSCO Shipping Tanker (Dalian) Co., Ltd., or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Co., Ltd., including any transaction or dealing in property or interests in property of the foregoing, subject to the conditions and expiration dates noted in Iran General License K. However, please note that Iran General License K does not authorize any transactions involving COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. 

Please note that absent knowledge or a reason to know that the transaction is not authorized by Iran General License K, OFAC would not expect the intermediary U.S. financial institution to conduct additional due diligence beyond the information collected in the ordinary course of processing such transactions, and accordingly, in the event of a potential violation, OFAC would consider the totality of the facts and circumstances in determining the appropriate administrative enforcement response, if any. 

Please see FAQ 116 for additional guidance on due diligence for U.S. financial institutions serving as intermediaries within a transaction. [11-27-2019] 

Links:

OFAC Notice

FAQ 303

FAQ 804

New FAQs

FINTRAC updates its Methods to verify the identity of an individual and confirm the existence of a corporation or an entity other than a corporation guidance 

After consulting and working closely with businesses, FINTRAC has updated its guidance on Methods to verify the identity of an individual and confirm the existence of a corporation or an entity other than a corporation. The updated guidance reflects amendments to theProceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR) that came into force on June 25, 2019, and the feedback we received from Canadian businesses which helped us create a better product.

Specifically, government-issued photo identification documents used to verify the identity of an individual must be ‘authentic, valid and current’ instead of ‘original, valid and current’ as it was previously; and the prohibition on the use of electronic images as sources of information has been lifted.

This change provides greater flexibility to businesses to effectively comply with PCMLTFA requirements by allowing for the use of new technologies to verify identity and authenticate documents.

Additionally, FINTRAC has also made a slight change to Guideline 5. Terrorist group and Listed person lists can now be found:

·         on Public Safety Canada’s website.

·         in the Schedule of the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism.

FINTRAC is committed to working with businesses to increase their awareness and understanding of their compliance obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and to reducing the associated administrative burden where possible.

Sorry about this – about those OFAC changes to the Venezuela program I just posted? Well, OFAC also issued a new Frequently Asked Question (FAQ):

803. What types of activity does General License 35 authorize? 

U.S. persons are authorized to engage in certain administrative transactions with the Government of Venezuela that are prohibited by E.O. 13884 of August 5, 2019, where such transactions are necessary and ordinarily incident to such persons’ day-to-day operations.  General License 35 authorizes U.S. persons to pay taxes, fees, and import duties to the Government of Venezuela, and to purchase or receive permits, licenses, registrations, certifications, and public utility services from the Government of Venezuela, so long as these transactions are necessary and ordinarily incident to such persons’ day-to-day operations.  

U.S. persons should remain cautious when engaging in authorized activity with blocked persons to ensure all criteria for use of the general license are met.  The illegitimate former Maduro regime has a long history of corruption, and we encourage U.S. persons who rely on the authorization in General License 35 to exercise appropriate due diligence to ensure compliance with the terms of the authorization.  The U.S. government will continue to target corruption by the illegitimate former Maduro regime.  As with any general or specific license, OFAC is prepared to revoke this authorization if appropriate to support U.S. foreign policy and national security priorities. [11-05-2019]

and an amended one, too:

680. Does the blocking of the Government of Venezuela impact the ability of U.S. persons to transact with the Government of Venezuela, or persons in which the Government of Venezuela owns, directly or indirectly, a 50 percent or greater interest? 


Yes. Unless exempt or authorized by OFAC, all property and interests in property of persons meeting the definition of the Government of Venezuela  (see section 6(d) of E.O. 13884 of August 5, 2019) that are in, or come within, the United States or the possession or control of a United States person are blocked, pursuant to E.O. 13884.  The term “Government of Venezuela,” as defined in E.O. 13884, includes the state and Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petroleos de Venezuela, S.A. (PdVSA), any person owned or controlled, directly or indirectly, by the foregoing, and any person who has acted or purported to act directly or indirectly for or on behalf of, any of the foregoing, including as a member of the Maduro regime.


OFAC has issued several General Licenses (GLs) that provide authorization for categories of persons blocked by E.O. 13884.  GL 34A authorizes transactions with certain Government of Venezuela individuals, including United States citizens; permanent resident aliens of the United States; individuals who have a valid U.S. immigrant or nonimmigrant visa, other than individuals in the United States as part of Venezuela’s mission to the United Nations; former employees and contractors of the Government of Venezuela; and current employees and contractors of the Government of Venezuela who provide health or education services in Venezuela, including at hospitals, schools, and universities.  In addition, GL 22 authorizes certain transactions related to Venezuela’s mission to the United Nations, and GL 31 provides authorization related to the Government of the Interim President of Venezuela.

Without authorization from OFAC, U.S. persons are generally prohibited from engaging in transactions with the Government of Venezuela, or persons in which the Government of Venezuela owns, directly or indirectly, a 50 percent or greater interest. U.S. persons are not prohibited from engaging in transactions involving the country or people of Venezuela, provided blocked persons or any conduct prohibited by any other Executive order imposing sanctions measures related to the situation in Venezuela, are not involved.

Please note that persons meeting the definition of Government of Venezuela and persons that are owned, directly or indirectly, 50 percent or more by the Government of Venezuela are blocked pursuant to E.O. 13884, regardless of whether the person appears on the Specially Designated Nationals and Blocked Persons list (SDN List), unless exempt or authorized by OFAC.

As a general matter, OFAC expects financial institutions to conduct due diligence on their own direct customers (including, for example, their ownership structure) to confirm that those customers are not persons whose property and interests in property are blocked.  With regard to other types of transactions where a financial institution is acting solely as an intermediary and fails to block transactions involving a sanctions target, OFAC will consider the totality of the circumstances surrounding the bank’s processing of the transaction to determine what, if any, regulatory response is appropriate. [11-05-2019]

Links:

New FAQs

Amended FAQs

On Friday, Treasury imposed Special Measure 5 (i.e. no correspondent banking accounts allowed) on Iran, but announced how Iran could still get humanitarian assistance:

PRESS RELEASES

Treasury and State Announce New Humanitarian Mechanism to Increase Transparency of Permissible Trade Supporting the Iranian People

FinCEN identifies Iran as jurisdiction of primary money laundering concern

WASHINGTON – Today, the U.S. Departments of the Treasury and State announced a new humanitarian mechanism to ensure unprecedented transparency into humanitarian trade with Iran.  This mechanism will help the international community perform enhanced due diligence on humanitarian trade to ensure that funds associated with permissible trade in support of the Iranian people are not diverted by the Iranian regime to develop ballistic missiles, support terrorism, or finance other malign activities.  Concurrently, Treasury’s Financial Crimes Enforcement Network (FinCEN) identified Iran as a jurisdiction of primary money laundering concern under Section 311 of the USA PATRIOT Act, and issued a new rulemaking to protect the U.S. financial system from malign Iranian financial activities.  

“This administration remains committed to the unfettered flow of humanitarian aid to the Iranian people, who have suffered for forty years under the mismanagement of this corrupt regime. This new humanitarian mechanism will help international companies that seek to engage in permissible humanitarian trade with Iran to ensure that they do not run afoul of sanctions,” said Treasury Secretary Steven T. Mnuchin.  “Iran is a jurisdiction of primary money laundering concern that deliberately ensures that there is no transparency in their economy so they can export terrorism around the world.  FinCEN’s action further exposes the characteristics of Iran’s deceptive financial conduct to the international community as part of our maximum pressure campaign to shut off the Iranian regime’s illicit sources of revenue.”

PROCESS FOR NEW HUMANITARIAN MECHANISM

Treasury and State will establish a process to help ensure that participating governments and financial institutions commit to conducting enhanced due diligence to mitigate the higher risks associated with Iran-related transactions.  A stringent framework is crucial given that Iran continues to be the world’s largest state sponsor of terrorism and the regime continues to fail to implement key anti-money laundering and countering the financing of terror (AML/CFT) safeguards, as set by the Financial Action Task Force (FATF), the global standard-setting body for combating money laundering and terrorist financing.

“FinCEN’s action designating Iran as a jurisdiction of primary money laundering concern underscores the need for enhanced due diligence in a country that has systematically obfuscated its support for terrorism and ignored international anti-money laundering standards.  This humanitarian mechanism offers a process for enhanced due diligence to help mitigate the high risk of doing business in a country whose repressive leaders remain intent on diverting resources to fund terrorism,” said Sigal Mandelker, Treasury Under Secretary for Terrorism and Financial Intelligence. “Through this new mechanism, no revenue or payment may flow to the Iranian regime. This framework will provide unprecedented transparency to help ensure that humanitarian goods entering Iran actually reach the Iranian people.”

“The Iranian regime oversees a vast network of corruption designed to evade sanctions, generate money for terrorists, and enrich Iran’s clerics,” said Brian Hook, State Department Special Envoy to Iran. “A new humanitarian channel will make it easier for foreign governments, financial institutions, and private companies to engage in legitimate humanitarian trade on behalf of the Iranian people while reducing the risk that money ends up in the wrong hands. The U.S. will continue to stand with the Iranian people.”

While the U.S. has consistently maintained broad exceptions and authorizations to support humanitarian transactions with Iran, this new mechanism will assist foreign governments and foreign financial institutions that conduct appropriate enhanced due diligence to establish payment mechanisms for legitimate humanitarian exports.

The humanitarian mechanism will require foreign governments and financial institutions that choose to participate in the mechanism to conduct enhanced due diligence and provide to Treasury a substantial and unprecedented amount of information, with appropriate disclosure and use restrictions, on a monthly basis, as described in guidance provided by OFAC outlining specific requirements.

This mechanism includes a number of safeguards to prevent any sanctionable dealings with persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) that have been designated in connection with Iran’s support for terrorism or WMD proliferation.

If foreign governments or financial institutions detect potential abuse of this mechanism, pursuant to the requirements of the humanitarian mechanism, they must immediately restrict any suspicious transactions and provide relevant information to Treasury.  Provided that financial institutions commit to implement these stringent requirements, the humanitarian mechanism will enable them to seek written confirmation from Treasury and State regarding sanctions compliance.

This mechanism, designed solely for the purpose of commercial exports of humanitarian goods to Iran, can be used by U.S. persons and U.S.-owned or -controlled foreign entities, as well as non-U.S. entities.  Of course, U.S. persons and U.S.-owned or -controlled entities must still comply with existing requirements under the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), as implemented in OFAC’s regulations. In line with the United States’ long standing policy of allowing for the sale of agricultural commodities, food, medicine, and medical devices to Iran, OFAC will also continue to consider other requests related to humanitarian trade with Iran as appropriate. Treasury encourages interested parties to reach out to OFAC for more detailed consultations. 

IMPLICATIONS OF SECTION 311 ON IRANIAN FINANCIAL INSTITUTIONS

Pursuant to Section 311 of the USA PATRIOT Act, FinCEN issued a final ruleprohibiting the opening or maintaining of a correspondent account in the United States for or on behalf of an Iranian financial institution.  The rule also prohibits foreign financial institutions’ correspondent accounts at covered U.S. financial institutions from processing transactions involving Iranian financial institutions.  FinCEN based the rulemaking on its finding that Iran is a foreign jurisdiction of primary money laundering concern.

“FinCEN’s action is based on its finding that international terrorists and entities involved in missile proliferation have transacted business in Iran, and that Iran is a jurisdiction characterized by a high level of institutional corruption and weak AML/CFT laws,” said FinCEN Director Kenneth A. Blanco.  “This action seeks to protect international financial institutions from the wide range of illicit finance risks emanating from this jurisdiction.”

Section 311 of the USA PATRIOT Act authorizes FinCEN to alert U.S. financial institutions to foreign jurisdictions, foreign financial institutions, classes of transactions, or types of accounts that it finds to be of primary money laundering concern, and, if necessary, order them severed from the U.S. financial system. 

While extensive U.S. and international sanctions on Iran largely prohibit U.S. financial institutions from facilitating, directly or indirectly, transactions by Iranian financial institutions, this action requires U.S. financial institutions to apply special due diligence to their correspondent accounts to further guard against their improper indirect use by Iranian banking institutions.  It also subjects U.S. financial institutions to penalties under the Bank Secrecy Act if they violate provisions of the final rule.  Furthermore, it protects the U.S. financial system from Iran’s illicit financial activities by ensuring that U.S. financial institutions are not exposed to the Iranian regime’s support for terrorist groups, advancement of its ballistic missile program, and its fueling of armed conflicts in Syria, Afghanistan, Yemen, and elsewhere.

FinCEN’s decision to take this action as a final rule is in the interest of U.S. foreign policy and consistent with the Administrative Procedure Act.

FACTORS BEHIND FINCEN’S FINDING

The Iranian regime is the world’s leading state sponsor of terrorism, and FinCEN found evidence that international terrorist groups, including Hizballah and HAMAS, have transacted business in or with Iran and rely on Iranian financial support.  Estimates indicate that the Iranian government has historically provided approximately $700 million of Hizballah’s estimated $1 billion annual budget.  Iran’s support to HAMAS is estimated to be in the tens of millions of dollars per year and as high as $300 million per year.

FinCEN’s action builds on Treasury’s Office of Foreign Assets Control’s (OFAC) September 20, 2019 designation of the Central Bank of Iran (CBI) under its counterterrorism authority, Executive Order (E.O.) 13224, as amended by E.O. 13886.  The CBI has been intimately involved in facilitating the movement of funds to terrorist groups, and senior CBI officials, acting in their official capacity, have procured currency and conducted transactions for Iran’s Islamic Revolutionary Guard Corps Qods Force (IRGC-QF), which was designated by OFAC in connection with terrorism and human rights abuses.  As OFAC stated, in 2018 and 2019, the CBI has provided billions of dollars and euros to terrorist organizations, including the IRGC, IRGC-QF, and the IRGC-QF’s terrorist proxy, Hizballah.  The CBI has also worked to supply foreign currency and funding to the IRGC-QF and Iran’s Ministry of Defense and Armed Forces Logistics, also OFAC-designated for terrorism. 

FinCEN also found that the Iranian regime continues to engage in deceptive financial practices, such as the use of front companies and shell companies, to facilitate the advancement of its ballistic missile arsenal.  With more than ten types of ballistic missiles in its inventory or in development, some of which are inherently capable of delivering a nuclear explosive device, Iran has the largest ballistic missile program in the Middle East—a major challenge to nonproliferation efforts in the region.  

Iran has consistently been identified by non-governmental organizations as one of the most corrupt countries in the globe, and FinCEN found that institutionalized corruption in Iran is widespread in its economy.  According to FinCEN’s information, in early 2018, after hearing complaints about corruption, Iran’s Supreme Leader, Ali Husseini Khamenei, issued a directive requiring Iran’s armed forces to sell the private companies they owned. However, because Khamenei permitted the armed forces to use revenue from the sales to then purchase shares in the same companies, the directive appeared to be a gesture to placate public pressure, not a genuine effort to lessen the role of the IRGC and its components such as the Basij militia in the economy or curb corruption. Additionally, in late 2017, IRGC officials were aware of corruption and mismanagement at an IRGC economic development firm, estimating the cost of the corruption to be approximately $5.5 billion in losses, debts, and funds required for a capital injection to facilitate the firm’s dissolution.

This culture of economic corruption is further compounded by Iran’s continued failure to adequately address its AML/CFT deficiencies, as identified by the Financial Action Task Force (FATF). To protect the international financial system from abuse, the FATF has therefore re-imposed several countermeasures on Iran and called on its members and urged all jurisdictions to advise their financial institutions to apply enhanced due diligence with respect to business relationships and transactions with natural and legal persons from Iran.

And OFAC issued a guidance on “Financial Channels to Facilitate Humanitarian Trade with Iran and Related Due Diligence and Reporting Expectations”:

Financial Channels to Facilitate Humanitarian Trade with Iran and Related Due Diligence and Reporting Expectations

The U.S. Government has levied unprecedented economic pressure to disrupt the Iranian regime’s ability to covertly and illicitly access the international financial system to finance terrorism abroad, increase its domestic oppression, support the brutal Assad regime, procure ballistic missile technology, and broadly destabilize the Middle East. These U.S. government efforts are directed at the Iranian regime. They are not directed at the people of Iran, who themselves are victims of the regime’s oppression, corruption, and economic mismanagement.

The United States maintains broad exceptions and authorizations for the sale of agricultural commodities, food, medicine, and medical devices to Iran by U.S. and non-U.S. persons, provided such transactions do not involve persons designated in connection with Iran’s proliferation of weapons of mass destruction (WMD), or Iran’s support for international terrorism. These exceptions and authorizations are clearly outlined by Treasury’s Office of Foreign Assets Control (OFAC) in Frequently Asked Questions (FAQs) regarding Iran sanctions, Guidance on Humanitarian Assistance and Related Exports to the Iranian People (2013), and Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran (2013).

Unfortunately, the U.S. government has seen the Iranian regime abuse the goodwill of the international community, including by using so-called humanitarian trade to evade sanctions and fund its malign activity. The U.S. government also knows that the regime and its proxies are looking for new ways to generate funds and launder money. In fact, we have grown increasingly concerned as we have uncovered Iranian and Iranian-proxy schemes to access illicitly the international financial system under the cover of seemingly humanitarian organizations or through shell companies or exchange houses.

Today, October 25, 2019, the U.S. Departments of the Treasury and State announced a new humanitarian mechanism to ensure unprecedented transparency into humanitarian trade with Iran. Given the Iranian regime’s history of squandering its wealth on corruption and terrorism instead of supporting the Iranian people, we have developed a framework to guard against such theft and assist foreign governments and foreign financial institutions in establishing a payment mechanism to facilitate legitimate humanitarian exports to Iran. Through this mechanism, no revenue or payment of any kind will be transferred to Iran.

Importantly, this path restricts the Central Bank of Iran’s (CBI) role in facilitating humanitarian trade, which is critical because the CBI and its senior officials have facilitated significant funds transfers to terrorist organizations. Iran’s deceptive financial practices and its deficient anti-money laundering and countering the financing of terrorism (AML/CFT) regimes can make it extremely difficult to determine who is on the other end of an Iranian transaction. Our designation of CBI under Executive Order 13224 puts governments and financial institutions on notice that engaging in transactions with the CBI may make them complicit in the CBI’s support of terrorism.

This mechanism, designed solely for the purpose of commercial exports of agricultural commodities, food, medicine, and medical devices to Iran, will provide unprecedented transparency into humanitarian trade to Iran and help ensure that humanitarian goods go to the Iranian people, and are not diverted by the Iranian regime to fund its nefarious purposes. To achieve this transparency, participating governments and financial institutions must commit to conducting enhanced due diligence to mitigate the higher risks associated with transactions involving Iran. Such stringency is merited given Iran’s status as the largest state sponsor of terrorism, as well as its continued failure to implement key AML/CFT safeguards established by the Financial Action Task Force (FATF), the global standard-setting body for combating money laundering and the financing of terrorism and proliferation. The enhanced due diligence requirements are informed by appropriate FATF standards.

As set forth below in greater detail, this framework will enable foreign governments and foreign financial institutions to seek written confirmation from Treasury that the proposed financial channel will not be exposed to U.S. sanctions in exchange for foreign governments and financial institutions committing to provide to Treasury robust information on the use of this mechanism on a monthly basis.

If foreign governments or financial institutions detect any potential abuse of this mechanism by Iranian customers, or the involvement of designated individuals or entities, they will be required to immediately restrict any suspicious transactions and provide relevant information to Treasury.

This mechanism also can be used by U.S. persons and U.S.-owned or -controlled foreign entities, as well as other non-U.S. persons. Of course, U.S. persons and U.S.-owned or – controlled entities must still comply with existing requirements under the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) for humanitarian exports to Iran, as implemented through OFAC’s regulations.

Enhanced Due Diligence and Reporting Expectations

Provided that foreign financial institutions commit to implement stringent enhanced due diligence steps, the framework will enable them to seek written confirmation from Treasury that the proposed financial channel will not be exposed to U.S. sanctions

Host nation foreign financial institutions and their governments, as appropriate, will be expected to collect, maintain, and report to Treasury, with appropriate disclosure and use restrictions, a great deal of information on a monthly basis. Treasury will evaluate the information it receives in making any determination about whether the transactions continue to meet the stated due diligence and reporting expectations. Treasury will seek to protect information identified by the submitter, consistent with applicable laws and regulations.

The following is an illustrative list of documentation and information that Treasury and State may require depending on the nature of transactions:

1. The information used to identify the Iranian customers and to verify their identities and beneficial ownership;

a. For legal persons or arrangements, this would include the information used to identify and verify the existence of the entity or arrangement (company name, legal form and status, proof of incorporation, basic regulating powers, the registered address, list of directors, and principal place of business), and information sufficient to understand the nature of the Iranian customers’ business, ownership, and control structure;

b. For legal persons, information sufficient to identify and verify the identities of the natural person(s) who are beneficial owners. For legal arrangements, information sufficient to identify and verify the identities of the natural person(s) who are the settlor, trustee(s), protector (if any), the beneficiaries or class of beneficiaries, and any other natural person exercising ultimate effective control over the legal arrangements;

2. The information used by both the host nation’s foreign financial institutions and any Iranian financial institution involved to understand the purpose and intended nature of the business relationship between the seller of the humanitarian goods and the Iranian customer;

3. Monthly statement balances with the value, currency, and balance date of any account of an Iranian financial institution held at the participating host nation’s foreign financial institutions that is being used for humanitarian transactions, in .csv format;

4. A list of Iranian designated individuals or entities1 with which the Iranian customers indicate they currently have business relationships;

5. Detailed information regarding the commercial elements and logistics of the transaction that would be transmitted between the seller of humanitarian goods and the customer in the normal course of financial messaging, which could include:

a. customer information, including the identities of all consignees and intermediaries involved in the transactions;

b. information about the Iranian customer and the seller of the humanitarian goods and the Iranian financial institution’s payment order explanation or narrative linked to the contracts for the sale of humanitarian goods;

1 Persons designated on the List of Specially Designated Nationals and Blocked Persons under a program other than solely the Iranian Transactions and Sanctions Regulations (31 C.F.R. Part 560), and carrying a tag other than solely the “[IRAN]” tag.

c. order transaction amount and currency;

d. date of transaction order;

e. names of all involved financial institutions;

f. bills of lading, airway bills and invoices, as well as other relevant documents that verify the export to and entry into Iran of the goods;

g. the beneficiary’s identity; and

h. the beneficiary’s bank.

6. A written commitment from any Iranian distributors involved in the transactions that they will not allow the goods to be sold or resold to Iranian designated individuals or entities and that the Iranian distributor will impose this obligation on downstream customers;

7. Additional information obtained regularly throughout the course of the host nation foreign financial institutions’ ongoing due diligence of the business relationship that is necessary to verify the consistency of the transaction with the purposes of the humanitarian channel, including host nation’s foreign financial institutions’ knowledge of the Iranian customers and their business and risk profiles;

8. If, through the course of the host nation’s foreign financial institutions’ enhanced due diligence, Iranian customers are found to have attempted, or are suspected of, misuse of the humanitarian channel, the participating host nation’s foreign financial institution will immediately restrict any suspicious transactions and provide relevant information to Treasury when permitted; and

9. If a host nation foreign financial institution finds that an Iranian customer had previous ties (within five years) to U.S.-, U.N.-, or EU-designated entities or individuals, the host nation foreign financial institution will provide to Treasury detailed information regarding any changes to those ties, such as a change in beneficial ownership or control of the Iranian customer.

In certain circumstances, Treasury and State may require other information.

Interested foreign governments and foreign financial institutions should reach out to Treasury for more information or with any questions.

Links:

Treasury Press Release

Section 311 Final Rule

OFAC Guidance

On Thursday, OFAC updated General License 5 (now 5A) for the Venezuela program, making the authorization for these transactions regarding the PdVSA 8.5% 2020 bond only effective starting in mid-January. They also amended FAQ 595 to explain:

595. What does Venezuela-related General License 5A authorize?

The President issued Executive Order (E.O.) 13835 on May 21, 2018.  Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV.  One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV.  Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond.  OFAC issued General License 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.  

 

On October 24, 2019, General License 5 was replaced and superseded by General License 5A, which now has a delay in effectiveness until January 22, 2020.  Between October 24, 2019 and January 22, 2020 (the date the authorization in General License 5A becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond.  As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.  

 

To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply.  OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement. [10-24-2019] 

Links:

OFAC Notice

General License 5A

FAQ 595