64518 Federal Register / Vol. 83, No. 241 / Monday, December 17, 2018 / Notices 

ballast; lithium, lead-acid and nickelmetal hydride batteries; bearings; bell 

assemblies; bellcranks; bellows; 

transmission belts; fan blades; thermal 

insulation blankets; bolts; technicalflight manual books; boost pump 

cartridges; turbine boots; bootstrap 

reservoirs; brackets; brake assemblies; 

bushings; cabin air distribution kits; 

cables; engine cams; interlock cams; 

cameras; caps; capacitors; cargo straps; 

cockpit carpet; turbine chambers; 

circlips; circuit breakers; integrated 

circuits; clamps; clevis; clutches; coils; 

collars; combustors; commutators; 

compensators; compressors; computers; 

oil level conditioners; conduits; wheel 

cones; connectors; electrical contacts; 

ferry containers; grip controls; control 

panels; control units; static converters; 

oil coolers; ferrite cores; couplings; 

covers; partition curtains; pneumatic 

cylinders; cowl dampers; deflectors; 

turbine engine valve diaphragms; 

diodes; satcom diplexers; LED, LCD and 

analog displays; LED, LCD and analog 

display components; hot air 

distributors; ditching lifelines and 

pouches; doors; drains; ducts; elbows; 

elevator assemblies; gas turbine engines; 

equipment stands; heat exchangers; 

ignition exciters; external compensation 

units; faceplates; fairings; engine and 

avionics fans; filters; engine fire bottles; 

fire extinguishers; first-aid kits; fittings; 

flanges; flaps; flashlights; flight data 

recorders; floor boards; fuses; gaskets; 

gears; gear motors; gear shafts; 

generators; handles; handrail 

assemblies; wire and cable harnesses; 

headsets; heat shields; heat sinks; 

heating elements; hoses; housings; 

impellers; indicators; inductors; fuel 

injectors; inlet assemblies; rubber inner 

tubes; nickel inserts; insulators; 

interface units; interlock rollers; 

inverters; knobs; landing gear 

assemblies; latches; lavatories; ignitor 

leads; leading edges; lens assemblies; 

life jackets; life rafts; light assemblies; 

hydraulic lines; magnetometers; bleed 

air manifolds; microphones; control 

modules; waste tank modules; AC 

motors; mounts; nipples; switching 

nodes; nuts; rubber O-rings; structural 

overhead strips; instrument panel 

overlays; oxygen cylinders and full face 

masks; panels; rudder pedal assemblies; 

piccolo tubes; pins; pipes; nameplates 

and placards; plates; plugs; port kits; 

potentiometers; static pressure ports; 

printed circuits; oil probes; pumps; 

radar; radio racks; radio receiver and 

transmitter; radomes; spring reels; 

voltage regulators; relays; resistors; 

restraint systems; rig pin assemblies; 

rollers; rotors; screws; seals; seats; 

security wedges; sensors; servos; shafts; 

aluminum sheets; shock absorbers; 

slider assemblies; spacers; springs; 

stators; strut assemblies; studs; sun 

visors; support assemblies; switches; tail 

cones; T-fittings; thermocouples; 

thermostats; throttle quadrants; tie rod 

assemblies; rubber tires; traffic 

surveillance systems; transceivers; 

transducers; transformers; transistors; 

transponders; trim assemblies; tubes; 

valves; vibration isolators; washers; 

wheel assemblies; window assemblies; 

and, winglets (duty rate ranges from 

duty-free to 12.5%). Gulfstream would 

be able to avoid duty on foreign-status 

components which become scrap/waste. 

Customs duties also could possibly be 

deferred or reduced on foreign-status 

production equipment. 

The material/component sourced 

from abroad is: Aircraft (duty-free). 

Public comment is invited from 

interested parties. Submissions shall be 

addressed to the Board’s Executive 

Secretary at the address below. The 

closing period for their receipt is 

January 28, 2019. 

A copy of the notification will be 

available for public inspection at the 

Office of the Executive Secretary, 

Foreign-Trade Zones Board, Room 

21013, U.S. Department of Commerce, 

1401 Constitution Avenue NW, 

Washington, DC 20230–0002, and in the 

‘‘Reading Room’’ section of the Board’s 

website, which is accessible via 

www.trade.gov/ftz. 

For further information, contact 

Elizabeth Whiteman at 

Elizabeth.Whiteman@trade.gov or (202) 

482–0473. 

Dated: December 11, 2018. 

Andrew McGilvray, 

Executive Secretary. 

[FR Doc. 2018–27245 Filed 12–14–18; 8:45 am] 

BILLING CODE 3510–DS–P 

DEPARTMENT OF COMMERCE 

Foreign-Trade Zones Board 

[B–51–2018] 

Foreign-Trade Zone (FTZ) 189—Kent/ 

Ottawa/Muskegon Counties, Michigan; 

Authorization of Production Activity, 

Helix Steel (Twisted Steel Micro Rebar) 

Grand Rapids, Michigan 

On August 13, 2018, KOM Foreign 

Trade Zone Authority, grantee of FTZ 

189, submitted a notification of 

proposed production activity to the FTZ 

Board on behalf of Helix Steel, within 

Site 11, in Grand Rapids, Michigan. 

The notification was processed in 

accordance with the regulations of the 

FTZ Board (15 CFR part 400), including 

notice in the Federal Register inviting 

public comment (83 FR 42109, August 

20, 2018). On December 11, 2018, the 

applicant was notified of the FTZ 

Board’s decision that no further review 

of the activity is warranted at this time. 

The production activity described in the 

notification was authorized, subject to 

the FTZ Act and the FTZ Board’s 

regulations, including Section 400.14. 

Dated: December 11, 2018. 

Andrew McGilvray, 

Executive Secretary. 

[FR Doc. 2018–27246 Filed 12–14–18; 8:45 am] 

BILLING CODE 3510–DS–P 

DEPARTMENT OF COMMERCE 

Bureau of Industry and Security 

Order Renewing Order Temporarily 

Denying Export Privileges 

Mahan Airways, Mahan Tower, No. 21, 

Azadegan St., M.A. Jenah Exp. Way, 

Tehran, Iran; 

Pejman Mahmood Kosarayanifard, a/k/a 

Kosarian Fard, P.O. Box 52404, Dubai, 

United Arab Emirates; 

Mahmoud Amini, G#22 Dubai Airport Free 

Zone, P.O. Box 393754, Dubai, United Arab 

Emirates, and P.O. Box 52404, Dubai, 

United Arab Emirates, and Mohamed 

Abdulla Alqaz Building, Al Maktoum 

Street, Al Rigga, Dubai, United Arab 

Emirates; 

Kerman Aviation, a/k/a GIE Kerman 

Aviation, 42 Avenue Montaigne 75008, 

Paris, France; 

Sirjanco Trading LLC, P.O. Box 8709, Dubai, 

United Arab Emirates; 

Mahan Air General Trading LLC, 19th Floor 

Al Moosa Tower One, Sheik Zayed Road, 

Dubai 40594, United Arab Emirates; 

Mehdi Bahrami, Mahan Airways—Istanbul 

Office, Cumhuriye Cad. Sibil Apt No: 101 

D:6, 34374 Emadad, Sisli Istanbul, Turkey; 

Al Naser Airlines, a/k/a al-Naser Airlines, a/ 

k/a Al Naser Wings Airline, a/k/a Alnaser 

Airlines and Air Freight Ltd., Home 46, AlKarrada, Babil Region, District 929, St 21, 

Beside Al Jadirya Private Hospital, 

Baghdad, Iraq; and Al Amirat Street, 

Section 309, St. 3/H.20, Al Mansour, 

Baghdad, Iraq; P.O. Box 28360, Dubai, 

United Arab Emirates; and P.O. Box 

911399, Amman 11191, Jordan; 

Ali Abdullah Alhay, a/k/a Ali Alhay, a/k/a 

Ali Abdullah Ahmed Alhay, Home 46, AlKarrada, Babil Region, District 929, St 21, 

Beside Al Jadirya Private Hospital, 

Baghdad, Iraq; and Anak Street, Qatif, 

Saudi Arabia 61177; 

Bahar Safwa General Trading, P.O. Box 

113212, Citadel Tower, Floor-5, Office 

#504, Business Bay, Dubai, United Arab 

Emirates; and P.O. Box 8709, Citadel 

Tower, Business Bay, Dubai, United Arab 

Emirates; 

Sky Blue Bird Group, a/k/a Sky Blue Bird 

Aviation, a/k/a Sky Blue Bird Ltd., a/k/a 

Sky Blue Bird FZC, P.O. Box 16111, Ras Al 


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1The Regulations, currently codified at 15 CFR 

parts 730–774 (2018), originally issued pursuant to 

the Export Administration Act (50 U.S.C. 4601– 

4623) (Supp. III 2015) (‘‘EAA’’), which lapsed on 

August 21, 2001. The President, through Executive 

Order 13222 of August 17, 2001 (3 CFR, 2001 

Comp. 783 (2002)), which has been extended by 

successive Presidential Notices, the most recent 

being that of August 8, 2018 (83 FR 39,871 (Aug. 

13, 2018)), continued the Regulations in effect 

under the International Emergency Economic 

Powers Act (50 U.S.C. 1701, et seq. (2012)) 

(‘‘IEEPA’’). On August 13, 2018, the President 

signed into law the John S. McCain National 

Defense Authorization Act for Fiscal Year 2019, 

which includes the Export Control Reform Act of 

2018, Title XVII, Subtitle B of Public Law 115–232, 

132 Stat. 2208 (‘‘ECRA’’). While Section 1766 of 

ECRA repeals the provisions of the EAA (except for 

three sections which are inapplicable here), Section 

1768 of ECRA provides, in pertinent part, that all 

rules and regulations that were made or issued 

under the EAA, including as continued in effect 

pursuant to IEEPA, and were in effect as of ECRA’s 

date of enactment (August 13, 2018), shall continue 

in effect until modified, superseded, set aside, or 

revoked through action undertaken pursuant to the 

authority provided under ECRA. Moreover, Section 

1761(a)(5) of ECRA also authorizes the issuance of 

temporary denial orders. 

2Section 766.24(d) provides that BIS may seek 

renewal of a temporary denial order for additional 

180-day renewal periods, if it believes that renewal 

is necessary in the public interest to prevent an 

imminent violation. Renewal requests are to be 

made in writing no later than 20 days before the 

scheduled expiration date of a temporary denial 

order. Renewal requests may include discussion of 

any additional or changed circumstances, and may 

seek appropriate modifications to the order, 

including the addition of parties as respondents or 

related persons, or the removal of parties previously 

added as respondents or related persons. BIS is not 

required to seek renewal as to all parties, and a 

removal of a party can be effected if, without more, 

BIS does not seek renewal as to that party. Any 

party included or added to a temporary denial order 

as a respondent may oppose a renewal request as 

set forth in Section 766.24(d). Parties included or 

added as related persons can at any time appeal 

their inclusion as a related person, but cannot 

challenge the underlying temporary denial order, 

either as initially issued or subsequently renewed, 

and cannot oppose a renewal request. See also note 

4, infra. 

3The June 14, 2018 renewal order was effective 

upon issuance and published in the Federal 

Register on June 21, 2018 (83 FR 28,801). Prior 

renewal orders issued on September 17, 2008, 

March 16, 2009, September 11, 2009, March 9, 

2010, September 3, 2010, February 25, 2011, August 

24, 2011, February 15, 2012, August 9, 2012, 

February 4, 2013, July 31, 2013, January 24, 2014, 

July 22, 2014, January 16, 2015, July 13, 2015, 

January 7, 2016, July 7, 2016, December 30, 2016, 

June 27, 2017, and December 20, 2017, respectively. 

The August 24, 2011 renewal followed the issuance 

of a modification order that issued on July 1, 2011, 

to add Zarand Aviation as a respondent. The July 

13, 2015 renewal followed a modification order that 

issued May 21, 2015, and added Al Naser Airlines, 

Ali Abdullah Alhay, and Bahar Safwa General 

Trading as respondents. Each of the renewal orders 

and each of the modification orders referenced in 

this footnote or elsewhere in this order has been 

published in the Federal Register. 

4Pursuant to Sections 766.23 and 766.24(c) of the 

Regulations, any person, firm, corporation, or 

business organization related to a denied person by 

affiliation, ownership, control, or position of 

responsibility in the conduct of trade or related 

services may be added as a ‘‘related person’’ to a 

temporary denial order to prevent evasion of the 

order. 

5Balli Group PLC and Balli Aviation settled 

proposed BIS administrative charges as part of a 

settlement agreement that was approved by a 

settlement order issued on February 5, 2010. The 

sanctions imposed pursuant to that settlement and 

order included, inter alia, a $15 million civil 

penalty and a requirement to conduct five external 

audits and submit related audit reports. The Balli 

Group Respondents also settled related charges 

with the Department of Justice and the Treasury 

Department’s Office of Foreign Assets Control. 

6See note 4, supra, concerning the addition of 

related persons to a temporary denial order. 

Kosarian Fard and Mahmoud Amini remain parties 

to the TDO. On August 13, 2014, BIS and Gatewick 

resolved administrative charges against Gatewick, 

including a charge for acting contrary to the terms 

of a BIS denial order (15 CFR 764.2(k)). In addition 

to the payment of a civil penalty, the settlement 

includes a seven-year denial order. The first two 

years of the denial period were active, with the 

remaining five years suspended conditioned upon 

Gatewick’s full and timely payment of the civil 

penalty and its compliance with the Regulations 

during the seven-year denial order period. This 

denial order, in effect, superseded the TDO as to 

Gatewick, which was not included as part of the 

January 16, 2015 renewal order. The Gatewick LLC 

Final Order was published in the Federal Register 

on August 20, 2014. See 79 FR 49283 (Aug. 20, 

2014). 

7Zarand Aviation’s export privileges remained 

denied until July 22, 2014, when it was not 

included as part of the renewal order issued on that 

date. 

8The U.S. Department of the Treasury’s Office of 

Foreign Assets Control (‘‘OFAC’’) designated Sky 

Blue Bird and Issam Shammout as Specially 

Designated Global Terrorists (‘‘SDGTs’’) on May 21, 

Continued 

Khaimah Trade Zone, United Arab 

Emirates; 

Issam Shammout, a/k/a Muhammad Isam 

Muhammad, Anwar Nur Shammout, a/k/a 

Issam Anwar, Philips Building, 4th Floor, 

Al Fardous Street, Damascus, Syria; and Al 

Kolaa, Beirut, Lebanon 151515; and 17–18 

Margaret Street, 4th Floor, London, W1W 

8RP, United Kingdom; and Cumhuriyet 

Mah. Kavakli San St. Fulya, Cad. Hazar 

Sok. No.14/A Silivri, Istanbul, Turkey 

Pursuant to Section 766.24 of the 

Export Administration Regulations, 15 

CFR parts 730–774 (2018) (‘‘EAR’’ or 

‘‘the Regulations’’), I hereby grant the 

request of the Office of Export 

Enforcement (‘‘OEE’’) to renew the 

temporary denial order issued in this 

matter on June 14, 2018. I find that 

renewal of this order, as modified, is 

necessary in the public interest to 

prevent an imminent violation of the 

Regulations.1

I. Procedural History 

On March 17, 2008, Darryl W. 

Jackson, the then-Assistant Secretary of 

Commerce for Export Enforcement 

(‘‘Assistant Secretary’’), signed an order 

denying Mahan Airways’ export 

privileges for a period of 180 days on 

the ground that issuance of the order 

was necessary in the public interest to 

prevent an imminent violation of the 

Regulations. The order also named as 

denied persons Blue Airways, of 

Yerevan, Armenia (‘‘Blue Airways of 

Armenia’’), as well as the ‘‘Balli Group 

Respondents,’’ namely, Balli Group 

PLC, Balli Aviation, Balli Holdings, 

Vahid Alaghband, Hassan Alaghband, 

Blue Sky One Ltd., Blue Sky Two Ltd., 

Blue Sky Three Ltd., Blue Sky Four Ltd., 

Blue Sky Five Ltd., and Blue Sky Six 

Ltd., all of the United Kingdom. The 

order was issued ex parte pursuant to 

Section 766.24(a) of the Regulations, 

and went into effect on March 21, 2008, 

the date it was published in the Federal 

Register. 

This temporary denial order (‘‘TDO’’) 

was renewed in accordance with 

Section 766.24(d) of the Regulations.2

Subsequent renewals also have issued 

pursuant to Section 766.24(d), including 

most recently on June 14, 2018.3 Some 

of the renewal orders and the 

modification orders that have issued 

between renewals have added certain 

parties as respondents or as related 

persons, or effected the removal of 

certain parties.4

The September 11, 2009 renewal 

order continued the denial order as to 

Mahan Airways, but not as to the Balli 

Group Respondents or Blue Airways of 

Armenia.5 As part of the February 25, 

2011 renewal order, Pejman Mahmood 

Kosarayanifard (a/k/a Kosarian Fard), 

Mahmoud Amini, and Gatewick LLC (a/ 

k/a Gatewick Freight and Cargo 

Services, a/k/a Gatewick Aviation 

Services) were added as related persons 

to prevent evasion of the TDO.6 A 

modification order issued on July 1, 

2011, adding Zarand Aviation as a 

respondent in order to prevent an 

imminent violation.7

As part of the August 24, 2011 

renewal, Kerman Aviation, Sirjanco 

Trading LLC, and Ali Eslamian were 

added as related persons. Mahan Air 

General Trading LLC, Equipco (UK) 

Ltd., and Skyco (UK) Ltd. were added as 

related persons by a modification order 

issued on April 9, 2012. Mehdi Bahrami 

was added as a related person as part of 

the February 4, 2013 renewal order. 

On May 21, 2015, a modification 

order issued adding Al Naser Airlines, 

Ali Abdullah Alhay, and Bahar Safwa 

General Trading as respondents. As 

detailed in that order and discussed 

further infra, these respondents were 

added to the TDO based upon evidence 

that they were acting together to, inter 

alia, obtain aircraft subject to the 

Regulations for export or reexport to 

Mahan in violation of the Regulations 

and the TDO. 

Sky Blue Bird Group and its chief 

executive officer, Issam Shammout, 

were added as related persons as part of 

the July 13, 2015 renewal order.8 On 


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2015, pursuant to Executive Order 13324, for 

‘‘providing support to Iran’s Mahan Air.’’ See 80 FR 

30762 (May 29, 2015). 

9The November 16, 2017 modification was 

published in the Federal Register on December 4, 

2017. See 82 FR 57,203 (Dec. 4, 2017). On 

September 28, 2017, BIS and Ali Eslamian resolved 

an administrative charge for acting contrary to the 

terms of the denial order (15 CFR 764.2(k)) that was 

based upon Eslamian’s violation of the TDO after 

his addition to the TDO on August 24, 2011. 

Equipco (UK) Ltd. and Skyco (UK) Ltd., two 

companies owned and operated by Eslamian, also 

were parties to settlement agreement and were 

added to the settlement order as related persons. In 

addition to other sanctions, the settlement provides 

that Eslamian, Equipco, and Skyco shall be subject 

to a conditionally-suspended denial order for a 

period of four years from the date of the settlement 

order. 

10A party named or added as a related person 

may not oppose the issuance or renewal of the 

underlying temporary denial order, but may file an 

appeal of the related person determination in 

accordance with Section 766.23(c). See also note 2, 

supra. 

11Engaging in conduct prohibited by a denial 

order violates the Regulations. 15 CFR 764.2(a) and 

(k). 

12The third Boeing 747 appeared to have 

undergone significant service maintenance and may 

not have been operational at the time of the March 

9, 2010 renewal order. 

November 16, 2017, a modification 

order issued to remove Ali Eslamian, 

Equipco (UK) Ltd., and Skyco (UK) Ltd. 

as related persons following a request by 

OEE for their removal.9

The June 14, 2018 renewal order 

continued the denial of the export 

privileges of Mahan Airways, Pejman 

Mahmood Kosarayanifard, Mahmoud 

Amini, Kerman Aviation, Sirjanco 

Trading LLC, Mahan Air General 

Trading LLC, Mehdi Bahrami, Al Naser 

Airlines, Ali Abdullah Alhay, Bahar 

Safwa General Trading, Sky Blue Bird 

Group, and Issam Shammout. 

On November 20, 2018, BIS, through 

OEE, submitted a written request for 

renewal of the TDO that issued on June 

14, 2018. The written request was made 

more than 20 days before the TDO’s 

scheduled expiration. Notice of the 

renewal request was provided to Mahan 

Airways, Al Naser Airlines, Ali 

Abdullah Alhay, and Bahar Safwa 

General Trading in accordance with 

Sections 766.5 and 766.24(d) of the 

Regulations. No opposition to the 

renewal of the TDO has been received. 

Furthermore, no appeal of the related 

person determinations made as part of 

the September 3, 2010, February 25, 

2011, August 24, 2011, April 9, 2012, 

February 4, 2013, and July 13, 2015 

renewal or modification orders has been 

made by Kosarian Fard, Mahmoud 

Amini, Kerman Aviation, Sirjanco 

Trading LLC, Mahan Air General 

Trading LLC, Mehdi Bahrami, Sky Blue 

Bird Group, or Issam Shammout.10

II. Renewal of the TDO 

A. Legal Standard 

Pursuant to Section 766.24, BIS may 

issue or renew an order temporarily 

denying a respondent’s export privileges 

upon a showing that the order is 

necessary in the public interest to 

prevent an ‘‘imminent violation’’ of the 

Regulations. 15 CFR 766.24(b)(1) and 

766.24(d). ‘‘A violation may be 

‘imminent’ either in time or degree of 

likelihood.’’ 15 CFR 766.24(b)(3). BIS 

may show ‘‘either that a violation is 

about to occur, or that the general 

circumstances of the matter under 

investigation or case under criminal or 

administrative charges demonstrate a 

likelihood of future violations.’’ Id. As 

to the likelihood of future violations, 

BIS may show that the violation under 

investigation or charge ‘‘is significant, 

deliberate, covert and/or likely to occur 

again, rather than technical or negligent 

[.]’’ Id. A ‘‘lack of information 

establishing the precise time a violation 

may occur does not preclude a finding 

that a violation is imminent, so long as 

there is sufficient reason to believe the 

likelihood of a violation.’’ Id. 

B. The TDO and BIS’s Request for 

Renewal 

OEE’s request for renewal is based 

upon the facts underlying the issuance 

of the initial TDO, and the renewal and 

modification orders subsequently issued 

in this matter, including the May 21, 

2015 modification order and the 

renewal order issued on June 14, 2018, 

and the evidence developed over the 

course of this investigation, which 

indicate a blatant disregard of U.S. 

export controls and the TDO. The initial 

TDO was issued as a result of evidence 

that showed that Mahan Airways and 

other parties engaged in conduct 

prohibited by the EAR by knowingly reexporting to Iran three U.S.-origin 

aircraft, specifically Boeing 747s 

(‘‘Aircraft 1–3’’), items subject to the 

EAR and classified under Export 

Control Classification Number 

(‘‘ECCN’’) 9A991.b, without the required 

U.S. Government authorization. Further 

evidence submitted by BIS indicated 

that Mahan Airways was involved in the 

attempted re-export of three additional 

U.S.-origin Boeing 747s (‘‘Aircraft 4–6’’) 

to Iran. 

As discussed in the September 17, 

2008 renewal order, evidence presented 

by BIS indicated that Aircraft 1–3 

continued to be flown on Mahan 

Airways’ routes after issuance of the 

TDO, in violation of the Regulations and 

the TDO itself.11 It also showed that 

Aircraft 1–3 had been flown in further 

violation of the Regulations and the 

TDO on the routes of Iran Air, an 

Iranian Government airline. Moreover, 

as discussed in the March 16, 2009, 

September 11, 2009 and March 9, 2010 

renewal orders, Mahan Airways 

registered Aircraft 1–3 in Iran, obtained 

Iranian tail numbers for them (EP–MNA, 

EP–MNB, and EP–MNE, respectively), 

and continued to operate at least two of 

them in violation of the Regulations and 

the TDO,12 while also committing an 

additional knowing and willful 

violation when it negotiated for and 

acquired an additional U.S.-origin 

aircraft. The additional acquired aircraft 

was an MD–82 aircraft, which 

subsequently was painted in Mahan 

Airways’ livery and flown on multiple 

Mahan Airways’ routes under tail 

number TC–TUA. 

The March 9, 2010 renewal order also 

noted that a court in the United 

Kingdom (‘‘U.K.’’) had found Mahan 

Airways in contempt of court on 

February 1, 2010, for failing to comply 

with that court’s December 21, 2009 and 

January 12, 2010 orders compelling 

Mahan Airways to remove the Boeing 

747s from Iran and ground them in the 

Netherlands. Mahan Airways and the 

Balli Group Respondents had been 

litigating before the U.K. court 

concerning ownership and control of 

Aircraft 1–3. In a letter to the U.K. court 

dated January 12, 2010, Mahan Airways’ 

Chairman indicated, inter alia, that 

Mahan Airways opposes U.S. 

Government actions against Iran, that it 

continued to operate the aircraft on its 

routes in and out of Tehran (and had 

158,000 ‘‘forward bookings’’ for these 

aircraft), and that it wished to continue 

to do so and would pay damages if 

required by that court, rather than 

ground the aircraft. 

The September 3, 2010 renewal order 

discussed the fact that Mahan Airways’ 

violations of the TDO extended beyond 

operating U.S.-origin aircraft and 

attempting to acquire additional U.S.- 

origin aircraft. In February 2009, while 

subject to the TDO, Mahan Airways 

participated in the export of computer 

motherboards, items subject to the 

Regulations and designated as EAR99, 

from the United States to Iran, via the 

United Arab Emirates (‘‘UAE’’), in 

violation of both the TDO and the 

Regulations, by transporting and/or 

forwarding the computer motherboards 

from the UAE to Iran. Mahan Airways’ 

violations were facilitated by Gatewick 

LLC, which not only participated in the 

transaction, but also has stated to BIS 

that it acted as Mahan Airways’ sole 

booking agent for cargo and freight 

forwarding services in the UAE. 


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13See http://www.treasury.gov/resource-center/ 

sanctions/OFAC-Enforcement/pages/ 

20120919.aspx. 

14The Airbus A310s are powered with U.S.-origin 

engines. The engines are subject to the EAR and 

classified under Export Control Classification 

(‘‘ECCN’’) 9A991.d. The Airbus A310s contain 

controlled U.S.-origin items valued at more than 10 

percent of the total value of the aircraft and as a 

result are subject to the EAR. They are classified 

under ECCN 9A991.b. The export or reexport of 

these aircraft to Iran requires U.S. Government 

authorization pursuant to Sections 742.8 and 746.7 

of the Regulations. 

15OEE subsequently presented evidence that after 

the August 24, 2011 renewal, Mahan Airways 

worked along with Kerman Aviation and others to 

de-register the two Airbus A310 aircraft in France 

and to register both aircraft in Iran (with, 

respectively, Iranian tail numbers EP–MHH and 

EP–MHI). It was determined subsequent to the 

February 15, 2012 renewal order that the 

registration switch for these A310s was cancelled 

and that Mahan Airways then continued to fly the 

aircraft under the original French tail numbers (F– 

OJHH and F–OJHI, respectively). Both aircraft 

apparently remain in Mahan Airways’ possession. 

16See note 14, supra. 

17See http://www.treasury.gov/resource-center/ 

sanctions/OFAC-Enforcement/pages/ 

20120919.aspx. Mahan Airways was previously 

designated by OFAC as a SDGT on October 18, 

2011. 77 FR 64,427 (October 18, 2011). 

18 Kral Aviation was referenced in the February 

4, 2013 renewal order as ‘‘Turkish Company No. 1.’’ 

Kral Aviation purchased a GE CF6–50C2 aircraft 

engine (MSN 517621) from the United States in July 

2012, on behalf of Mahan Airways. OEE was able 

to prevent this engine from reaching Mahan by 

issuing a redelivery order to the freight forwarder 

in accordance with Section 758.8 of the 

Regulations. OEE also issued Kral Aviation a 

redelivery order for the second CF6–50C2 engine 

(MSN 517738) on July 30, 2012. The owner of the 

second engine subsequently cancelled the item’s 

sale to Kral Aviation. In September 2012, OEE was 

alerted by a U.S. exporter that another Turkish 

company (‘‘Turkish Company No. 2’’) was 

attempting to purchase aircraft spare parts intended 

for re-export by Turkish Company No. 2 to Mahan 

Airways. See February 4, 2013 renewal order. 

On December 31, 2013, Kral Aviation was added 

to BIS’s Entity List, Supplement No. 4 to Part 744 

of the Regulations. See 78 FR75458 (Dec. 12, 2013). 

Companies and individuals are added to the Entity 

List for engaging in activities contrary to the 

national security or foreign policy interests of the 

United States. See 15 CFR 744.11. 

19Pioneer Logistics, Gulnihal Yegane, and Kosol 

Surinanda also were added to the Entity List on 

December 12, 2013. See 78 FR 75458 (Dec. 12, 

2013). 

Moreover, in a January 24, 2011 filing 

in the U.K. court, Mahan Airways 

asserted that Aircraft 1–3 were not being 

used, but stated in pertinent part that 

the aircraft were being maintained in 

Iran especially ‘‘in an airworthy 

condition’’ and that, depending on the 

outcome of its U.K. court appeal, the 

aircraft ‘‘could immediately go back into 

service . . . on international routes into 

and out of Iran.’’ Mahan Airways’ 

January 24, 2011 submission to U.K. 

Court of Appeal, at p. 25, ¶¶ 108, 110. 

This clearly stated intent, both on its 

own and in conjunction with Mahan 

Airways’ prior misconduct and 

statements, demonstrated the need to 

renew the TDO in order to prevent 

imminent future violations. Two of 

these three 747s subsequently were 

removed from Iran and are no longer in 

Mahan Airways’ possession. The third 

of these 747s, with Manufacturer’s 

Serial Number (‘‘MSN’’) 23480 and 

Iranian tail number EP–MNE, remained 

in Iran under Mahan’s control. Pursuant 

to Executive Order 13324, it was 

designated a Specially Designated 

Global Terrorist (‘‘SDGT’’) by the U.S. 

Department of the Treasury’s Office of 

Foreign Assets Control (‘‘OFAC’’) on 

September 19, 2012.13 Furthermore, as 

discussed in the February 4, 2013 Order, 

open source information indicated that 

this 747, painted in the livery and logo 

of Mahan Airways, had been flown 

between Iran and Syria, and was 

suspected of ferrying weapons and/or 

other equipment to the Syrian 

Government from Iran’s Islamic 

Revolutionary Guard Corps. Open 

source information showed that this 

aircraft had flown from Iran to Syria as 

recently as June 30, 2013, and continues 

to show that it remains in active 

operation in Mahan Airways’ fleet. 

In addition, as first detailed in the 

July 1, 2011 and August 24, 2011 orders, 

and discussed in subsequent renewal 

orders in this matter, Mahan Airways 

also continued to evade U.S. export 

control laws by operating two Airbus 

A310 aircraft, bearing Mahan Airways’ 

livery and logo, on flights into and out 

of Iran.14 At the time of the July 1, 2011 

and August 24, 2011 orders, these 

Airbus A310s were registered in France, 

with tail numbers F–OJHH and F–OJHI, 

respectively.15

The August 2012 renewal order also 

found that Mahan Airways had acquired 

another Airbus A310 aircraft subject to 

the Regulations, with MSN 499 and 

Iranian tail number EP–VIP, in violation 

of the TDO and the Regulations.16 On 

September 19, 2012, all three Airbus 

A310 aircraft (tail numbers F–OJHH, F– 

OJHI, and EP–VIP) were designated as 

SDGTs.17

The February 4, 2013 renewal order 

laid out further evidence of continued 

and additional efforts by Mahan 

Airways and other persons acting in 

concert with Mahan, including Kral 

Aviation and another Turkish company, 

to procure U.S.-origin engines—two GE 

CF6–50C2 engines, with MSNs 517621 

and 517738, respectively—and other 

aircraft parts in violation of the TDO 

and the Regulations.18 The February 4, 

2013 order also added Mehdi Bahrami 

as a related person in accordance with 

Section 766.23 of the Regulations. 

Bahrami, a Mahan Vice-President and 

the head of Mahan’s Istanbul Office, 

also was involved in Mahan’s 

acquisition of the original three Boeing 

747s (Aircraft 1–3) that resulted in the 

original TDO, and has had a business 

relationship with Mahan dating back to 

1997. 

The July 31, 2013 renewal order 

detailed additional evidence obtained 

by OEE showing efforts by Mahan 

Airways to obtain another GE CF6–50C2 

aircraft engine (MSN 528350) from the 

United States via Turkey. Multiple 

Mahan employees, including Mehdi 

Bahrami, were involved in or aware of 

matters related to the engine’s arrival in 

Turkey from the United States, plans to 

visually inspect the engine, and prepare 

it for shipment from Turkey. 

Mahan Airways sought to obtain this 

U.S.-origin engine through Pioneer 

Logistics Havacilik Turizm Yonetim 

Danismanlik (‘‘Pioneer Logistics’’), an 

aircraft parts supplier located in Turkey, 

and its director/operator, Gulnihal 

Yegane, a Turkish national who 

previously had conducted Mahan 

related business with Mehdi Bahrami 

and Ali Eslamian. Moreover, as 

referenced in the July 31, 2013 renewal 

order, a sworn affidavit by Kosol 

Surinanda, also known as Kosol 

Surinandha, Managing Director of 

Mahan’s General Sales Agent in 

Thailand, stated that the shares of 

Pioneer Logistics for which he was the 

listed owner were ‘‘actually the property 

of and owned by Mahan.’’ He further 

stated that he held ‘‘legal title to the 

shares until otherwise required by 

Mahan’’ but would ‘‘exercise the rights 

granted to [him] exactly and only as 

instructed by Mahan and [his] vote and/ 

or decisions [would] only and 

exclusively reflect the wills and 

demands of Mahan[.]’’ 19

The January 24, 2014 renewal order 

outlined OEE’s continued investigation 

of Mahan Airways’ activities and 

detailed an attempt by Mahan, which 

OEE thwarted, to obtain, via an 

Indonesian aircraft parts supplier, two 

U.S.-origin Honeywell ALF–502R–5 

aircraft engines (MSNs LF5660 and 

LF5325), items subject to the 

Regulations, from a U.S. company 

located in Texas. An invoice of the 

Indonesian aircraft parts supplier dated 

March 27, 2013, listed Mahan Airways 

as the purchaser of the engines and 

included a Mahan ship-to address. OEE 

also obtained a Mahan air waybill dated 

March 12, 2013, listing numerous U.S.- 

origin aircraft parts subject to the 

Regulations—including, among other 

items, a vertical navigation gyroscope, a 

transmitter, and a power control unit— 


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20The BAE regional jets are powered with U.S.- 

origin engines. The engines are subject to the EAR 

and classified under ECCN 9A991.d. These aircraft 

contain controlled U.S.-origin items valued at more 

than 10 percent of the total value of the aircraft and 

as a result are subject to the EAR. They are 

classified under ECCN 9A991.b. The export or 

reexport of these aircraft to Iran requires U.S. 

Government authorization pursuant to Sections 

742.8 and 746.7 of the Regulations. 

21See 76 FR 50407 (Aug. 15, 2011). The July 22, 

2014 renewal order also referenced two Airbus 

A320 aircraft painted in the livery and logo of 

Mahan Airways and operating under Iranian tail 

numbers EP–MMK and EP–MML, respectively. 

OEE’s investigation also showed that Mahan 

obtained these aircraft in November 2013, from 

Khors Air Company, another Ukrainian airline that, 

like Ukrainian Mediterranean Airlines, was added 

to BIS’s Entity List on August 15, 2011. Open 

source evidence indicates the two Airbus A320 

aircraft may be been transferred by Mahan Airways 

to another Iranian airline in October 2014, and 

issued Iranian tail numbers EP–APE and EP–APF, 

respectively. 

22See http://www.treasury.gov/resource-center/ 

sanctions/OFAC-Enforcement/Pages/ 

20140829.aspx. See 79 FR 55073 (Sep. 15, 2014). 

OFAC also blocked the property and property 

interests of Pioneer Logistics of Turkey on August 

29, 2014. Id. Mahan Airways’ use of Pioneer 

Logistics in an effort to evade the TDO and the 

Regulations was discussed in a prior renewal order, 

as summarized, supra, at 13–14. BIS added both 

Asian Aviation Logistics and Pioneer Logistics to 

the Entity List on December 12, 2013. See 78 FR 

75458 (Dec. 12, 2013). 

23Both of these aircraft are powered by U.S.- 

origin engines that are subject to the Regulations 

and classified under ECCN 9A991.d. Both aircraft 

contain controlled U.S.-origin items valued at more 

than 10 percent of the total value of the aircraft and 

as a result are subject to the EAR regardless of their 

location. The aircraft are classified under ECCN 

9A991.b. The export or re-export of these aircraft to 

Iran requires U.S. Government authorization 

pursuant to Sections 742.8 and 746.7 of the 

Regulations. 

24The evidence obtained by OEE showed Ali 

Abdullah Alhay as a 25% owner of Al Naser 

Airlines. 

25Both aircraft were physically located in the 

United States and therefore are subject to the 

Regulations pursuant to Section 734.3(a)(1). 

Moreover, these Airbus A320s are powered by U.S.- 

origin engines that are subject to the Regulations 

and classified under Export Control Classification 

Number ECCN 9A991.d. The Airbus A320s contain 

controlled U.S.-origin items valued at more than 10 

percent of the total value of the aircraft and as a 

result are subject to the EAR regardless of their 

location. The aircraft are classified under ECCN 

9A991.b. The export or re-export of these aircraft to 

Iran requires U.S. Government authorization 

pursuant to Sections 742.8 and 746.7 of the 

Regulations. 

26This evidence included a press release dated 

May 9, 2015, that appeared on Mahan Airways’ 

website and stated that Mahan ‘‘added 9 modern 

aircraft to its air fleet [,]’’ and that the newly 

acquired aircraft included eight Airbus A340s and 

one Airbus A321. See http://www.mahan.aero/en/ 

mahan-air/press-room/44. The press release was 

subsequently removed from Mahan Airways’ 

website. Publicly available aviation databases 

similarly showed that Mahan had obtained nine 

additional aircraft from Al Naser Airlines in May 

2015, including MSNs 164 and 550. As also 

discussed in the July 13, 2015 renewal order, Sky 

Blue Bird Group, via Issam Shammout, was actively 

involved in Al Naser Airlines’ acquisition of MSNs 

164 and 550, and the attempted acquisition of 

MSNs 82 and 99 (which were detained by OEE). 

27The Airbus A340s are powered by U.S.-origin 

engines that are subject to the Regulations and 

classified under ECCN 9A991.d. The Airbus A340s 

contain controlled U.S.-origin items valued at more 

than 10 percent of the total value of the aircraft and 

as a result are subject to the EAR regardless of their 

location. The aircraft are classified under ECCN 

9A991.b. The export or re-export of these aircraft to 

Iran requires U.S. Government authorization 

pursuant to Sections 742.8 and 746.7 of the 

Regulations. 

being transported by Mahan from 

Turkey to Iran in violation of the TDO. 

The July 22, 2014 renewal order 

discussed open source evidence from 

the March–June 2014 time period 

regarding two BAE regional jets, items 

subject to the Regulations, that were 

painted in the livery and logo of Mahan 

Airways and operating under Iranian 

tail numbers EP–MOK and EP–MOI, 

respectively.20 In addition, aviation 

industry resources indicated that these 

aircraft were obtained by Mahan 

Airways in late November 2013 and 

June 2014, from Ukrainian 

Mediterranean Airline, a Ukrainian 

airline that was added to BIS’s Entity 

List (Supplement No. 4 to Part 744 of 

the Regulations) on August 15, 2011, for 

acting contrary to the national security 

and foreign policy interests of the 

United States.21 Open source 

information indicated that at least EP– 

MOI remained active in Mahan’s fleet, 

and that the aircraft was being operated 

on multiple flights in July 2014. 

The January 16, 2015 renewal order 

detailed evidence of additional attempts 

by Mahan Airways to acquire items 

subject the Regulations in further 

violation of the TDO. Specifically, in 

March 2014, OEE became aware of an 

inertial reference unit bearing serial 

number 1231 (‘‘the IRU’’) that had been 

sent to the United States for repair. The 

IRU is subject to the Regulations, 

classified under ECCN 7A103, and 

controlled for missile technology 

reasons. Upon closer inspection, it was 

determined that IRU came from or had 

been installed on an Airbus A340 

aircraft bearing MSN 056. Further 

investigation revealed that as of 

approximately February 2014, this 

aircraft was registered under Iranian tail 

number EP–MMB and had been painted 

in the livery and logo of Mahan 

Airways. 

The January 16, 2015 renewal order 

also described related efforts by the 

Departments of Justice and Treasury to 

further thwart Mahan’s illicit 

procurement efforts. Specifically, on 

August 14, 2014, the United States 

Attorney’s Office for the District of 

Maryland filed a civil forfeiture 

complaint for the IRU pursuant to 22 

U.S.C. 401(b) that resulted in the court 

issuing an Order of Forfeiture on 

December 2, 2014. EP–MMB remains 

listed as active in Mahan Airways’ fleet 

and has been used on flights into and 

out of Iran as recently as December 19, 

2017. 

Additionally, on August 29, 2014, 

OFAC blocked the property and 

interests in property of Asian Aviation 

Logistics of Thailand, a Mahan Airways 

affiliate or front company, pursuant to 

Executive Order 13,224. In doing so, 

OFAC described Mahan Airways’ use of 

Asian Aviation Logistics to evade 

sanctions by making payments on behalf 

of Mahan for the purchase of engines 

and other equipment.22

The May 21, 2015 modification order 

detailed the acquisition of two aircraft, 

specifically an Airbus A340 bearing 

MSN 164 and an Airbus A321 bearing 

MSN 550, that were purchased by Al 

Naser Airlines in late 2014/early 2015 

and were under the possession, control, 

and/or ownership of Mahan Airways.23

The sales agreements for these two 

aircraft were signed by Ali Abdullah 

Alhay for Al Naser Airlines.24 Payment 

information reveals that multiple 

electronic funds transfers (‘‘EFT’’) were 

made by Ali Abdullah Alhay and Bahar 

Safwa General Trading in order to 

acquire MSNs 164 and 550. 

The May 21, 2015 modification order 

also laid out evidence showing the 

respondents’ attempts to obtain other 

controlled aircraft, including aircraft 

physically located in the United States 

in similarly-patterned transactions 

during the same recent time period. 

Transactional documents involving two 

Airbus A320s bearing MSNs 82 and 99, 

respectively, again showed Ali 

Abdullah Alhay signing sales 

agreements for Al Naser Airlines.25 A 

review of the payment information for 

these aircraft similarly revealed EFTs 

from Ali Abdullah Alhay and Bahar 

Safwa General Trading that follow the 

pattern described for MSNs 164 and 

550, supra. MSNs 82 and 99 were 

detained by OEE Special Agents prior to 

their planned export from the United 

States. 

The July 13, 2015 renewal order 

outlined evidence showing that Al 

Naser Airlines’ attempts to acquire 

aircraft on behalf of Mahan Airways 

extended beyond MSNs 164 and 550 to 

include a total of nine aircraft.26 Four of 

the aircraft, all of which are subject to 

the Regulations and were obtained by 

Mahan from Al Naser Airlines, had been 

issued the following Iranian tail 

numbers: EP–MMD (MSN 164), EP– 

MMG (MSN 383), EP–MMH (MSN 391) 

and EP–MMR (MSN 416), 

respectively.27 Publicly available flight 

tracking information provided evidence 

that at the time of the July 13, 2015 


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28There is some publicly available information 

indicating that the aircraft Mahan Airways is flying 

under Iranian tail number EP–MMR is now MSN 

615, rather than MSN 416. Both aircraft are Airbus 

A340 aircraft that Mahan acquired from Al Naser 

Airlines in violation of the TDO and the 

Regulations. Moreover, both aircraft were 

designated as SDGTs by OFAC on May 21, 2015, 

pursuant to Executive Order 13324. See 80 FR 

30762 (May 29, 2015). 

29The BAE Avro RJ–85 is powered by U.S.-origin 

engines that are subject to the Regulations and 

classified under ECCN 9A991.d. The BAE Avro RJ– 

85 contains controlled U.S.-origin items valued at 

more than 10 percent of the total value of the 

aircraft and as a result is subject to the EAR 

regardless of its location. The aircraft is classified 

under ECCN 9A991.b, and its export or re-export to 

Iran requires U.S. Government authorization 

pursuant to Sections 742.8 and 746.7 of the 

Regulations. 

30Specifically, on December 22, 2016, EP–MMD 

(MSN 164) flew from Dubai, UAE to Tehran, Iran. 

Between December 20 and December 22, 2016, EP– 

MMF (MSN 376) flew on routes from Tehran, Iran 

to Beijing, China and Istanbul, Turkey, respectively. 

Between December 26 and December 28, 2016, EP– 

MMH (MSN 391) flew on routes from Tehran, Iran 

to Kuala Lumpur, Malaysia. 

31Publicly available flight tracking information 

shows that on June 22, 2017, EP–MME (MSN 371) 

flew from Moscow, Russia to Tehran, Iran. 

Additionally, between June 19, 2017, and June 20, 

2017, EP–MMQ (MSN 449), an Airbus A430 also 

obtained from or through Al Naser Airlines, flew on 

routes between Shanghai, China and Tehran, Iran. 

Similar flight tracking information shows that on 

June 20, 2017, EP–MNK (MSN 618), an Airbus A300 

originally acquired by Mahan via a Ukrainian 

company, flew between Kabul, Afghanistan and 

Mashhad, Iran. 

32The Airbus A320 is powered with U.S.-origin 

engines, which are subject to the EAR and classified 

under Export Control Classification (‘‘ECCN’’) 

9A991.d. The engines are valued at more than 10 

percent of the total value of the aircraft, which 

consequently is subject to the EAR. The aircraft is 

classified under ECCN 9A991.b, and its export or 

reexport to Iran would require U.S. Government 

authorization pursuant to Sections 742.8 and 746.7 

of the Regulations. 

33For example, publicly available flight tracking 

information shows that on December 17, 2017, EP– 

MNV (MSN 567) flew from Lahore, Pakistan to 

Tehran, Iran. On December 18–19, 2017, EP–MMQ 

(MSN 449) flew on routes between Istanbul, Turkey 

and Tehran, Iran. Additionally, on December 17, 

2017, EP–MNK (MSN 618), an Airbus A300 

originally acquired by Mahan via a Ukrainian 

company, flew on routes between Baghdad, Iraq 

and Mashhad, Iran. 

34The Airbus A340 is powered by U.S.-origin 

engines that are subject to the Regulations and 

classified under ECCN 9A991.d. The Airbus A340 

contains controlled U.S.-origin items valued at 

more than 10 percent of the total value of the 

aircraft and as a result is subject to the EAR 

regardless of its location. The aircraft is classified 

under ECCN 9A991.b. The export or re-export of 

this aircraft to Iran requires U.S. Government 

authorization pursuant to Sections 742.8 and 746.7 

of the Regulations. On June 4, 2018, EP–MMT (MSN 

292) flew from Bangkok, Thailand to Tehran, Iran. 

35Publicly available flight tracking information 

shows that on June 3, 2018, EP–MMF (MSN 376) 

flew on routes between Beijing, China and Tehran, 

Iran and on June 4, 2018, EP–MMH (MSN 391) flew 

from Dubai, United Arab Emirates to Tehran, Iran. 

Additionally, on June 4, 2018, EP–MME (MSN 371) 

flew on routes between Istanbul, Turkey and 

Tehran, Iran. 

36See FR 27,828 (June 14, 2018). OFAC’s related 

press release states in part that ‘‘[o]ver the last 

several years, Otik Aviation has procured and 

delivered millions of dollars in aviation-related 

spare and replacement parts for Mahan Air, some 

Continued 

renewal, both EP–MMH and EP–MMR 

were being actively flown on routes into 

and out of Iran in violation of the TDO 

and Regulations.28

The January 7, 2016 renewal order 

discussed evidence that Mahan Airways 

had begun actively flying EP–MMD on 

international routes into and out of Iran, 

including from/to Bangkok, Thailand. 

Additionally, the January 7, 2016 order 

described publicly available aviation 

database and flight tracking information 

indicating that Mahan Airways 

continued efforts to acquire Iranian tail 

numbers and press into active service 

under Mahan’s livery and logo at least 

two more of the Airbus A340 aircraft it 

had obtained from or through Al Naser 

Airlines: EP–MME (MSN 371) and EP– 

MMF (MSN 376), respectively. Since 

January 2016, EP–MME has logged 

flights to and from Tehran, Iran 

involving various destinations, 

including Guangzhou, China and Dubai, 

United Arab Emirates, in further 

violation of the TDO and the 

Regulations. 

The July 7, 2016 renewal order 

described Mahan Airways’ acquisition 

of a BAE Avro RJ–85 aircraft (MSN 

2392) in violation of the TDO and its 

subsequent registration under Iranian 

tail number EP–MOR.29 This 

information was corroborated by 

publicly available information on the 

website of Iran’s civil aviation authority. 

The July 7, 2016 order also outlined 

Mahan’s continued operation of EP– 

MMF in violation of the TDO on routes 

from Tehran, Iran to Beijing, China and 

Shanghai, China, respectively. 

The December 30, 2016 renewal order 

outlined Mahan’s continued operation 

of multiple Airbus aircraft, including 

EP–MMD (MSN 164), EP–MMF (MSN 

376), and EP–MMH (MSN 391), which 

were acquired from or through Al Naser 

Airlines in violation of the TDO, as 

previously detailed in pertinent part in 

the July 13, 2015 and January 7, 2016 

renewal orders. Publicly available flight 

tracking information showed that the 

aircraft were operated on flights into 

and out of Iran, including from/to 

Beijing, China, Kuala Lumpur, Malaysia, 

and Istanbul, Turkey.30

The June 27, 2017 renewal order 

included similar evidence regarding 

Mahan Airways’ violation of the TDO by 

operating multiple Airbus aircraft 

subject to the Regulations, including, 

but not limited to, aircraft procured 

from or through Al Naser Airlines, on 

flights into and out of Iran, including 

from/to Moscow, Russia, Shanghai, 

China and Kabul, Afghanistan. 31

The June 27, 2017 order also detailed 

evidence concerning a suspected 

planned or attempted diversion to 

Mahan of an Airbus A340 subject to the 

Regulations that had first been 

mentioned in OEE’s December 13, 2016 

renewal request. 

The December 20, 2017 renewal order 

presented evidence that a Mahan 

employee attempted to initiate 

negotiations with a U.S. company for 

the purchase of an aircraft subject to the 

Regulations and classified under ECCN 

9A610. Moreover, the order highlighted 

Al Naser Airlines’ acquisition, via lease, 

of at least possession and/or control of 

a Boeing 737 (MSN 25361), bearing tail 

number YR–SEB, and an Airbus A320 

(MSN 357), bearing tail number YR– 

SEA, from a Romanian company in 

violation of the TDO.32 Open source 

information indicates that after the 

December 20, 2017 renewal order 

publicly exposed Al Naser’s acquisition 

of these two aircraft (MSNs 25361 and 

357), the leases were subsequently 

cancelled and the aircraft returned to 

their owner. 

The December 20, 2017 renewal order 

also included evidence indicating that 

Mahan Airways was continuing to 

operate a number of aircraft subject to 

the Regulations, including aircraft 

originally procured from or through Al 

Naser Airlines, on flights into and out 

of Iran from/to Lahore, Pakistan, 

Shanghai, China, Ankara, Turkey, 

Kabul, Afghanistan, and Baghdad, Iraq, 

in violation of the TDO.33

The June 14, 2018 renewal order 

outlined evidence that Mahan began 

actively operating EP–MMT, an Airbus 

A340 aircraft (MSN 292) acquired in 

2017 and previously registered in 

Kazakhstan under tail number UP– 

A4003, on international flights into and 

out of Iran.34 It also discussed evidence 

that Mahan continued to operate a 

number of aircraft subject to the EAR, 

including, but not limited to, EP–MME, 

EP–MMF, and EP–MMH, on 

international flights into and out of Iran 

from/to Beijing, China, Dubai, United 

Arab Emirates, and Istanbul, Turkey.35

The June 14, 2018 order also noted 

that on May 24, 2018, OFAC had 

designated a number of Mahan-related 

entities and individuals as Specially 

Designated Global Terrorists, pursuant 

to Executive Order 13,224, for providing 

material support to Mahan, including, 

but not limited to, Otik Aviation, a/k/a 

Otik Havacilik Sanayi Ve Ticaret 

Limited Sirketi, of Turkey.36 On May 24, 


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of which are procured from the United States and 

the European Union. As recently as 2017, Otik 

Aviation continued to provide Mahan Air with 

replacement parts worth well over $100,000 per 

shipment, such as aircraft brakes.’’ See https://

home.treasury.gov/news/press-releases/sm0395. See 

also https://www.treasury.gov/resource-center/ 

sanctions/OFAC-Enforcement/Pages/ 

20180524.aspx. 

37See FR 27,828 (June 14, 2018). These twelve 

aircraft, in which Mahan Airways has an interest, 

are: EP–MMA (MSN 20), EP–MMB (MSN 56), EP– 

MMC (MSN 282), EP–MMJ (MSN 526), EP–MMV 

(MSN 2079), EP–MNF (MSN 547), EP–MOD (MSN 

3162), EP–MOM (MSN 3165), EP–MOP (MSN 

2257), EP–MOQ (MSN 2261), EP–MOR (MSN 2392), 

and EP–MOS (MSN 2347). 

38Flight tracking information shows that on 

December 10, 2018, EP–MMB (MSN 56) flew from 

Istanbul, Turkey to Tehran, Iran, and EP–MME 

(MSN 371) flew from Guangzhou, China to Tehran, 

Iran. Additionally, on December 6, 2018, EP–MMF 

(MSN 376) flew from Bangkok, Thailand to Tehran, 

Iran, and on December 9, 2018, EP–MMQ (MSN 

449) flew on routes between Dubai, United Arab 

Emirates and Tehran, Iran. 

39See 83 FR 34,301 (July 19, 2018) (designation 

of Mahan Travel and Tourism SDN BHD on July 9, 

2018), and 83 FR 53,359 (Oct. 22, 2018) 

(designation of My Aviation Company Limited and 

updating of entry for Mahan Travel and Tourism 

SDN BHD on September 14, 2018). 

40OFAC’s press release concerning its 

designation of My Aviation Company Limited on 

September 14, 2018, states in part that ‘‘[t]his 

Thailand-based company has disregarded numerous 

U.S. warnings, issued publicly and delivered 

bilaterally to the Thai government, to sever ties 

with Mahan Air.’’ My Aviation provides cargo 

services to Mahan Airways, including freight 

booking, and works with local freight forwarding 

entities to ship cargo on regularly-scheduled Mahan 

Airways’ flights to Tehran, Iran. My Aviation has 

also provided Mahan Airways with passenger 

booking services. See https://home.treasury.gov/ 

news/press-releases/sm484. 

2018, OFAC also designated an 

additional twelve aircraft owned and/or 

operated by Mahan.37

The June 14, 2018 renewal order also 

cited the April 2018 arrest and 

arraignment of a U.S. citizen on a threecount criminal information filed in the 

United States District Court for the 

District of New Jersey involving the 

unlicensed exports of U.S.-origin 

aircraft parts to Iran valued at over $2 

million. The criminal information listed 

Mahan Airways as one of the 

defendant’s customers. 

OEE’s November 20, 2018 renewal 

request details publicly available 

information showing that Mahan 

Airways has continued operating a 

number of aircraft subject to the EAR, 

including, but not limited to, EP–MMB, 

EP–MME, EP–MMF, and EP–MMQ, on 

international flights into and out of Iran 

from/to Istanbul, Turkey, Guangzhou, 

China, Bangkok, Thailand, and Dubai, 

United Arab Emirates, including as 

recently as December 10, 2018.38

Since the TDO was last renewed on 

June 14, 2018, OFAC has designated 

additional Mahan-related entities as 

SDGTs pursuant to Executive Order 

13,224, namely, My Aviation Company 

Limited, of Thailand, and Mahan Travel 

and Tourism SDN BHD, a/k/a Mahan 

Travel a/k/a Mihan Travel & Tourism 

SDN BHD, of Malaysia.39 As general 

sales agents for Mahan Airways, these 

companies sell cargo space aboard 

Mahan Airways’ flights, including on 

flights to Iran, and provide other 

services to or for benefit of Mahan 

Airways and its operations.40

Lastly, on October 3, 2018, OEE’s 

continued investigation of Mahan 

Airways and its affiliates resulted in a 

guilty plea by Arzu Sagsoz, a Turkish 

national, in the United States District 

Court for the District of Columbia 

stemming from her involvement in a 

conspiracy to export a U.S.-origin 

aircraft engine valued at approximately 

$810,000 to Mahan. 

C. Findings 

Under the applicable standard set 

forth in Section 766.24 of the 

Regulations and my review of the entire 

record, I find that the evidence 

presented by BIS convincingly 

demonstrates that the denied persons 

have acted in violation of the 

Regulations and the TDO; that such 

violations have been significant, 

deliberate and covert; and that given the 

foregoing and the nature of the matters 

under investigation, there is a likelihood 

of future violations. Therefore, renewal 

of the TDO is necessary in the public 

interest to prevent imminent violation 

of the Regulations and to give notice to 

companies and individuals in the 

United States and abroad that they 

should continue to cease dealing with 

Mahan Airways and Al Naser Airlines 

and the other denied persons in 

connection with export and reexport 

transactions involving items subject to 

the Regulations and in connection with 

any other activity subject to the 

Regulations. 

IV. Order 

It is therefore ordered: FIRST, that 

MAHAN AIRWAYS, Mahan Tower, No. 

21, Azadegan St., M.A. Jenah Exp. Way, 

Tehran, Iran; PEJMAN MAHMOOD 

KOSARAYANIFARD A/K/A 

KOSARIAN FARD, P.O. Box 52404, 

Dubai, United Arab Emirates; 

MAHMOUD AMINI, G#22 Dubai 

Airport Free Zone, P.O. Box 393754, 

Dubai, United Arab Emirates, and P.O. 

Box 52404, Dubai, United Arab 

Emirates, and Mohamed Abdulla Alqaz 

Building, Al Maktoum Street, Al Rigga, 

Dubai, United Arab Emirates; KERMAN 

AVIATION A/K/A GIE KERMAN 

AVIATION, 42 Avenue Montaigne 

75008, Paris, France; SIRJANCO 

TRADING LLC, P.O. Box 8709, Dubai, 

United Arab Emirates; MAHAN AIR 

GENERAL TRADING LLC, 19th Floor Al 

Moosa Tower One, Sheik Zayed Road, 

Dubai 40594, United Arab Emirates; 

MEHDI BAHRAMI, Mahan AirwaysIstanbul Office, Cumhuriye Cad. Sibil 

Apt No: 101 D:6, 34374 Emadad, Sisli 

Istanbul, Turkey; AL NASER AIRLINES 

A/K/A AL–NASER AIRLINES A/K/A 

AL NASER WINGS AIRLINE A/K/A AL 

NASER AIRLINES AND AIR FREIGHT 

LTD., Home 46, Al-Karrada, Babil 

Region, District 929, St 21, Beside Al 

Jadirya Private Hospital, Baghdad, Iraq, 

and Al Amirat Street, Section 309, St. 3/ 

H.20, Al Mansour, Baghdad, Iraq, and 

P.O. Box 28360, Dubai, United Arab 

Emirates, and P.O. Box 911399, Amman 

11191, Jordan; ALI ABDULLAH ALHAY 

A/K/A ALI ALHAY A/K/A ALI 

ABDULLAH AHMED ALHAY, Home 

46, Al-Karrada, Babil Region, District 

929, St 21, Beside Al Jadirya Private 

Hospital, Baghdad, Iraq, and Anak 

Street, Qatif, Saudi Arabia 61177; 

BAHAR SAFWA GENERAL TRADING, 

P.O. Box 113212, Citadel Tower, Floor5, Office #504, Business Bay, Dubai, 

United Arab Emirates, and P.O. Box 

8709, Citadel Tower, Business Bay, 

Dubai, United Arab Emirates; SKY 

BLUE BIRD GROUP A/K/A SKY BLUE 

BIRD AVIATION A/K/A SKY BLUE 

BIRD LTD A/K/A SKY BLUE BIRD FZC, 

P.O. Box 16111, Ras Al Khaimah Trade 

Zone, United Arab Emirates; and ISSAM 

SHAMMOUT A/K/A MUHAMMAD 

ISAM MUHAMMAD ANWAR NUR 

SHAMMOUT A/K/A ISSAM ANWAR, 

Philips Building, 4th Floor, Al Fardous 

Street, Damascus, Syria, and Al Kolaa, 

Beirut, Lebanon 151515, and 17–18 

Margaret Street, 4th Floor, London, 

W1W 8RP, United Kingdom, and 

Cumhuriyet Mah. Kavakli San St. Fulya, 

Cad. Hazar Sok. No.14/A Silivri, 

Istanbul, Turkey, and when acting for or 

on their behalf, any successors or 

assigns, agents, or employees (each a 

‘‘Denied Person’’ and collectively the 

‘‘Denied Persons’’) may not, directly or 

indirectly, participate in any way in any 

transaction involving any commodity, 

software or technology (hereinafter 

collectively referred to as ‘‘item’’) 

exported or to be exported from the 

United States that is subject to the 

Export Administration Regulations 

(‘‘EAR’’), or in any other activity subject 

to the EAR including, but not limited to: 

A. Applying for, obtaining, or using 

any license, license exception, or export 

control document; 

B. Carrying on negotiations 

concerning, or ordering, buying, 

receiving, using, selling, delivering, 


amozie on DSK3GDR082PROD with NOTICES1
Federal Register / Vol. 83, No. 241 / Monday, December 17, 2018 / Notices 64525 

1See Notice of Amended Final Determination of 

Sales at Less Than Fair Value and Antidumping 

Duty Orders: Silicomanganese from India, 

Kazakhstan, and Venezuela, 67 FR 36149 (May 23, 

2002). 

2See Silicomanganese from India, Kazakhstan, 

and Venezuela: Continuation of Antidumping Duty 

Orders, 78 FR 60846 (October 2, 2013) (Third 

Continuation of the AD Orders). 

3See Initiation of Five-Year (‘‘Sunset’’) Reviews, 

83 FR 45887 (September 11, 2018) (Initiation). 

storing, disposing of, forwarding, 

transporting, financing, or otherwise 

servicing in any way, any transaction 

involving any item exported or to be 

exported from the United States that is 

subject to the EAR, or engaging in any 

other activity subject to the EAR; or 

C. Benefitting in any way from any 

transaction involving any item exported 

or to be exported from the United States 

that is subject to the EAR, or from any 

other activity subject to the EAR. 

Second, that no person may, directly 

or indirectly, do any of the following: 

A. Export or reexport to or on behalf 

of a Denied Person any item subject to 

the EAR; 

B. Take any action that facilitates the 

acquisition or attempted acquisition by 

a Denied Person of the ownership, 

possession, or control of any item 

subject to the EAR that has been or will 

be exported from the United States, 

including financing or other support 

activities related to a transaction 

whereby a Denied Person acquires or 

attempts to acquire such ownership, 

possession or control; 

C. Take any action to acquire from or 

to facilitate the acquisition or attempted 

acquisition from a Denied Person of any 

item subject to the EAR that has been 

exported from the United States; 

D. Obtain from a Denied Person in the 

United States any item subject to the 

EAR with knowledge or reason to know 

that the item will be, or is intended to 

be, exported from the United States; or 

E. Engage in any transaction to service 

any item subject to the EAR that has 

been or will be exported from the 

United States and which is owned, 

possessed or controlled by a Denied 

Person, or service any item, of whatever 

origin, that is owned, possessed or 

controlled by a Denied Person if such 

service involves the use of any item 

subject to the EAR that has been or will 

be exported from the United States. For 

purposes of this paragraph, servicing 

means installation, maintenance, repair, 

modification or testing. 

Third, that, after notice and 

opportunity for comment as provided in 

section 766.23 of the EAR, any other 

person, firm, corporation, or business 

organization related to a Denied Person 

by ownership, control, position of 

responsibility, affiliation in the conduct 

of trade or business may also be made 

subject to the provisions of this Order. 

Fourth, that this Order does not 

prohibit any export, reexport, or other 

transaction subject to the EAR where the 

only items involved that are subject to 

the EAR are the foreign-produced direct 

product of U.S.-origin technology. 

In accordance with the provisions of 

Sections 766.24(e) of the EAR, Mahan 

Airways, Al Naser Airlines, Ali 

Abdullah Alhay, and/or Bahar Safwa 

General Trading may, at any time, 

appeal this Order by filing a full written 

statement in support of the appeal with 

the Office of the Administrative Law 

Judge, U.S. Coast Guard ALJ Docketing 

Center, 40 South Gay Street, Baltimore, 

Maryland 21202–4022. In accordance 

with the provisions of Sections 

766.23(c)(2) and 766.24(e)(3) of the EAR, 

Pejman Mahmood Kosarayanifard, 

Mahmoud Amini, Kerman Aviation, 

Sirjanco Trading LLC, Mahan Air 

General Trading LLC, Mehdi Bahrami, 

Sky Blue Bird Group, and/or Issam 

Shammout may, at any time, appeal 

their inclusion as a related person by 

filing a full written statement in support 

of the appeal with the Office of the 

Administrative Law Judge, U.S. Coast 

Guard ALJ Docketing Center, 40 South 

Gay Street, Baltimore, Maryland 21202– 

4022. 

In accordance with the provisions of 

Section 766.24(d) of the EAR, BIS may 

seek renewal of this Order by filing a 

written request not later than 20 days 

before the expiration date. A renewal 

request may be opposed by Mahan 

Airways, Al Naser Airlines, Ali 

Abdullah Alhay, and/or Bahar Safwa 

General Trading as provided in Section 

766.24(d), by filing a written submission 

with the Assistant Secretary of 

Commerce for Export Enforcement, 

which must be received not later than 

seven days before the expiration date of 

the Order. 

A copy of this Order shall be provided 

to Mahan Airways, Al Naser Airlines, 

Ali Abdullah Alhay, and Bahar Safwa 

General Trading and each related 

person, and shall be published in the 

Federal Register. This Order is effective 

immediately and shall remain in effect 

for 180 days. 

Dated: December 11, 2018. 

Douglas R. Hassebrock, 

Director, Office of Export Enforcement, 

performing the non-exclusive functions, and 

duties of the Assistant Secretary of Commerce 

for Export Enforcement. 

[FR Doc. 2018–27225 Filed 12–14–18; 8:45 am] 

BILLING CODE P 

DEPARTMENT OF COMMERCE 

International Trade Administration 

[A–533–823; A–834–807; A–307–820] 

Silicomanganese From India, 

Kazakhstan, and Venezuela: Final 

Results of Expedited Third Sunset 

Reviews of the Antidumping Duty 

Orders 

AGENCY: Enforcement and Compliance, 

International Trade Administration, 

Department of Commerce. 

SUMMARY: As a result of these sunset 

reviews, the Department of Commerce 

(Commerce) finds that revocation of the 

antidumping duty orders on 

silicomanganese from India, 

Kazakhstan, and Venezuela would be 

likely to lead to continuation or 

recurrence of dumping. The magnitude 

of the dumping margins likely to prevail 

are indicated in the ‘‘Final Results of 

Sunset Review’’ section of this notice. 

DATES: Applicable December 17, 2018. 

FOR FURTHER INFORMATION CONTACT: 

Jacqueline Arrowsmith, AD/CVD 

Operations, Office VII, Enforcement and 

Compliance, U.S. Department of 

Commerce, 1401 Constitution Avenue 

NW, Washington, DC 20230; telephone 

(202) 482–5255. 

SUPPLEMENTARY INFORMATION: 

Background 

On May 23, 2002, Commerce 

published the Amended Final 

Determination of Sales at Less Than 

Fair Value and Antidumping Duty 

Orders: Silicomanganese from India, 

Kazakhstan, and Venezuela (AD 

Orders).1 On October 2, 2013, the 

Department published the notice of 

continuation of these AD Orders.2

On September 11, 2018, Commerce 

published the notice of initiation of the 

sunset reviews of the AD Orders on 

silicomanganese from India, 

Kazakhstan, and Venezuela, pursuant to 

section 751(c) of the Tariff Act of 1930, 

as amended (the Act).3

On September 13, 2018, Commerce 

received a notice of intent to participate 

from Eramet Marietta, Inc. (Eramet) as a 

domestic interested party, within the 

deadline specified in 19 CFR 


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