Federal Register / Vol. 89, No. 212 / Friday, November 1, 2024 / Notices 87329 

1The Regulations, currently codified at 15 CFR 

parts 730–774 (2023), 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 part 2001 

Comp. 783 (2002)), as extended by successive 

Presidential Notices, 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, 50 U.S.C. 4801–4852 (‘‘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 orders, rules, regulations, and other 

forms of administrative action 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 according to their terms until 

modified, superseded, set aside, or revoked through 

action undertaken pursuant to the authority 

provided under ECRA. Moreover, section 1761(a)(5) 

of ECRA 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. In cases demonstrating a 

pattern of repeated, ongoing and/or continuous 

apparent violations, BIS may request the renewal of 

a temporary denial order for an additional period 

not exceeding one year. 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, 

Continued 

expect to incur regular charges for calls 

they initiate over wireless lines, 

according to their wireless plan. The 

Commission will not refund any 

incurred charges. Closed captioning will 

be available for individuals who are 

deaf, hard of hearing, or who have 

certain cognitive or learning 

impairments. To request additional 

accommodations, please email Angelica 

Trevino, Support Services Specialist, 

atrevino@usccr.gov at least 10 business 

days prior to the meeting. 

Members of the public are entitled to 

make comments during the open period 

at the end of the meeting. Members of 

the public may also submit written 

comments; the comments must be 

received in the Regional Programs Unit 

within 30 days following the meeting. 

Written comments can be sent via email 

to Brooke Peery (DFO) at bpeery@

usccr.gov. 

Records generated from this meeting 

may be inspected and reproduced at the 

Regional Programs Coordination Unit 

Office, as they become available, both 

before and after the meeting. Records of 

the meetings will be available via 

www.facadatabase.gov under the 

Commission on Civil Rights, Texas 

Advisory Committee link. Persons 

interested in the work of this Committee 

are directed to the Commission’s 

website, http://www.usccr.gov, or may 

contact the Regional Programs 

Coordination Unit at atrevino@

usccr.gov. 

Agenda 

I. Welcome & Roll Call 

II. Approval of Minutes 

III. Committee Discussion 

IV. Public Comment 

V. Adjournment 

Dated: October 29, 2024. 

David Mussatt, 

Supervisory Chief, Regional Programs Unit. 

[FR Doc. 2024–25475 Filed 10–31–24; 8:45 am] 

BILLING CODE 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, 

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, 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 

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 § 766.24 of the Export 

Administration Regulations, 15 CFR 

parts 730–774 (2024) (‘‘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 October 

31, 2023. I find that renewal of this 

order, as modified, is necessary in the 

public interest to prevent an imminent 

violation of the Regulations and that 

renewal for an extended period is 

appropriate because Mahan Airways has 

engaged in a pattern of repeated, 

ongoing and/or continuous apparent 

violations of the EAR.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 

§ 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 

§ 766.24(d of the Regulations.2


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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 § 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 October 31, 2023 renewal order was 

effective upon issuance and published in the 

Federal Register on November 3, 2023 (88 FR 

75541. 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, December 20, 2017, June 14, 2018, 

December 11, 2018, June 5, 2019, May 29, 2020, 

November 24, 2020, May 21, 2021, November 17, 

2021, May 13, 2022, November 8, 2022, May 5, 

2023, and October 31, 2024, 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 §§ 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, 

2015, pursuant to Executive Order 13224, 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 57203 (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 the 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 § 766.23(c). See also note 2, supra. 

Subsequent renewals also have issued 

pursuant to § 766.24(d), including most 

recently on October 31, 2023.3 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 was 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 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 December 11, 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 April 6, 2023, BIS, through OEE, 

submitted a written request for renewal 

of the TDO that issued on November 8, 

2022. 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 

§§ 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 § 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, 


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11 88 FR 59791 (Aug. 30, 2023). 

12Engaging in conduct prohibited by a denial 

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

(k). 

13The 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. 

14See http://www.treasury.gov/resource-center/ 

sanctions/OFAC-Enforcement/pages/ 

20120919.aspx. 

15The Airbus A310s are powered with U.S.-origin 

engines. The engines are subject to the Regulations 

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 Regulations. They are 

classified under ECCN 9A991.b. The export or 

reexport of these aircraft to Iran requires U.S. 

Government authorization pursuant to §§ 742.8 and 

746.7 of the Regulations. 

16OEE subsequently presented evidence that after 

the August 24, 2011 renewal, Mahan Airways 

Continued 

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. 

If BIS believes that renewal of a denial 

order is necessary in the public interest 

to prevent an imminent violation, it may 

file a written request for renewal, with 

any modifications if appropriate. 15 

CFR 766.24(d)(1). The written request, 

which must be filed no later than 20 

days prior to the TDO’s expiration, 

should set forth the basis for BIS’s belief 

that renewal is necessary, including any 

additional or changed circumstances. Id. 

‘‘In cases demonstrating a pattern of 

repeated, ongoing and/or continuous 

apparent violations, BIS may request the 

renewal of a temporary denial order for 

an additional period not exceeding one 

year.’’ 11 Id. 

B. The TDO and BIS’s Requests 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 November 8, 

2022, 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.12 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,13 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. 

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 ‘‘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 remained in Iran under Mahan’s 

control. Pursuant to Executive Order 

13224, this 747 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, 

2012.14 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. 

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.15 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.16 The August 2012 


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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. 

17See note 14, supra. 

18See 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 64427 (October 18, 2011). 

19 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 § 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 FR 75458 (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. 

20Pioneer Logistics, Gulnihal Yegane, and Kosol 

Surinanda also were added to the Entity List on 

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

2013). 

21The 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 §§ 742.8 and 

746.7 of the Regulations. 

22See 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 have been transferred by Mahan 

Airways to another Iranian airline in October 2014, 

and issued Iranian tail numbers EP–APE and EP– 

APF, respectively. 

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 

Regulations.17 On September 19, 2012, 

all three Airbus A310 aircraft (tail 

numbers F–OJHH, F–OJHI, and EP–VIP) 

were designated as SDGTs.18

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.19 The February 4, 

2013 order also added Mehdi Bahrami 

as a related person in accordance with 

§ 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[.]’’ 20

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— 

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–MOI and EP–MOK, 

respectively.21 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.22 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 to 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 a U.S.-origin item, 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 


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23See 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 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). 

24Both 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 §§ 742.8 and 746.7 of the Regulations. 

25The evidence obtained by OEE showed Ali 

Abdullah Alhay as a 25% owner of Al Naser 

Airlines. 

26Both aircraft were physically located in the 

United States and therefore are subject to the 

Regulations pursuant to § 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 §§ 742.8 and 746.7 of the Regulations. 

27This 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). 

28The 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 §§ 742.8 and 746.7 of the Regulations. 

29There 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 Regulations. Moreover, 

both aircraft were designated as SDGTs by OFAC 

on May 21, 2015, pursuant to Executive Order 

13224. See 80 FR 30762 (May 29, 2015). 

30The 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 §§ 742.8 and 746.7 of the Regulations. 

31Specifically, 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. 

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 13224. 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.23

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.24

The sales agreements for these two 

aircraft were signed by Ali Abdullah 

Alhay for Al Naser Airlines.25 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.26 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.27 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.28 Publicly available flight 

tracking information provided evidence 

that at the time of the July 13, 2015 

renewal, both EP–MMH and EP–MMR 

were being actively flown on routes into 

and out of Iran in violation of the 

Regulations.29

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. 

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. 

The July 7, 2016 renewal order 

described Mahan Airways’ acquisition 

of a BAE Avro RJ–85 aircraft (MSN 

2392) in violation of the Regulations 

and its subsequent registration under 

Iranian tail number EP–MOR.30 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 Regulations 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, 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.31

The June 27, 2017 renewal order 

included similar evidence regarding 

Mahan Airways’ operation of multiple 

Airbus aircraft subject to the 

Regulations, including, but not limited 

to, aircraft procured from or through Al 


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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 §§ 742.8 and 746.7 of the 

Regulations. 

33The 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 Regulations 

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 §§ 742.8 and 746.7 of the 

Regulations. On June 4, 2018, EP–MMT (MSN 292) 

flew from Bangkok, Thailand to Tehran, Iran. 

34See 83 FR 27828 (June 14, 2018). OFAC’s 

related press release stated 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 

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.’’ The twelve 

additional Mahan-related aircraft that were 

designated 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). See https:// 

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

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

sanctions/OFAC-Enforcement/Pages/ 

20180524.aspx. 

35Flight tracking information showed 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. 

36See 83 FR 34301 (July 19, 2018) (designation 

of Mahan Travel and Tourism SDN BHD on July 9, 

2018), and 83 FR 53359 (Oct. 22, 2018) (designation 

of My Aviation Company Limited and updating of 

entry for Mahan Travel and Tourism SDN BHD on 

September 14, 2018). 

37OFAC’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. 

38Specifically, on May 26, 2019, EP–MMJ (MSN 

526) flew from Damascus, Syria to Tehran, Iran. In 

addition, on May 24, 2019, EP–MNF (MSN 547) 

flew on routes between Moscow, Russia and 

Tehran, and on May 23, 2019, EP–MMF (MSN 376) 

flew from Dubai, UAE to Tehran. 

Naser Airlines, on flights into and out 

of Iran, including from/to Moscow, 

Russia, Shanghai, China and Kabul, 

Afghanistan. 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 and the 

Regulations.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, including from/to Lahore, 

Pakistan, Shanghai, China, Ankara, 

Turkey, Kabul, Afghanistan, and 

Baghdad, Iraq. 

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.33 It also discussed evidence 

that Mahan continued to operate a 

number of aircraft subject to the 

Regulations, including, but not limited 

to, EP–MME, EP–MMF, and EP–MMH, 

on international flights into and out of 

Iran, including from/to Beijing, China. 

The June 14, 2018 renewal order also 

noted OFAC’s May 24, 2018 designation 

of Otik Aviation, a/k/a Otik Havacilik 

Sanayi Ve Ticaret Limited Sirketi, of 

Turkey, as an SDGT pursuant to 

Executive Order 13224, for providing 

material support to Mahan, as well as 

OFAC’s designation as SDGTs of an 

additional twelve aircraft in which 

Mahan has an interest.34 The June 14, 

2018 order also cited the April 2018 

arrest and arraignment of a U.S. citizen 

on a three-count 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 valued at over $2 million 

to Iran, including to Mahan Airways. 

The December 11, 2018 renewal order 

detailed publicly available information 

showing that Mahan Airways had 

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, UAE.35

It also discussed that OEE’s continued 

investigation of Mahan Airways and its 

affiliates and agents had resulted in an 

October 2018 guilty plea by Arzu 

Sagsoz, a Turkish national, in the U.S. 

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. 

The December 11, 2018 order also 

noted OFAC’s September 14, 2018 

designation of Mahan-related entities as 

SDGTs pursuant to Executive Order 

13224, 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.36 As general 

sales agents for Mahan Airways, these 

companies sold cargo space aboard 

Mahan Airways’ flights, including on 

flights to Iran, and provided other 

services to or for the benefit of Mahan 

Airways and its operations.37

The June 5, 2019 renewal order 

highlighted Mahan’s continued 

violation of the TDO and the 

Regulations. An end-use check 

conducted by BIS in Malaysia in March 

2019 uncovered evidence that, on 

approximately ten occasions, Mahan 

had caused, aided and/or abetted the 

unlicensed export of U.S.-origin items 

subject to the Regulations from the 

United States to Iran via Malaysia. The 

items included helicopter shafts, 

transmitters, and other aircraft parts, 

some of which are listed on the 

Commerce Control List and controlled 

on anti-terrorism grounds. The June 5, 

2019 order also detailed publicly 

available flight tracking information 

showing that Mahan continued to 

unlawfully operate a number of aircraft 

subject to the EAR on flights into and 

out of Iran, including on routes to and 

from Damascus, Syria.38

The June 5, 2019 order also described 

actions taken by both BIS and OFAC to 

thwart efforts by entities connected to or 

acting on behalf of Mahan Airways to 

violate U.S. export controls and 

sanctions related to Iran. On May 14, 

2019, BIS added Manohar Nair, Basha 


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39See 84 FR 21233 (May 14, 2019). 

40These 747s are registered in Iran with tail 

numbers EP–FAA and EP–FAB, respectively. 

41OFAC’s press release concerning these 

designations states that Qeshm Fars Air was being 

designated for ‘‘being owned or controlled by 

Mahan Air, as well as for assisting in, sponsoring, 

or providing financial, material or technological 

support for, or financial or other services to or in 

support of, the IRGC–QF,’’ and that Flight Travel 

LLC was being designated for ‘‘acting for or on 

behalf of Mahan Air.’’ It further states, inter alia, 

that ‘‘Mahan Air employees fill Qeshm Fars Air 

management positions, and Mahan Air provides 

technical and operational support for Qeshm Fars 

Air, facilitating the airline’s illicit operations.’’ See 

https://home.treasury.gov/news/press-releases/ 

sm590. See also https://www.treasury.gov/resourcecenter/sanctions/OFAC-Enforcement/Pages/ 

20190124.aspx. 

42The same open sources indicated this aircraft 

continued to operate on flights within Iran to 

include a May 11, 2020 flight from Tehran, Iran to 

Kerman, Iran. 

43Publicly available flight tracking information 

shows that on November 23, 2019, EP–MME (MSN 

371) flew from Guangzhou, China to Tehran, Iran, 

and on November 21, 2019, EP–MMF (MSN 376) 

flew on routes between Istanbul, Turkey and 

Tehran, Iran. Additionally, on November 20, 2019, 

EP–MMQ (MSN 449) flew from Kuala Lumpur, 

Malaysia, to Tehran, Iran. 

44Publicly available flight tracking information 

shows that on May 8, 2020, EP–MMD (MSN 164) 

flew on routes between Bangkok, Thailand and 

Tehran, Iran, and on May 10, 2020, EP–MMF (MSN 

376) flew on routes between Dubai, UAE and 

Tehran. In addition, on May 9, 2020, EP–MMI 

(MSN 416) flew on routes between Shanghai, China 

and Tehran. 

45Publicly available flight tracking information 

shows that on November 13, 2020, EP–MMQ (MSN 

449) flew on routes between Istanbul, Turkey and 

Tehran, Iran, and on November 15, 2020, EP–MMI 

(MSN 416) flew on routes between Shenzhen, China 

and Tehran. 

46See 85 FR 52321 (Aug. 25, 2020). 

47PTMS Aero, PTAK, PTKEU, and Sunarko 

Kuntjoro were each indicted in December 2019 on 

multiple counts related to this conspiracy in the 

United States District Court for the District of 

Columbia. 

48https://home.treasury.gov/news/press-releases/ 

sm1098. 

49https://www.justice.gov/opa/pr/iraniannational-and-uae-business-organization-chargedcriminal-conspiracy-violate-iranian. 

50Eliasbachus’ arrest and arraignment were 

detailed in the June 14, 2018 renewal order, as 

described supra at 21. 

51Publicly available flight tracking information 

shows that on May 14, 2021, EP–MMH (MSN 391) 

flew on routes between Shanghai, China and 

Tehran, Iran, and on May 13, 2021, EP–MMI (MSN 

416) flew on routes between Dubai, United Arab 

Emirates and Tehran. In addition, on May 20, 2021, 

EP–MMQ (MSN 346) flew on routes between 

Guangzhou, China and Tehran. 

52https://simpleflying.com/mahan-air-747-300- 

flies-again/. 

Asmath Shaikh, and two co-located 

companies that they operate, Emirates 

Hermes General Trading and Presto 

Freight International, LLC, to the Entity 

List pursuant to § 744.11 of the 

Regulations, including for engaging in 

activities to procure U.S.-origin items on 

Mahan’s behalf.39 On January 24, 2019, 

OFAC designated as SDGTs Flight 

Travel LLC, which is Mahan’s general 

service agent in Yerevan, Armenia, and 

Qeshm Fars Air, an Iranian airline 

which operates two U.S.-origin Boeing 

747s 40 and is owned or controlled by 

Mahan, and also linked to the Islamic 

Revolutionary Guard Corps-Qods Force 

(IRGC–QF).41

The December 2, 2019 renewal order 

noted that OEE’s on-going investigation 

revealed that U.S.-origin passenger 

flight and database management 

software subject to the Regulations was 

provided to a company in Turkey and 

subsequently used to facilitate and 

service Mahan’s operations into and out 

of Turkey in further violation of the 

Regulations. 

Additionally, open source 

information, including flight tracking 

data and news articles published in 

October 2019, showed that Mahan 

Airways was now operating a U.S.- 

origin Boeing 747 on routes between 

Iranian airports in Tehran, Kish Island, 

and Mashhad. This aircraft, bearing 

Iranian tail number EP–MNB, appears to 

be one of the three aircraft that Mahan 

illegally acquired via Blue Airways of 

Armenia and U.K.-based Balli Group 

that resulted in the issuance of the 

original TDO.42 See supra at 10–12. 

Evidence was also described in the 

December 2, 2019 renewal order 

showing that on or about November 11, 

2019, Mahan caused, aided and/or 

abetted the unlicensed export of a U.S.- 

origin atomic absorption spectrometer, 

an item subject to the Regulations, from 

the United States to Iran via the UAE. 

Finally, publicly available flight 

tracking information showed that 

Mahan continued to unlawfully operate 

a number of aircraft subject to the EAR 

on flights into and out of Iran, including 

on routes to and from Guangzhou, 

China, Istanbul, Turkey, and Kuala 

Lumpur, Malaysia.43

The May 29, 2020 renewal order cited 

Mahan’s operation of EP–MMD, EP– 

MMF, and EP–MMI, aircraft originally 

acquired from Al Naser Airlines, on 

international flights into and out of Iran 

from/to Bangkok, Thailand, Dubai, UAE, 

and Shanghai, China in violation of the 

TDO and EAR.44 The May 29, 2020 

renewal order also detailed the 

indictment of Ali Abdullah Alhay and 

Issam Shammout, parties added to the 

TDO in May and July 2015, respectively, 

in the United States District Court for 

the District of Columbia. Alhay and 

Shammout were charged with, among 

other violations, conspiring to export 

aircraft and parts to Mahan in violation 

of export control laws and the embargo 

on Iran beginning around August 2012 

through May 2015. 

In addition to detailing the operation 

of multiple aircraft in violation of the 

Regulations,45 the November 24, 2020 

renewal order discussed a related TDO 

issued on August 19, 2020, denying for 

180 days the export privileges of 

Indonesia-based PT MS Aero Support 

(‘‘PTMS Aero’’), PT Antasena Kreasi 

(‘‘PTAK’’), PT Kandiyasa Energi Utama 

(‘‘PTKEU’’), Sunarko Kuntjoro, Triadi 

Senna Kuntjoro, and Satrio Wiharjo 

Sasmito based on their involvement in 

the unlicensed export of aircraft parts to 

Mahan Airways—often in coordination 

with Mustafa Ovieci, a Mahan 

executive.46 These parties also 

facilitated the shipment of damaged 

Mahan parts to the United States for 

repair and subsequent export back to 

Iran in further violation of U.S. laws. In 

both instances, the fact that the items 

were destined to Iran/Mahan was 

concealed from U.S. companies, 

shippers, and freight forwarders.47

The November 24, 2020 renewal order 

also includes actions taken by other U.S. 

government agencies such as OFAC’s 

August 19, 2020 designation of UAEbased Parthia Cargo, its CEO Amin 

Mahdavi, and Delta Parts Supply FZC as 

SDGTs pursuant to Executive Order 

13224 for providing ‘‘key parts and 

logistics services for Mahan Air . . . .’’ 

The OFAC press release further states, 

in part, that Mahdavi ‘‘has directly 

coordinated the shipment of parts on 

behalf of Mahan Air.’’ 48 In addition, 

Mahdavi and Parthia Cargo were 

indicted in the United States District 

Court for the District of Columbia for 

violating sanctions on Iran.49

Moreover, in October 2020, the U.S. 

District Court for the District of New 

Jersey sentenced Joyce Eliasbachus to 18 

months of confinement based on her 

role in a conspiracy to export $2 million 

dollars’ worth of aircraft parts from the 

United States to Iran, including to 

Mahan Airways.50

The May 21, 2021 renewal order 

outlined Mahan’s continued operation 

of a number of aircraft subject to the 

EAR, including, but not limited to, EP– 

MMH, EP–MMI, and EP–MMQ, on 

international flights into and out of Iran 

from/to Shanghai, China, and Dubai, 

United Arab Emirates, and Guangzhou, 

China, respectively.51

Open source news reporting also 

indicated that after five years of 

maintenance, Mahan Air is now 

operating EP–MNE, a Boeing 747 on 

domestic flights within Iran.52 In 

addition to this aircraft being one of the 

original three Boeing aircraft Mahan 

obtained in violation of the Regulations, 

any service or maintenance involving 


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53Publicly available flight tracking information 

shows that on November 7, 2021, EP–MME (MSN 

376) flew on routes between Istanbul, Turkey and 

Tehran, Iran, and on November 9, 2021, EP–MMJ 

(MSN 526) flew on routes between Dubai, United 

Arab Emirates and Tehran, Iran. In addition, on 

November 8, 2021, EP–MMQ (MSN 346) flew on 

routes between Shenzhen, China and Tehran, Iran. 

54Publicly available flight tracking information 

shows that on May 2, 2022, EP–MME (MSN 376) 

flew on routes between Moscow, Russia and 

Tehran, Iran, and on May 5, 2022, EP–MNO (MSN 

595) flew on routes between Damascus, Syria and 

Tehran, Iran. In addition, on May 6, 2022, EP–MMB 

(MSN 56) flew on routes between Guangzhou, 

China and Tehran, Iran. 

55https://centreforaviation.com/news/mahan-airlaunches-moscow-sheremetyevo-service-1131185. 

56The TDO prohibits Mahan from being eligible 

to use license exception Aircraft, Vessels, and 

Spacecraft (AVS) (§ 740.15 of the EAR). 

57https://home.treasury.gov/system/files/126/ 

20220425_toll.pdf. 

58https://bis.doc.gov/index.php/documents/ 

about-bis/newsroom/press-releases/3138-bis-pressrelease-gp10-iranian-craft-additions/file. 

59Publicly available flight tracking information 

shows that on October 9, 2022, EP–MME (MSN 376) 

flew on routes between Tehran, Iran and Moscow, 

Russia’s VTO airport, and on October 26, 2022, EP– 

MMJ (MSN 526) flew on routes between Tehran, 

Iran and Moscow, Russia’s SVO airport. On October 

28, 2022, EP–MMQ (MSN 346) flew on routes 

between Dubai, United Arab Emirates and Tehran, 

Iran. 

60BIS issued a separate TDO denying the export 

privileges of EMTRASUR for a period of 180 days. 

See 87 FR 47964 (Aug. 5, 2022). 

61On or about February 7, 2020, U.S. Department 

of the Treasury’s Office of Foreign Assets Control 

(‘‘OFAC’’) added CONVIASA, a Venezuelan stateowned airline, to the list of Specially Designated 

Nationals (‘‘SDN’’) pursuant to Executive Order 

(E.O.) 13884. See https://home.treasury.gov/news/ 

press-releases/sm903. 

62Publicly available flight tracking information 

shows that on April 24, 2023, EP–MMQ (MSN 346) 

flew on routes between Guangzhou, China, and 

Tehran, Iran, and on April 27, 2023, EP–MNF (MSN 

547) flew on routes between Kabul, Afghanistan 

and Tehran, Iran. On April 28, 2023, EP–MME 

(MSN 371) flew on routes between Moscow, Russia 

and Tehran, Iran. 

63https://iranpress.com/content/76332/mahanair-launches-direct-flight-from-tehran-minsk. 

64See 88 FR 66807 (Sep. 28, 2023). 

65https://simpleflying.com/aeroflot-airbus-a330- 

maintenance-iran-mahan-air/. 

66Publicly available flight tracking information 

shows that on October 24, 2023, EP–MME (MSN 

371) flew on routes between Erbil, Iraq and Tehran, 

Iran, and on October 23, 2023, EP–MMB (MSN 56) 

flew on routes between Moscow, Russia and 

Tehran, Iran. On October 21–22, 2023, EP–MMQ 

(MSN 346) flew on routes between Lahore, Pakistan 

and Tehran, Iran. 

67See supra at footnote 34. 

68https://www.jns.org/syria-airport-strikes-saidto-stop-iranian-missile-shipment/; https://

www.reuters.com/world/middle-east/syria-state-tvsays-israeli-attack-targets-aleppo-damascusairports-2023-10-12/; https://

www.israelhayom.com/2023/10/17/revealed-thiscould-be-why-israel-allegedly-bombed-2-airportssimultaneously/. 

parts subject to the EAR would further 

violate the TDO. 

The November 17, 2021 order details 

Mahan’s continued operation of a 

number of aircraft subject to the EAR, 

including, but not limited to EP–MME, 

EP–MMJ, EP–MMQ, on flights into and 

out of Iran from/to Istanbul, Turkey, and 

Dubai, United Arab Emirates, and 

Shenzhen, China, respectively.53

Additionally, publicly available 

industry sources showed that EP–MMG 

(MSN 383), an aircraft that Mahan 

acquired from Al Naser Air in violation 

of both the TDO and Regulations, was 

in a maintenance, repair, overhaul 

(‘‘MRO’’) status at Iran’s Imam 

Khomeini International Airport in 

Tehran, Iran. 

The May 13, 2022 renewal order 

outlines Mahan’s continuing violation 

of the TDO and/or Regulations 

including, but not limited to the 

operation of EP–MME, EP–MNO, and 

EP–MMB on flights into and out of Iran 

from/to Moscow, Russia, Damascus, 

Syria, and Guangzhou, China, 

respectively.54 Open source press 

reports also indicates that as of April 

2022, Mahan Air increased its service 

into Moscow, Russia by adding two 

weekly flights to Moscow’s 

Sheremetyevo Airport (‘‘SVO’’) to its 

current service into Moscow’s Vnukovo 

Airport (‘‘VKO’’).55 Mahan flights into 

Russia after February 24, 2022 violated 

the stringent export controls imposed on 

aviation-related (e.g., Commerce Control 

List Categories 7 and 9) items to Russia 

in response to Russia’s further invasion 

of Ukraine. These controls include a 

license requirement for the export, 

reexport or transfer (in-country) to 

Russia of any aircraft or aircraft parts 

specified in Export Control 

Classification Number (ECCN) 9A991 

(§ 746.8(a)(1) of the EAR).56

The May 13, 2022 renewal order also 

cited OFAC’s recent administrative 

enforcement action with an Australian 

freight forwarder resulting in a 

$6,131,855 civil penalty, which 

resolved, in part, allegations of receiving 

327 payments from Mahan that were 

processed through U.S. financial 

institutions or foreign branches of U.S. 

financial institutions in apparent 

violation of OFAC sanctions.57

The November 8, 2022 order detailed 

Mahan Air’s continued violation of the 

TDO and Regulations, including the 

Russia-related export controls set out in 

§ 746.8 of the Regulations. On 

September 19, 2022, BIS publicly 

identified Mahan’s EP–MEE aircraft for 

its unlicensed reexport to Russia in 

apparent violation of § 746.8 of the 

Regulations.58 Additionally, open 

source evidence showed that Mahan 

continues to operate EP–MME, EP– 

MMJ, and EP–MMQ on flights into and 

out of Iran from/to Moscow, Russia, and 

Dubai, United Arab Emirates, 

respectively, without the requisite 

authorization.59

Further, on August 2, 2022, BIS took 

a related enforcement action against 

Venezuela-based cargo airline Empresa 

de Transporte Ae ́reocargo del Sur, S.A., 

a/k/a Aerocargo del Sur Transportation 

Company, a/k/a EMTRASUR 

(‘‘EMTRASUR’’), for acquiring custody 

and/or control from Mahan Air of a 

U.S.-origin Boeing 747 aircraft bearing 

manufacturer’s serial number 23413 

(‘‘MSN 23413’’) in violation of the 

TDO.60 In or around October 2021, 

Mahan Air transferred custody and 

control of MSN 23413 to EMTRASUR’s 

parent company, CONVIASA,61 through 

an intermediary. 

The May 5, 2023 renewal order 

outlined open source evidence showing 

Mahan continuing to operate EP–MNF, 

EP–MMQ, and EP–MME on flights into 

and out of Iran from/to Guangzhou, 

China, Kabul, Afghanistan, and 

Moscow, Russia, respectively, without 

the requisite authorization.62 The 

renewal order also noted the national 

security and foreign policy concerns 

raised by Mahan’s intention to start 

direct flights from Iran to Minsk, 

Belarus.63 Lastly, the May 3, 2023 

renewal order cited publicly available 

information showing that Russian 

airline Aeroflot, which is currently 

subject to its own TDO,64 has begun 

sending its aircraft to Mahan for repairs 

and/or maintenance.65

OEE’s October 31, 2023 renewal 

outlined Mahan’s continued violation of 

the TDO by operating aircraft including 

EP–MME, EP–MMQ, and EP–MMB on 

flights into and out of Iran from/to Erbil, 

Iraq, Shanghai, China, Lahore, Pakistan, 

and Moscow, Russia.66 The October 31, 

2023 order also highlighted OEE’s 

continued investigation into Mahan’s 

recent acquisition of an Airbus A340 

(MSN 75) bearing Iranian tail number 

EP–MJA, and its flights to/from Tehran, 

Iran and Moscow, Russia 

The October 31, 2023 renewal order 

also detailed the on-going national 

security and foreign policy threats and 

concerns raised by Mahan’s 

destabilizing activities. Specifically, 

open source reporting details October 

12, 2023 airstrikes at Syria’s Damascus 

and Aleppo airports made in an effort to 

divert a Mahan A340 (MSN 282 and 

bearing tail number EP–MMC) 67 which 

was in route at the time from Tehran, 

Iran to Syria and suspected of carrying 

weapons.68

OEE’s October 8, 2024 request to 

renew the TDO and its on-going 

investigation further detail Mahan’s 

blatant violations of the TDO by 

operating aircraft including EP–MME, 


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69Publicly available flight tracking information 

shows that on October 13–14, 2024, EP–MME (MSN 

371) flew on routes between Guangzhou, China and 

Tehran, Iran, and on October 10, 2024, EP–MMQ 

(MSN 346) flew on routes between Moscow, Russia 

and Tehran, Iran. On October 15, 2024, EP–MMR 

(MSN 416) flew on routes between Erbil, Iraq and 

Tehran, Iran. 

70Since February 24, 2022, BIS has implemented 

a series of stringent export controls that restrict 

Russia’s access to the technologies and other items 

that it needs to sustain its brutal attack on Ukraine. 

Tier 1 items are of the highest concern due to their 

critical role in the production of advanced Russian 

precision-guided weapons systems, Russia’s lack of 

domestic production, and limited global 

manufacturers. 

71https://www.consilium.europa.eu/en/press/ 

press-releases/2024/10/14/iran-seven-individualsand-seven-entities-sanctioned-in-response-to-iran-smissile-transfer-to-russia/. 

EP–MMQ, EP–MMR on flights into and 

out Iran from/to Guangzhou, China, 

Moscow, Russia, and Erbil, Iraq.69

Additionally, a May 2024 BIS postshipment verification indicated that 

Taiwanese Company No. 1 diverted 

several shipments of electronic 

components to Russia via Iran aboard 

Mahan aircraft. The items at issue were 

subject to the Regulations and included 

items classified under ECCN 3A991.a.2 

and others listed in Tier 1 of BIS’s 

Common High Prior List.70 Mahan’s role 

in transporting the item violated the 

TDO. 

Most recently, in October 2024, the 

European Union imposed sanctions on 

Mahan Air given its role in the ‘‘transfer 

and supply, through transnational 

procurement networks, of Iran-made 

UAVs and related components and 

technologies to Russia, to be used in its 

war of aggression against Ukraine.’’ 71

C. Findings 

Under the applicable standard set 

forth in § 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 imminent violations. Moreover, I find 

that renewal for an extended period is 

appropriate given the pattern of 

repeated, ongoing and/or continuous 

apparent violations of the EAR. 

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 avoid 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. 

III. 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 

ALNASER 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 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, 

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, reexport, or transfer (incountry) 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 


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purposes of this paragraph, servicing 

means installation, maintenance, repair, 

modification or testing. 

Third, that, after notice and 

opportunity for comment as provided in 

§ 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 or other 

connection 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 

§§ 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 §§ 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 

§ 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 § 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 one year. 

Matthew S. Axelrod, 

Assistant Secretary of Commerce for Export 

Enforcement. 

[FR Doc. 2024–25471 Filed 10–31–24; 8:45 am] 

BILLING CODE 3510–DT–P 

DEPARTMENT OF COMMERCE 

International Trade Administration 

Antidumping or Countervailing Duty 

Order, Finding, or Suspended 

Investigation; Opportunity To Request 

Administrative Review and Join 

Annual Inquiry Service List 

AGENCY: Enforcement and Compliance, 

International Trade Administration, 

Department of Commerce. 

FOR FURTHER INFORMATION CONTACT: 

Brenda E. Brown, Office of AD/CVD 

Operations, Customs Liaison Unit, 

Enforcement and Compliance, 

International Trade Administration, 

U.S. Department of Commerce, 1401 

Constitution Avenue NW, Washington, 

DC 20230, telephone: (202) 482–4735. 

SUPPLEMENTARY INFORMATION: 

Background 

Each year during the anniversary 

month of the publication of an 

antidumping duty (AD) or 

countervailing duty (CVD) order, 

finding, or suspended investigation, an 

interested party, as defined in section 

771(9) of the Tariff Act of 1930, as 

amended (the Act), may request, in 

accordance with 19 CFR 351.213, that 

the U.S. Department of Commerce 

(Commerce) conduct an administrative 

review of that AD or CVD order, finding, 

or suspended investigation. 

All deadlines for the submission of 

comments or actions by Commerce 

discussed below refer to the number of 

calendar days from the applicable 

starting date. 

Respondent Selection 

In the event Commerce limits the 

number of respondents for individual 

examination for administrative reviews 

initiated pursuant to requests made for 

the orders identified below, Commerce 

intends to select respondents based on 

U.S. Customs and Border Protection 

(CBP) data for U.S. imports during the 

period of review (POR). We intend to 

release the CBP data under 

Administrative Protective Order (APO) 

to all parties having an APO within five 

days of publication of the initiation 

notice and to make our decision 

regarding respondent selection within 

35 days of publication of the initiation 

Federal Register notice. Therefore, we 

encourage all parties interested in 

commenting on respondent selection to 

submit their APO applications on the 

date of publication of the initiation 

notice, or as soon thereafter as possible. 

Commerce invites comments regarding 

the CBP data and respondent selection 

within five days of placement of the 

CBP data on the record of the review. 

In the event Commerce decides it is 

necessary to limit individual 

examination of respondents and 

conduct respondent selection under 

section 777A(c)(2) of the Act: 

In general, Commerce finds that 

determinations concerning whether 

particular companies should be 

‘‘collapsed’’ (i.e., treated as a single 

entity for purposes of calculating AD 

rates) require a substantial amount of 

detailed information and analysis, 

which often require follow-up questions 

and analysis. Accordingly, Commerce 

will not conduct collapsing analyses at 

the respondent selection phase of a 

review and will not collapse companies 

at the respondent selection phase unless 

there has been a determination to 

collapse certain companies in a 

previous segment of this AD proceeding 

(i.e., investigation, administrative 

review, new shipper review, or changed 

circumstances review). For any 

company subject to a review, if 

Commerce determined, or continued to 

treat, that company as collapsed with 

others, Commerce will assume that such 

companies continue to operate in the 

same manner and will collapse them for 

respondent selection purposes. 

Otherwise, Commerce will not collapse 

companies for purposes of respondent 

selection. Parties are requested to: (a) 

identify which companies subject to 

review previously were collapsed; and 

(b) provide a citation to the proceeding 

in which they were collapsed. Further, 

if companies are requested to complete 

a Quantity and Value Questionnaire for 

purposes of respondent selection, in 

general each company must report 

volume and value data separately for 

itself. Parties should not include data 

for any other party, even if they believe 

they should be treated as a single entity 

with that other party. If a company was 

collapsed with another company or 

companies in the most recently 

completed segment of a proceeding 

where Commerce considered collapsing 

that entity, complete quantity and value 

data for that collapsed entity must be 

submitted. 

Deadline for Withdrawal of Request for 

Administrative Review 

Pursuant to 19 CFR 351.213(d)(1), a 

party that requests a review may 


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