May 21, 2015

Treasury Targets Iran’s Support for Terrorism Through its Islamic Revolutionary Guard Corps-Qods Force

by Jeremy Paner

Today, OFAC designated the Iraq-based Al-Naser Airlines, Syrian Issam Shammout, and his Emirates-based Sky Blue Bird Aviation pursuant to its counterterrorism authority (Executive Order 13224) for providing support to Mahan Air, an entity previously designated for providing support to the terrorist group, the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). In its designations of this IRGC-QF terrorist support network, OFAC signaled that it will continue to expose Iran’s support for terrorism.

U.S. individuals and entities are generally prohibited from dealing with these designees, which now appear on OFAC’s Specially Designated Nationals (SDN) List. All property and interests in property held by these designees that is in the United States, or comes into the jurisdiction of the United States at a later date must be blocked. Failure to comply with these prohibitions will lead to civil and in the case of willful violations, criminal penalties.

Interestingly, OFAC’s press release does not provide the historical basis for the designation of Mahan Air as a supporter of terrorism, but rather sets forth a current assessment of the airline’s nefarious deeds. OFAC identifies Mahan Air as a carrier for the terrorist group Hizballah, and transporter of IRGC-QF operatives, weapons and funds in support of the Asad regime in Syria.

According to OFAC’s press release, which is mainly comprised of information that is declassified by the Intelligence Community for this purpose, Al-Nasser Airlines transferred at least nine Airbus passenger jets to Mahan Air this month alone. Issam Shammout and his company Sky Blue Bird Aviation also procured airplanes and parts for Mahan Air.

In addition to the designations, OFAC also published the  identifiers for Mahan Air’s newly acquired Airbus jets. OFAC could facilitate enhanced compliance with its regulations through more frequent use of this “identification of blocked property.” Additional identifiers  assist adherence to U.S. sanctions regulations, as compliance has become increasingly reliant on automated filtering over the more time consuming due diligence process.