OFAC targets the Iranian aviation sector

OFAC imposed blocking sanctions on one individual (Egyptian national based in the UAE) and 35 entities (27 in Iran; two in UAE; one in UK; three in Turkey; one in Malaysia; one in Kazakhstan) under its counterterrorism (E.O. 13224, as amended), global terrorism and Iran sanctions programs (E.O. 13902) targeting the support of Iran's aviation industry and Mahan Air's proliferation, terrorist-linked flight operations, and illicit aircraft procurement. Concurrently, OFAC suspended indefinitely three ITSR aviation-related general licenses/authorizations: 1. 31 CFR § 560.522 (overflight payments), 2. § 560.529 (bunkering/emergency repairs), and 3. Iran GL J-1 (temporary sojourn of U.S.-origin civil aircraft). In conjunction with the suspension of the above licenses, OFAC issued General License DD, authorizing all transactions prohibited by the ITSR that are ordinarily incident and necessary to the wind down of any transaction previously authorized by the above applicable general licenses (31 CFR §§ 560.522 and 560.529, and Iran General License J-1) until September 23, 2026. Alongside these actions, OFAC issued Counterterrorism General License No. 37, authorizing wind-down transactions through September 23, 2026 involving ECT Aviation Support LLC, S Sistem Lojistik Hizmetler A.Ş., Mes Cargo Transportation Tourism and Foreign Trade Ltd., and any entity 50%-or-more owned by them, provided payments to blocked persons are made into a blocked, interest-bearing U.S. account.