On September 8, 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) designated all 27 remaining Iranian passenger airlines and nine Mahan Air-linked support entities across the United Arab Emirates, Turkiye, the United Kingdom, Malaysia and Kazakhstan, adding 36 targets to the Specially Designated Nationals (SDN) List, according to OFAC's September 8 recent actions notice. The same action suspended Iran General License J-1, which had authorized the reexport of civil aircraft to Iran on temporary sojourn, effective immediately, and issued two wind-down licenses covering transactions with the newly blocked persons.
Treasury framed the move as a sweeping grounding of Iran's aviation sector, with Secretary Bessent warning in the accompanying press release that those doing business with Iranian airlines risk being cut off from the global financial system. The designations bind under strict liability, meaning civil penalties can attach without proof of intent.
Which entities were designated, and under what authority?
The 27 Iranian carriers, including Iran Aseman Airlines, ATA Airlines, Kish Airlines, Qeshm Air and Zagros Airlines, were blocked under the Iranian Transactions and Sanctions Regulations (ITSR) and Executive Order 13902, and each carries an explicit secondary-sanctions flag. They join the long-designated Mahan Air and Iran Air in OFAC's Iran aviation network.
The nine support parties, including one individual, Ibrahim Ali Mohamed Mohamed Mahran, were designated under the counter-terrorism authority of Executive Order 13224, as amended by EO 13886, and are tied to Mahan Air. They span ECT Aviation Support LLC (United Arab Emirates) and its London affiliate ECT Aviation Support Ltd, Aerobravo Airplane Management and Operation LLC (Dubai), ICargo SDN BHD (Malaysia), MES Cargo Transportation (Istanbul), S Sistem Lojistik (Istanbul), Sky Phoenix Airways (Izmir) and Tour Invest LLC (Kazakhstan). All carry a secondary-sanctions risk under section 1(b) of EO 13224.
What licenses changed, and what is the wind-down window?
OFAC suspended Iran General License J-1, which had permitted the temporary reexport of civil aircraft to Iran, effective September 8, 2026. In parallel it issued two new authorizations for orderly wind-down of transactions that were previously lawful:
| Instrument | What it does | Status |
|---|---|---|
| Iran General License J-1 | Reexport of civil aircraft to Iran on temporary sojourn | Suspended, September 8, 2026 |
| Counter-Terrorism General License 37 | Wind-down of transactions involving persons blocked on September 8, 2026 | Issued, new |
| Iran General License DD | Wind-down of civil aviation-related transactions previously authorized under the ITSR | Issued, new |
Compliance teams should read the specific wind-down periods in each license rather than assume a uniform window, because the two instruments authorize different transaction sets and carry different expiry dates.
Who is exposed, and what must compliance teams do now?
The exposed audience is broad and clearly identifiable: USD-clearing banks, aircraft lessors, airlines, freight forwarders, insurers and sanctions-screening vendors. Because OFAC operates under the 50 Percent Rule, any entity 50 percent or more owned in the aggregate by a blocked person is itself blocked even when not separately listed, so name-only screening of the 36 designations is insufficient.
Civil penalties attach under 31 CFR Part 501 without proof of intent, though voluntary self-disclosure can reduce a penalty by up to 50 percent. The secondary-sanctions exposure is the harder reach for non-U.S. parties: foreign persons that transact with the designated airlines or the Mahan Air support network risk losing access to the U.S. financial system and the U.S. dollar, even with no U.S. nexus. Extraterritoriality flows through USD clearing, so any payment touching a U.S. bank implicates OFAC jurisdiction. Obsidian's continuous, per-jurisdiction real-time monitoring surfaces a change like this the moment OFAC publishes it.
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Screen all counterparties, lessees, freight partners and beneficial owners against the updated SDN list immediately, applying the 50 Percent Rule to each Iranian airline and Mahan Air-linked entity. Review any open civil-aviation exposure to Iran under General License J-1 and pause transactions that no longer have authorization. Map the wind-down windows of General Licenses 37 and DD against your live contracts, and brief sanctions, aviation and treasury teams on the secondary-sanctions risk before the next USD clearing cycle.
