On October 27, 2026, the U.S. Bureau of Industry and Security published in the Federal Register, at 91 FR 67542, an order signed on October 22, 2026 by David A. Peters, Assistant Secretary of Commerce for Export Enforcement, renewing the temporary denial of export privileges for Mahan Airways, Al Naser Airlines and the related persons named in the order, under section 766.24 of the Export Administration Regulations, 15 CFR parts 730-774. The order is effective immediately and remains in effect for one year.
US exporters and reexporters of aircraft and aircraft parts subject to the EAR, aircraft lessors and MRO shops servicing EAR-subject aircraft that could be operated for Mahan Airways or Al Naser Airlines, freight forwarders and parts distributors in the UAE, Turkey and the EU who move EAR items, and US and non-US banks and brokers facilitating acquisition of EAR-subject aircraft or engines for the named denied persons must immediately screen those counterparties and refuse any export, reexport, in-country transfer or servicing of EAR items to or for them, or the dealing violates the renewed order and the EAR. BIS renewed the order to prevent an imminent violation, citing three Boeing 777-212ER aircraft flying Mahan routes under Iranian tail numbers EP-MTE, EP-MTB and EP-MTA.
- Authority : Bureau of Industry and Security, Assistant Secretary for Export Enforcement
- Entity : Mahan Airways, with Al Naser Airlines and the related persons named in the order
- Measure and amount : renewal of a temporary denial of export privileges, no fine stated
- Legal basis : EAR section 766.24, 15 CFR parts 730-774, under 50 U.S.C. 4820(a)(5)
- Decision date : signed October 22, 2026, published October 27, 2026 (91 FR 67542)
- Appeal or compliance window : appeal at any time under EAR sections 766.24(e) and 766.23(c)(2)
- Official source : Federal Register notice, 91 FR 67542
What happened
The order grants the Office of Export Enforcement request of September 8, 2026 to renew the temporary denial order last renewed on October 27, 2025. The Assistant Secretary found a pattern of repeated, ongoing or continuous apparent violations, and that renewal is necessary in the public interest to prevent an imminent violation.
The new facts are three Boeing 777-212ER airframes from the October 27, 2025 renewal: N99001 (MSN 33369), N99004 (MSN 28527) and N99005 (MSN 28522). The September 8, 2026 request states they carry EP-MTE, EP-MTB and EP-MTA and fly Mahan routes into and out of Iran, including Moscow, Beijing and Muscat. The order also records OFAC designations on July 30, 2026 and September 8, 2026 of parties that it says aided Mahan, including efforts to obtain three further Boeing 777 aircraft in the summer of 2026 via the UAE and Oman.
The breach
Under section 766.24, the order finds significant, deliberate and covert violations and a likelihood of imminent violations. It directs: "no person may, directly or indirectly, do any of the following: A. Export, reexport, or transfer (in-country) to or on behalf of a Denied Person any item subject to the EAR." The same paragraph bars facilitating a denied person's acquisition of an EAR item exported from the United States and servicing an item the denied person owns, possesses or controls when the service uses an EAR item. Servicing means installation, maintenance, repair, modification or testing. The fourth clause does not prohibit a transaction where the only EAR items are the foreign-produced direct product of U.S.-origin technology. BIS may seek renewal by a written request filed not later than 20 days before the one-year term ends.
Who else is in the same regime
The audience is every other person who could place an EAR item with, or service an item for, the denied persons: US exporters and reexporters of EAR aircraft and parts, lessors and MRO shops whose EAR-subject aircraft could be operated for Mahan Airways or Al Naser Airlines, freight forwarders and parts distributors in the UAE, Turkey and the EU, and banks and brokers who could finance EAR aircraft or engines for the named denied persons.
The order's screen list, besides Mahan Airways and Al Naser Airlines, is Pejman Mahmood Kosarayanifard, Mahmoud Amini, Kerman Aviation, Sirjanco Trading LLC, Mahan Air General Trading LLC, Mehdi Bahrami, Ali Abdullah Alhay, Bahar Safwa General Trading, Sky Blue Bird Group and Issam Shammout, plus agents and employees acting for them.
What to check now
- Screen counterparties, owners, lessees, operators, agents and banks against every denied person named in 91 FR 67542 before any EAR transaction.
- Refuse any export, reexport or in-country transfer of an EAR item to or on behalf of a denied person, including aircraft, engines and parts.
- Refuse installation, maintenance, repair, modification or testing of an item a denied person owns, possesses or controls when that service uses an EAR item.
- Refuse financing of a denied person's acquisition of an EAR item exported from the United States, including MSNs 33369, 28527 and 28522.
- Hold a transaction that relies on the foreign-produced direct product carve-out until counsel confirms no other EAR item is involved.
- Watch for a BIS renewal request not later than 20 days before the one-year term ends, and for any section 766.23 related-person addition.
Continuous, per-jurisdiction monitoring surfaces a denial order of this kind on the Federal Register publication date.
