The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has issued an Advisory for the civil aviation industry, including parties providing services to that industry warning them not to engage in or support unauthorized transfers of U.S. origin aircraft or related goods to Iran or those who do business with Iranian airlines. The potential sanctions and prosecutions could be significant for violations.
The Advisory has an interesting section relating to financial institutions relating to the unauthorized purchase, sale, delivery or provision of goods or services to Iran, its Government, its airlines even if the transactions are conducted wholly outside the United States.
“…Foreign financial institutions that knowingly conduct or facilitate significant financial transactions for or on behalf of certain designated Iran related persons…may be exposed to sanctions… which may include loss of access to the U.S. financial system.
Since early 2018, the U.S. has designated 10 entities that have provided support to Mahan Air, including front companies procuring spare aircraft parts, general sales agents providing services in Malaysia, Thailand and Armenia…”
U.S. sanctions on Iran cover a wide range of activities. They prohibit U.S. persons and U.S. owned or controlled foreign entities from engaging with or involving Iran, the Government of Iran and Iranian financial institutions. Read more about our Iran Sanctions
Individuals with information concerning violation of these sanctions against Iran may be able to bring a lawsuit against the violators on behalf of the federal government. These whistleblower False Claims Act cases allow for a whistleblower award of up to 30% of what the Government recovers if such a case is brought. For more information, contact Jeffrey Newman at 617-823-3217.