BIS Renews Temporary Denial of Export Privileges Against Mahan Airways and Related Parties for One Year

BIS renewed the temporary denial order first issued in 2008 and most recently renewed on October 27, 2025, against Mahan Airways and eleven related parties for one year, effective immediately. The Assistant Secretary found renewal necessary in the public interest to prevent an imminent violation of the Export Administration Regulations and appropriate given Mahan Airways’ pattern of repeated, ongoing and/or continuous apparent violations. The order prohibits the denied persons from participating in any way in transactions involving items subject to the EAR and bars others from exporting, reexporting, transferring, facilitating, or servicing such items for or with the denied persons.

Who this affects

• For exporters: No person may export, reexport, or transfer items subject to the EAR to or on behalf of a Denied Person, or facilitate acquisition of ownership, possession, or control of such items.
• For investors: The order covers Mahan Airways and related entities operating across Iran, UAE, France, Iraq, Syria, UK, Turkey, and other locations, with prohibitions extending to successors, assigns, agents, and employees.
• For counsel/compliance: The order is effective immediately and remains in effect for one year; appeals may be filed with the Office of the Administrative Law Judge, and BIS may seek renewal not later than 20 days before expiration.
• For policymakers: Renewal rests on the determination of significant, deliberate, and covert apparent violations and the likelihood of imminent further violations.

The read

The record documents a continuous pattern since the original March 17, 2008 order, with repeated renewals, including evidence of unauthorized reexports of U.S.-origin aircraft, Iranian registration of Boeing 777-212ER aircraft (EP-MTE MSN 33369, EP-MTB MSN 28527, EP-MTA MSN 28522), and operations on routes involving Russia, China, and Oman. The renewal extends the same prohibitions without modification to the core denial of export privileges, consistent with prior actions under Section 766.24.

What was the action?

The Assistant Secretary of Commerce for Export Enforcement granted the Office of Export Enforcement’s request to renew the temporary denial order issued on October 27, 2025, finding renewal necessary to prevent an imminent violation and appropriate given the pattern of apparent violations.

What’s the penalty / scope, and how is it set?

No monetary penalty is stated. The order denies the listed persons export privileges for one year: they may not apply for, obtain, or use licenses or participate in any transaction or activity subject to the EAR involving items exported from the United States. No person may export, reexport, transfer, facilitate, acquire from, or service items subject to the EAR for or with the Denied Persons. The order does not prohibit transactions involving only foreign-produced direct products of U.S.-origin technology.

Who else is exposed?

The order applies to the named Denied Persons (Mahan Airways, Pejman Mahmood Kosarayanifard a/k/a Kosarian Fard, Mahmoud Amini, Kerman Aviation a/k/a GIE Kerman Aviation, Sirjanco Trading LLC, Mahan Air General Trading LLC, Mehdi Bahrami, Al Naser Airlines and aliases, Ali Abdullah Alhay and aliases, Bahar Safwa General Trading, Sky Blue Bird Group and aliases, Issam Shammout and aliases) and their successors, assigns, agents, and employees. Related persons previously added remain subject; others affiliated may be added after notice.

What happens next

The order remains in effect for one year. BIS may seek renewal by written request not later than 20 days before expiration; Mahan Airways, Al Naser Airlines, Ali Abdullah Alhay, and Bahar Safwa General Trading may oppose by written submission received not later than seven days before expiration. Appeals of the order or of related-person status may be filed at any time with the Office of the Administrative Law Judge.