On January 24th, 2019, the Department of Treasury’s Office of Foreign Asset Control (OFAC) designated two Iranian-backed militias, an Iranian airline, and an Armenian travel agency that was providing services to the already-designated Mahan Air. Mahan Air was designated for its contributions to the IRGC’s efforts in Syria.

The militias, Fatemiyoun Division and the Zaynabiyoun Brigade, have been designated for supporting the IRGC’s Qods Force. The Iranian airline, Qeshm Fars Air, has also been designated for being owned or controlled by Mahan Air. Flight Travel LLC, the Armenian travel agency, has also been designated for acting on behalf of Mahan Air. As a result, all the designated entities’ properties and interest in properties in the United States or in possession of US persons are blocked and must be reported to OFAC.

Reasons for the New Designations

The US government has accused the IRGC-QF of using child soldiers and foreign fighters in Syria to defend the Assad regime and to cause chaos in Syria. US government accuses the Fatemiyoun Division of using Afghan migrants in Iran and accuses the Zaynabiyoun Brigade of using Pakistani fighters, mainly Pakistani Shiite immigrants that reside in Iran, to fight against rebel groups and opposition forces to the Assad regime in Syria.

Qeshm Fars Air is a commercial airline that restarted its business activities in 2017 with two B747 aircraft that have been delivering cargo to Damascus. The company was accused of being owned or controlled by Mahan Air, and Mahan Air was designated for similar practices with regards to Syria. OFAC designated the two B747 aircrafts with the tag EP-FAA and EP-FAB. Flight Travel LLC was providing services to Mahan Air, including reservations and ticketing services.

Contact a Knowledgeable Sanctions Attorney

If you holds property or have an interest in property that the designated parties also have an interest in, you must report such property to OFAC. An OFAC lawyer can help in evaluating what qualifies as an interest in property with an SDN and can help in filing with OFAC the necessary forms and documents. Failure to follow OFAC regulations could cause you or your business to become designated, so it is critical to ensure you are in compliance.