Mahan Airways BIS TDO renewed one year
One-year TDO renewal under EAR § 766.24 for a pattern of repeated apparent violations. Effective immediately. Keep screening records.
BIS renewed the temporary denial order (TDO) denying export privileges for Mahan Airways and related parties under EAR Section 766.24. Assistant Secretary of Commerce for Export Enforcement David A. Peters signed the order October 22, 2026. It is effective immediately and remains in effect for one year. The notice was placed on public inspection October 26, 2026, and is scheduled for publication October 27, 2026 (FR Doc. 2026-21840). OEE requested renewal September 8, 2026; no opposition was received.
Mahan Airways TDO renewed for one year from Oct 22, 2026. Pattern of repeated apparent EAR violations. Screen the named Denied Persons.
Why one year, not 180 days
The original TDO took effect March 21, 2008. This renewal continues the October 27, 2025 TDO. BIS may renew for up to one year (rather than 180 days) where there is a pattern of repeated, ongoing and/or continuous apparent violations. The Assistant Secretary found that standard met and that renewal is necessary in the public interest to prevent an imminent violation of the EAR.
New evidence cited in the renewal includes: three of the five Boeing 777-212ER aircraft identified in the October 27, 2025 renewal now carry Iranian tail numbers EP-MTE (MSN 33369), EP-MTB (MSN 28527), and EP-MTA (MSN 28522) and are flying Mahan routes including to/from Moscow, Beijing, and Muscat (flight tracking on August 25, 2026); July 30, 2026 OFAC designations of parties in China, India, and Russia acting as general service agents for Mahan Air under EO 13224; and September 8, 2026 OFAC Mahan-related designations of entities in the UAE, Turkey, and Malaysia (Operation Economic Outcast), some of which aided efforts to obtain three additional Boeing 777 aircraft in Summer 2026 via the UAE and Oman.
Public inspection Oct 26, 2026 · scheduled publication Oct 27, 2026 · renews Oct 27, 2025 TDO · original TDO effective Mar 21, 2008
OEE renewal request Sep 8, 2026 · no opposition · Assistant Secretary David A. Peters
New evidence: EP-MTE / EP-MTB / EP-MTA on Mahan routes · OFAC EO 13224 designations Jul 30 and Sep 8, 2026
Denied Persons on this renewal
Respondents who may appeal the order: Mahan Airways; Al Naser Airlines (and aliases); Ali Abdullah Alhay; Bahar Safwa General Trading. Related persons who may appeal their inclusion: 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; Sky Blue Bird Group (and aliases); Issam Shammout (and aliases).
FIRST and SECOND prohibitions
- FIRST: Denied Persons may not, directly or indirectly, participate in any transaction involving any item exported or to be exported from the United States that is subject to the EAR, or in any other activity subject to the EAR (including licenses, negotiations, financing, forwarding, or benefitting from such transactions).
- SECOND: No person may export, reexport, or transfer (in-country) to or on behalf of a Denied Person any item subject to the EAR; facilitate their acquisition of such items; acquire from them; obtain from them in the U.S. knowing of intended export; or service items they own or control when that service involves EAR-subject items exported or to be exported from the United States.
- FOURTH: The Order does not prohibit transactions where the only items subject to the EAR are the foreign-produced direct product of U.S.-origin technology.
BIS may seek renewal by filing not later than 20 days before expiration. Respondents named above may oppose no later than seven days before expiration. For broader BIS end-user screening context as the Affiliates Rule return approaches, see BIS Affiliates Rule returns November 2026.
An export used to support a drawback claim must still comply with the EAR. No person may export or reexport items subject to the EAR to or on behalf of a Denied Person. Screen parties and keep records before you rely on an export for a claim.
Action items
- Screen against the Denied Persons List and the parties named in this renewal (respondents and related persons).
- Check end users and routings involving the UAE, Turkey, Oman, Iraq, and Malaysia, and aviation parts / MRO / carrier channels that could touch Mahan or Al Naser.
- Keep screening records for exports that will also support drawback filings.
- FR Doc. 2026-21840: BIS renews Mahan Airways TDO for one year, effective Oct 22, 2026. Public inspection Oct 26; scheduled publication Oct 27, 2026.
- Renewal under EAR § 766.24 based on a pattern of repeated, ongoing and/or continuous apparent violations. OEE request Sep 8, 2026; no opposition.
- New evidence includes Iranian-tailed 777s on Mahan routes and OFAC Mahan-related designations Jul 30 and Sep 8, 2026.
- FIRST/SECOND bars Denied Person participation and third-party exports to or on behalf of them. Drawback exports must still comply with the EAR.
- Denial of Export Privileges: Mahan Airways, Pejman Mahmood Kosarayanifard a/k/a Kosarian Fard, et al. (Order Renewing Order Temporarily Denying Export Privileges) (FR Doc. 2026-21840) · U.S. Department of Commerce, Bureau of Industry and Security
- Order Renewing Order Temporarily Denying Export Privileges (Mahan Airways et al.) (public inspection PDF) · Federal Register Public Inspection
This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.
