BIS Renews Mahan Airways Denial Order for One Year

The Mahan Airways temporary denial order has been renewed for one year, reinforcing a broad set of restrictions on exports, reexports, transfers, acquisitions, and servicing. Exporters, freight forwarders, aviation suppliers, carriers, and compliance teams should treat the renewal as an immediate reason to reassess screening, routing, and end-use controls.

What the One-Year BIS Renewal Changes

The Bureau of Industry and Security renewed the temporary denial order against Mahan Airways and multiple related parties on October 22, 2026. The order took effect immediately and remains active for one year, extending the denial of export privileges that has been maintained through successive renewals since the original order became effective in March 2008.

The denied parties include Mahan Airways, Pejman Mahmood Kosarayanifard, also known as Kosarian Fard, Mahmoud Amini, Kerman Aviation, Sirjanco Trading LLC, Mahan Air General Trading LLC, Mehdi Bahrami, Al Naser Airlines, Ali Abdullah Alhay, Bahar Safwa General Trading, Sky Blue Bird Group, and Issam Shammout.

The one-year term is operationally significant. Temporary denial orders are often associated with shorter renewal periods, but BIS may impose a longer period when circumstances indicate repeated, ongoing, or continuous apparent violations of the Export Administration Regulations. No opposition was filed in response to the September 8, 2026 renewal request.

Why the Aircraft Activity Matters

The renewal highlights continued aviation activity involving U.S.-origin aircraft. Three Boeing 777-212ER aircraft identified in the previous renewal now carry Iranian tail numbers EP-MTE, EP-MTB, and EP-MTA. These aircraft have operated on Mahan routes that include destinations such as Moscow, Beijing, and Muscat.

For compliance teams, the issue extends beyond the aircraft themselves. Aircraft operations depend on a complex network of parts suppliers, maintenance organizations, ground handlers, freight forwarders, agents, lessors, and technical service providers. A transaction that appears to involve an independent intermediary may create exposure if the goods, software, technology, or services ultimately support a denied person or an item owned or controlled by that person.

Transactions Restricted by the Denial Order

The BIS denial order reaches much further than direct shipments addressed to Mahan Airways. No person may export, reexport, or transfer an item subject to the EAR to a denied person, on behalf of a denied person, or in circumstances that facilitate the denied person's acquisition or control of the item.

The restrictions can also affect purchases and servicing arrangements. Parties generally may not acquire items subject to the EAR from a denied person. They also may not service an item that is owned, possessed, or controlled by a denied person when the service involves an item subject to the EAR. This creates substantial risk for aviation maintenance, repair, overhaul, parts exchange, leasing, and logistics transactions.

Facilitation Can Create Compliance Exposure

Companies should not assume that avoiding a direct contract with a named party eliminates risk. Facilitation may arise through indirect procurement, transshipment, technical assistance, financing, freight arrangements, brokering, or documentation support. A supplier that knowingly ships aviation components to an intermediary for onward delivery to a denied person may face the same core compliance concerns as a direct exporter.

The risk is especially acute when transactions involve newly formed trading companies, general sales agents, vague end-use statements, changing consignees, or routing through multiple jurisdictions. Activity connected to the UAE, Turkey, Oman, Iraq, Malaysia, China, India, or Russia may warrant heightened review when aviation items or Mahan-related routes are involved. Geography alone is not determinative, but it can contribute to an overall risk assessment.

The Foreign-Produced Direct Product Limitation

The order does not prohibit a transaction when the only items subject to the EAR are foreign-produced direct products of U.S.-origin technology. This is a narrow limitation, not a general exemption for foreign-made aviation items.

Companies should classify all relevant commodities, software, and technology before relying on this language. Other EAR restrictions, sanctions requirements, licensing rules, or end-user controls may still apply. Legal and compliance review is generally appropriate before proceeding with any transaction that could benefit a denied party.

Building Effective Screening and Routing Controls

A denied party compliance program should combine automated screening with transaction-level judgment. Screening only the customer name at onboarding is rarely sufficient for aviation supply chains, where buyers, consignees, operators, beneficial owners, freight forwarders, and end users may be different entities.

Every transaction should generally be screened against the Denied Persons List and other applicable restricted party lists. Screening should cover legal names, trade names, known aliases, individual principals, addresses, and relevant ownership or control relationships. Mahan-related names should also be reviewed for spelling variations, transliterations, and abbreviations that can prevent simple exact-name matching.

Review the Full Transaction Network

Compliance teams should identify the purchaser, intermediate consignee, ultimate consignee, end user, aircraft operator, maintenance provider, freight forwarder, and any agent directing the movement of the goods. Purchase orders, air waybills, maintenance records, end-use statements, payment instructions, and aircraft tail numbers can reveal connections that are not apparent from the commercial invoice.

Potential warning signs include last-minute destination changes, requests to remove aircraft identifiers, payments from unrelated third parties, inconsistent end-use descriptions, and delivery to a general trading company without a clear aviation role. Routes through transshipment hubs should receive additional scrutiny when the item could support commercial aircraft operations.

Screening records should document the names searched, lists checked, date and time of review, potential matches, resolution steps, and final disposition. Rescreening is typically appropriate before shipment because restricted party data and transaction details can change after order acceptance.

Drawback Exports Still Require EAR Compliance

An export used to support a duty drawback claim must remain compliant with U.S. export controls. Drawback eligibility does not authorize an otherwise prohibited export, reexport, transfer, or service transaction. Customs brokers and importers should therefore preserve a clear separation between drawback qualification and export authorization analysis.

The drawback file should align with export records, commercial documentation, classification data, and screening evidence. If an export involves a denied party or prohibited facilitation, the existence of potential drawback recovery does not reduce the underlying enforcement risk. Trade compliance and drawback teams should coordinate before treating an export as eligible support for a claim.

Frequently Asked Questions

When Did the Renewed Mahan Airways Order Take Effect?

The renewed order was signed on October 22, 2026, took effect immediately, and remains effective for one year. It continues a temporary denial order first imposed in March 2008 and subsequently renewed as BIS identified continuing concerns involving apparent EAR violations.

Which Parties Are Covered by the Order?

The order covers Mahan Airways and named related parties, including individuals, aviation businesses, and trading companies. Among them are Kerman Aviation, Sirjanco Trading LLC, Mahan Air General Trading LLC, Al Naser Airlines, Bahar Safwa General Trading, Sky Blue Bird Group, and several named individuals. Screening should account for aliases and spelling variations.

Can a Company Sell Parts Through an Unrelated Distributor?

Using a distributor does not resolve the issue if the supplier knows, has reason to know, or identifies warning signs indicating that the items will reach or benefit a denied person. The order restricts facilitation as well as direct transactions. Suppliers should verify the true end user, aircraft operator, destination, and intended use before authorizing shipment.

Does the Order Apply Only to Aircraft and Aircraft Parts?

No. The restrictions generally apply to items subject to the EAR, not only complete aircraft or aviation components. Depending on the transaction, covered items could include equipment, software, technology, tools, test systems, or other products. Classification and jurisdiction analysis are necessary to determine whether an item is subject to the EAR.

Can a Drawback Claim Be Filed for an Export Connected to Mahan Airways?

Duty drawback does not override export control restrictions. An export supporting a drawback claim must still comply with the EAR and other applicable requirements. If the export, transfer, facilitation, or associated service is prohibited, potential drawback eligibility does not make the transaction lawful. Brokers should verify compliance before relying on the export in a claim.

How Stable Software Can Help

Support Consistent Trade Compliance Workflows

Denied party risk requires repeatable screening, documented review, and coordination across sales, logistics, export compliance, and customs functions. Companies evaluating technology for this process can explore Stable Software's denied party screening platform as part of their compliance planning.

For customs brokers managing refund programs, Stable Software also makes DrawbackAI, flat-license duty drawback software that brokers can white-label for importer clients and use to file under their own filer codes. Stable Software charges a flat software license and never takes a percentage of the refund. This model allows brokers to maintain control of the client relationship while keeping export compliance review separate from drawback eligibility and claim preparation.

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