Order Renewing Order Temporarily Denying Export Privileges, 44002-44006 [2014-17798]
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Federal Register / Vol. 79, No. 145 / Tuesday, July 29, 2014 / Notices
equines to take certain actions in
loading and transporting the equines
and to certify that the commercial
transportation meets certain
requirements. In addition, the
regulations prohibit the commercial
transportation for slaughter of equines
considered to be unfit for travel, the use
of electric prods on such animals in
commercial transportation for slaughter,
and the use of double-deck trailers for
commercial transportation of equines
for slaughter.
These regulations require information
collection activities, including a USDA–
APHIS Owner/Shipper Certificate
Fitness to Travel to a Slaughter Facility
Form/Continuation Sheet (Veterinary
Services-VS Forms 10–13/10–13A),
maintaining copies of the signed VS
Forms 10–13/10–13A, and the
collection of business information from
any individual or other entity found to
be transporting horses for slaughter.
This notice includes the information
collection requirements currently
approved by the Office of Management
and Budget (OMB) for the commercial
transportation of equines for slaughter
under OMB control numbers 0579–0332
and 0579–0160. These collection
activities are collecting the same
information; therefore, we are
combining them. As a result, we have
adjusted the values in the burden
summary to reflect the values listed in
the most recent renewal of OMB control
number 0579–0160. After OMB
approves and combines the burden for
both collections under one collection
(0579–0332), the USDA will retire OMB
control number 0579–0160.
We are asking OMB to approve our
use of these information collection
activities, as described, for an additional
3 years.
The purpose of this notice is to solicit
comments from the public (as well as
affected agencies) concerning our
information collection. These comments
will help us:
(1) Evaluate whether the collection of
information is necessary for the proper
performance of the functions of the
Agency, including whether the
information will have practical utility;
(2) Evaluate the accuracy of our
estimate of the burden of the collection
of information, including the validity of
the methodology and assumptions used;
(3) Enhance the quality, utility, and
clarity of the information to be
collected; and
(4) Minimize the burden of the
collection of information on those who
are to respond, through use, as
appropriate, of automated, electronic,
mechanical, and other collection
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technologies; e.g., permitting electronic
submission of responses.
Estimate of burden: The public
reporting burden for this collection of
information is estimated to average
0.7483 hours per response.
Respondents: Owners and shippers of
slaughter horses, owners or operators of
slaughtering facilities, and drivers of the
transport vehicles.
Estimated annual number of
respondents: 300.
Estimated annual number of
responses per respondent: 43.666.
Estimated annual number of
responses: 13,100.
Estimated total annual burden on
respondents: 9,803 hours. (Due to
averaging, the total annual burden hours
may not equal the product of the annual
number of responses multiplied by the
reporting burden per response.)
All responses to this notice will be
summarized and included in the request
for OMB approval. All comments will
also become a matter of public record.
Done in Washington, DC, this 23rd day of
July 2014.
Kevin Shea,
Administrator, Animal and Plant Health
Inspection Service.
[FR Doc. 2014–17884 Filed 7–28–14; 8:45 am]
BILLING CODE 3410–34–P
DEPARTMENT OF COMMERCE
Bureau of Industry and Security
Order Renewing Order Temporarily
Denying Export Privileges
Mahan Airways, Mahan Tower, No. 21,
Azadegan St., M.A. Jenah Exp. Way,
Tehran, Iran
Gatewick LLC, a/k/a Gatewick Freight &
Cargo Services, a/k/a/Gatewick
Aviation Services, G#22 Dubai
Airport Free Zone, P.O. Box 393754,
Dubai, United Arab Emirates, and
P.O. Box 52404, Dubai, United Arab
Emirates, and, Mohamed Abdulla
Alqaz Building, Al Maktoum Street,
Al Rigga, Dubai, United Arab Emirates
Pejman Mahmood Kosarayanifard, a/k/a
Kosarian Fard, P.O. Box 52404, Dubai,
United Arab Emirates
Mahmoud Amini, G#22 Dubai Airport
Free Zone, P.O. Box 393754, Dubai,
United Arab Emirates, and P.O. Box
52404, Dubai, United Arab Emirates,
and Mohamed Abdulla Alqaz
Building, Al Maktoum Street, Al
Rigga, Dubai, United Arab Emirates
Kerman Aviation, a/k/a GIE Kerman
Aviation, 42 Avenue Montaigne
75008, Paris, France
Sirjanco Trading LLC, P.O. Box 8709,
Dubai, United Arab Emirates
PO 00000
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Ali Eslamian, 4th Floor, 33 Cavendish
Square, London, W1G0PW, United
Kingdom, and 2 Bentinck Close,
Prince Albert Road St. Johns Wood,
London NW87RY, United Kingdom
Mahan Air General Trading LLC, 19th
Floor Al Moosa Tower One, Sheik
Zayed Road, Dubai 40594, United
Arab Emirates
Skyco (UK) Ltd., 4th Floor, 33
Cavendish Square, London, W1G 0PV,
United Kingdom
Equipco (UK) Ltd., 2 Bentinck Close,
Prince Albert Road, London, NW8
7RY, United Kingdom
Mehdi Bahrami, Mahan AirwaysIstanbul Office, Cumhuriye Cad. Sibil
Apt No: 101 D:6, 34374 Emadad, Sisli
Istanbul, Turkey
Pursuant to Section 766.24 of the
Export Administration Regulations, 15
CFR Parts 730–774 (2014) (‘‘EAR’’ or the
‘‘Regulations’’), I hereby grant the
request of the Office of Export
Enforcement (‘‘OEE’’) to renew the
January 24, 2014 Order Temporarily
Denying the Export Privileges of Mahan
Airways, Gatewick LLC, Pejman
Mahmood Kosarayanifard, Mahmoud
Amini, Kerman Aviation, Sirjanco
Trading LLC, Ali Eslamian, Mahan Air
General Trading LLC, Skyco (UK) Ltd.,
Equipco (UK) Ltd., and Mehdi
Bahrami.1 I find that renewal of the
Temporary Denial Order (‘‘TDO’’) is
necessary in the public interest to
prevent an imminent violation of the
EAR.
I. Procedural History
On March 17, 2008, Darryl W.
Jackson, the then-Assistant Secretary of
Commerce for Export Enforcement
(‘‘Assistant Secretary’’), signed a TDO
denying Mahan Airways’ export
privileges for a period of 180 days on
the grounds that its issuance was
necessary in the public interest to
prevent an imminent violation of the
Regulations. The TDO also named as
denied persons Blue Airways, of
Yerevan, Armenia (‘‘Blue Airways of
Armenia’’), as well as the ‘‘Balli Group
Respondents,’’ namely, Balli Group
PLC, Balli Aviation, Balli Holdings,
Vahid Alaghband, Hassan Alaghband,
Blue Sky One Ltd., Blue Sky Two Ltd.,
Blue Sky Three Ltd., Blue Sky Four Ltd.,
Blue Sky Five Ltd., and Blue Sky Six
Ltd., all of the United Kingdom. The
TDO was issued ex parte pursuant to
Section 766.24(a), and went into effect
on March 21, 2008, the date it was
published in the Federal Register.
The TDO subsequently has been
renewed in accordance with Section
766.24(d), including most recently on
1 See
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January 24, 2014.2 As of March 9, 2010,
the Balli Group Respondents and Blue
Airways were no longer subject to the
TDO. As part of the February 25, 2011
TDO renewal, Gatewick LLC, Mahmoud
Amini, and Pejman Mahmood
Kosarayanifard (‘‘Kosarian Fard’’) were
added as related persons in accordance
with Section 766.23 of the Regulations.
On July 1, 2011, the TDO was modified
by adding Zarand Aviation as a
respondent in order to prevent an
imminent violation. As part of the
August 24, 2011 renewal, Kerman
Aviation, Sirjanco Trading LLC, and Ali
Eslamian were added to the TDO as
related persons. Mahan Air General
Trading LLC, Skyco (UK) Ltd., and
Equipco (UK) Ltd. were added as related
persons on April 9, 2012. Mehdi
Bahrami was added to the TDO as a
related person as part of the February 4,
2013 renewal order.
On July 1, 2014, BIS, through its
Office of Export Enforcement (‘‘OEE’’),
submitted a written request for renewal
of the TDO.3 The current TDO dated
January 24, 2014, will expire on July 22,
2014, unless renewed on or before that
date. Notice of the renewal request was
provided to Mahan Airways in
accordance with Sections 766.5 and
766.24(d) of the Regulations. No
opposition to the renewal of the TDO
has been received from Mahan.
Furthermore, no appeal of the related
person determinations I made as part of
the September 3, 2010, February 25,
2011, August 24, 2011, April 9, 2012,
and February 4, 2013 renewal or
modification orders has been made by
Gatewick LLC, Kosarian Fard,
Mahmoud Amini, Kerman Aviation,
Sirjanco Trading LLC, Ali Eslamian,
Mahan Air General Trading LLC, Skyco
(UK) Ltd., Equipco (UK) Ltd., or Mehdi
Bahrami.4
2 The January 24, 2014 Order was published in
the Federal Register on January 30, 2014. 79 FR
4871 (Jan. 30, 2014). The TDO previously had been
renewed on September 17, 2008, March 16, 2009,
September 11, 2009, March 9, 2010, September 3,
2010, February 25, 2011, August 24, 2011, February
15, 2012, August 9, 2012, February 4, 2013, and July
31, 2013. The August 24, 2011 renewal followed the
modification of the TDO on July 1, 2011, which
added Zarand Aviation as a respondent. Each
renewal or modification order was published in the
Federal Register.
3 The July 1, 2014 renewal request sought renewal
as to all parties subject to the January 24, 2014
Order, including Zarand Aviation. Upon further
review and consideration, OEE has withdrawn its
request that the TDO be renewed as to Zarand
Aviation. No other aspect of the renewal request is
affected by the withdrawal as to Zarand.
4 A party named or added as a related person may
not oppose the issuance or renewal of the
underlying temporary denial order, but may file an
appeal of the related person determination in
accordance with Section 766.23(c).
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II. Renewal of the TDO
A. Legal Standard
Pursuant to Section 766.24, BIS may
issue or renew an order temporarily
denying a respondent’s export privileges
upon a showing that the order is
necessary in the public interest to
prevent an ‘‘imminent violation’’ of the
Regulations. 15 CFR §§ 766.24(b)(1) and
776.24(d). ‘‘A violation may be
‘imminent’ either in time or degree of
likelihood.’’ 15 CFR § 766.24(b)(3). BIS
may show ‘‘either that a violation is
about to occur, or that the general
circumstances of the matter under
investigation or case under criminal or
administrative charges demonstrate a
likelihood of future violations.’’ Id. As
to the likelihood of future violations,
BIS may show that the violation under
investigation or charge ‘‘is significant,
deliberate, covert and/or likely to occur
again, rather than technical or
negligent[.]’’ Id. A ‘‘lack of information
establishing the precise time a violation
may occur does not preclude a finding
that a violation is imminent, so long as
there is sufficient reason to believe the
likelihood of a violation.’’ Id.
B. The TDO and BIS’s Request for
Renewal
OEE’s request for renewal is based
upon the facts underlying the issuance
of the initial TDO and the TDO renewals
in this matter and the evidence
developed over the course of this
investigation indicating a blatant
disregard of U.S. export controls and the
TDO. The initial TDO was issued as a
result of evidence that showed that
Mahan Airways and other parties
engaged in conduct prohibited by the
EAR by knowingly re-exporting to Iran
three U.S.-origin aircraft, specifically
Boeing 747s (‘‘Aircraft 1–3’’), items
subject to the EAR and classified under
Export Control Classification Number
(‘‘ECCN’’) 9A991.b, without the required
U.S. Government authorization. Further
evidence submitted by BIS indicated
that Mahan Airways was involved in the
attempted re-export of three additional
U.S.-origin Boeing 747s (‘‘Aircraft 4–6’’)
to Iran.
As discussed in the September 17,
2008 renewal order, evidence presented
by BIS indicated that Aircraft 1–3
continued to be flown on Mahan
Airways’ routes after issuance of the
TDO, in violation of the Regulations and
the TDO itself.5 It also showed that
Aircraft 1–3 had been flown in further
violation of the Regulations and the
in conduct prohibited by a denial
order violates the Regulations. 15 CFR §§ 764.2(a)
and (k).
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TDO on the routes of Iran Air, an
Iranian Government airline. Moreover,
as discussed in the March 16, 2009,
September 11, 2009 and March 9, 2010
Renewal Orders, Mahan Airways
registered Aircraft 1–3 in Iran, obtained
Iranian tail numbers for them (including
EP–MNA and EP–MNB), and continued
to operate at least two of them in
violation of the Regulations and the
TDO,6 while also committing an
additional knowing and willful
violation of the Regulations and the
TDO when it negotiated for and
acquired an additional U.S.-origin
aircraft. The additional acquired aircraft
was an MD–82 aircraft, which
subsequently was painted in Mahan
Airways’ livery and flown on multiple
Mahan Airways’ routes under tail
number TC–TUA.
The March 9, 2010 Renewal Order
also noted that a court in the United
Kingdom (‘‘U.K.’’) had found Mahan
Airways in contempt of court on
February 1, 2010, for failing to comply
with that court’s December 21, 2009 and
January 12, 2010 orders compelling
Mahan Airways to remove the Boeing
747s from Iran and ground them in the
Netherlands. Mahan Airways and the
Balli Group Respondents had been
litigating before the U.K. court
concerning ownership and control of
Aircraft 1–3. In a letter to the U.K. court
dated January 12, 2010, Mahan Airways’
Chairman indicated, inter alia, that
Mahan Airways opposes U.S.
Government actions against Iran, that it
continued to operate the aircraft on its
routes in and out of Tehran (and had
158,000 ‘‘forward bookings’’ for these
aircraft), and that it wished to continue
to do so and would pay damages if
required by that court, rather than
ground the aircraft.
The September 3, 2010 renewal order
discussed the fact that Mahan Airways’
violations of the TDO extended beyond
operating U.S.-origin aircraft in
violation of the TDO and attempting to
acquire additional U.S.-origin aircraft.
In February 2009, while subject to the
TDO, Mahan Airways participated in
the export of computer motherboards,
items subject to the Regulations and
designated as EAR99, from the United
States to Iran, via the United Arab
Emirates (‘‘UAE’’), in violation of both
the TDO and the Regulations, by
transporting and/or forwarding the
computer motherboards from the UAE
to Iran. Mahan Airways’ violations were
facilitated by Gatewick LLC, which not
6 The third Boeing 747 appeared to have
undergone significant service maintenance and may
not have been operational at the time of the March
9, 2010 renewal order.
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only participated in the transaction, but
also has stated to BIS that it acts as
Mahan Airways’ sole booking agent for
cargo and freight forwarding services in
the UAE.
Moreover, in a January 24, 2011 filing
in the U.K. court, Mahan Airways
asserted that Aircraft 1–3 were not being
used, but stated in pertinent part that
the aircraft were being maintained in
Iran especially ‘‘in an airworthy
condition’’ and that, depending on the
outcome of its U.K. court appeal, the
aircraft ‘‘could immediately go back into
service . . . on international routes into
and out of Iran.’’ Mahan Airways’
January 24, 2011 submission to U.K.
Court of Appeal, at p. 25, ¶¶ 108, 110.
This clearly stated intent, both on its
own and in conjunction with Mahan
Airways’ prior misconduct and
statements, demonstrated the need to
renew the TDO in order to prevent
imminent future violations. Two of
these three 747s subsequently were
removed from Iran and are no longer in
Mahan Airway’s possession. The third
of these 747s, with Manufacturer’s
Serial Number (‘‘MSN’’) 23480 and
Iranian tail number EP–MNE, remains
in Iran under Mahan’s control. Pursuant
to Executive Order 13324, it was
designated a Specially Designated
Global Terrorist (‘‘SDGT’’) by the U.S.
Department of the Treasury’s Office of
Foreign Assets Control (‘‘OFAC’’) on
September 19, 2012.7 Furthermore, as
discussed in the February 4, 2013 Order,
open source information indicated that
this 747, which is painted in the livery
and logo of Mahan Airways, has been
flown between Iran and Syria, and was
suspected of ferrying weapons and/or
other equipment to the Syrian
Government from Iran’s Islamic
Revolutionary Guard Corps. Open
source information showed that this
aircraft remained in active operation in
Mahan Airways’ fleet and had flown
from Iran to Syria as recently as June 30,
2013.
In addition, as first detailed in the
July 1, 2011 and August 24, 2011 orders,
and discussed in subsequent renewal
orders in this matter, Mahan Airways
also continued to evade U.S. export
control laws by operating two Airbus
A310 aircraft, bearing Mahan Airways’
livery, colors and logo, on flights into
and out of Iran.8 At the time of the July
7 See https://www.treasury.gov/resource-center/
sanctions/OFAC-Enforcement/pages/
20120919.aspx.
8 The Airbus A310s are powered with U.S.-origin
engines. The engines are subject to the EAR and
classified under Export Control Classification
(‘‘ECCN’’) 9A991.d. The Airbus A310s contain
controlled U.S.-origin items valued at more than 10
percent of the total value of the aircraft and as a
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1, 2011 and August 24, 2011 Orders,
these Airbus A310s were registered in
France, with tail numbers F–OJHH and
F–OJHI, respectively.9
The August 2012 renewal order also
found that Mahan Airways had acquired
another Airbus A310 aircraft subject to
the Regulations,10 with MSN 499 and
Iranian tail number EP–VIP, in violation
of the TDO and the Regulations. On
September 19, 2012, all three Airbus
A310 aircraft (tail numbers F–OJHH, F–
OJHI, and EP–VIP) were designated as
SDGTs.11
The February 4, 2013 Order laid out
further evidence of continued and
additional efforts by Mahan Airways
and other persons acting in concert with
Mahan, including Kral Aviation and
another Turkish company, to procure
U.S.-origin engines (MSNs 517621 and
517738) and other aircraft parts in
violation of the TDO and the
Regulations.12 The February 4, 2013
renewal order also added Mehdi
Bahrami as a related person in
accordance with Section 766.23 of the
Regulations. Bahrami, a Mahan VicePresident and the head of Mahan’s
result are subject to the EAR. They are classified
under ECCN 9A991.b. The reexport of these aircraft
to Iran requires U.S. Government authorization
pursuant to Section 746.7 of the Regulations.
9 OEE subsequently presented evidence that after
the August 24, 2011 renewal, Mahan Airways
worked along with Kerman Aviation and others to
de-register the two Airbus A310 aircraft in France
and to register both aircraft in Iran (with,
respectively, Iranian tail numbers EP–MHH and
EP–MHI). It was determined subsequent to the
February 15, 2012 renewal order that the
registration switch for these A310s was cancelled
and that Mahan Airways then continued to fly the
aircraft under the original French tail numbers (F–
OJHH and F–OJHI, respectively).
10 See note 8, supra.
11 See https://www.treasury.gov/resource-center/
sanctions/OFAC-Enforcement/pages/
20120919.aspx. Mahan Airways was previously
designated by OFAC as a SDGT on October 18,
2011. 77 FR 64,427 (October 18, 2011).
12 Kral Aviation was referenced in the February
4, 2013 Order as ‘‘Turkish Company No. 1.’’ Kral
Aviation purchased a GE CF6–50C2 aircraft engine
(MSN517621) from the United States in July 2012,
on behalf of Mahan Airways. OEE was able to
prevent this engine from reaching Mahan by issuing
a redelivery order to the freight forwarder in
accordance with Section 758.8 of the Regulations.
OEE also issued Kral Aviation a redelivery order for
the second CF6–50C2 engine (MSN 517738) on July
30, 2012. The owner of the second engine
subsequently cancelled the item’s sale to Kral
Aviation. In September 2012, OEE was alerted by
a U.S. exporter that another Turkish company
(‘‘Turkish Company No. 2’’) was attempting to
purchase aircraft spare parts intended for re-export
by Turkish Company No. 2 to Mahan Airways. See
February 4, 2013 Order.
On December 31, 2013, Kral Aviation was added
to BIS’s Entity List, Supplement No. 4 to Part 744
of the Regulations. See 78 FR75458 (Dec. 12, 2013).
Companies and individuals are added to the Entity
List for engaging in activities contrary to the
national security or foreign policy interests of the
United States. See 15 CFR § 744.11.
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Istanbul Office, also was involved in
Mahan’s acquisition of the original three
Boeing 747s (Aircraft 1–3) that resulted
in the original TDO, and has had a
business relationship with Mahan
dating back to 1997.
The July 31, 2013 Order detailed
additional evidence obtained by OEE
showing efforts by Mahan Airways to
obtain another GE CF6–50C2 aircraft
engine (MSN 528350) from the United
States via Turkey. Multiple Mahan
employees, including Mehdi Bahrami,
were involved in or aware of matters
related to the engine’s arrival in Turkey
from the United States, plans to visually
inspect the engine, and prepare it for
shipment from Turkey.
Mahan sought to obtain this U.S.origin engine through Pioneer Logistics
Havacilik Turizm Yonetim Danismanlik
(‘‘Pioneer Logistics’’), an aircraft parts
supplier located in Turkey, and its
director/operator, Gulnihal Yegane, a
Turkish national who previously has
conducted Mahan related business with
Mehdi Bahrami and Ali Eslamian.
Moreover, as referenced in the July 31,
2013 Order, a sworn affidavit by Kosol
Surinanda, also known as Kosol
Surinandha, Managing Director of
Mahan’s General Sales Agent in
Thailand, stated that the shares of
Pioneer Logistics for which he is the
listed owner are ‘‘actually the property
of and owned by Mahan.’’ He further
stated that he held ‘‘legal title to the
shares until otherwise required by
Mahan’’ but would ‘‘exercise the rights
granted to [him] exactly and only as
instructed by Mahan and [his] vote and/
or decisions [would] only and
exclusively reflect the wills and
demands of Mahan[.]’’ 13
The January 24, 2014 Order outlines
OEE’s continued investigation of Mahan
Airways’ activities and detailed an
attempt by Mahan, which OEE
thwarted, to obtain, via an Indonesian
aircraft parts supplier, two U.S.-origin
Honeywell ALF–502R–5 aircraft engines
(MSNs LF5660 and LF5325), items
subject to the Regulations, from a U.S.
company located in Texas. An invoice
of the Indonesian aircraft parts supplier
dated March 27, 2013, listed Mahan
Airways as the purchaser of the engines
and included a Mahan ship-to address.
OEE also obtained a Mahan air waybill
dated March 12, 2013, listing numerous
U.S.-origin aircraft parts, including, but
not limited to, a vertical navigation
gyroscope, a transmitter, and a power
control unit, items subject to the
13 Pioneer Logistics, Gulnihal Yegane, and Kosol
Surinanda also were added to the Entity List on
December 12, 2013. See 78 FR 75458 (Dec. 12,
2013).
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Regulations, being transported by
Mahan from Turkey to Iran in violation
of the TDO.
OEE’s on-going investigation and
current renewal request include
evidence discovered or obtained after
the January 24, 2014 Order was issued
that further establishes Mahan Airways’
efforts to obtain and operate aircraft
subject to the EAR in violation of the
TDO and the Regulations. Open source
evidence from the March-June 2014
time period shows two BAE regional jets
painted in the livery and logo of Mahan
Airways and operating under Iranian
tail numbers EP–MOK and EP–MOI,
respectively. In addition, aviation
industry resources indicate that these
aircraft were obtained by Mahan
Airways in late November 2013 and
June 2014, from Ukrainian
Mediterranean Airline, a Ukrainian
airline that was added to BIS’s Entity
List on August 15, 2011, for acting
contrary to the national security and
foreign policy interests of the United
States.14 These BAE jets are subject to
the EAR and their acquisition and/or
operation by Mahan Airways violates
the TDO.15
Open source evidence from the April–
June 2014 time period likewise shows
two Airbus 320 aircraft painted in the
livery and logo of Mahan Airways and
operating under Iranian tail numbers
EP–MMK and EP–MML, respectively.
OEE’s investigation also shows that
Mahan obtained these aircraft in
November 2013, from Khors Air
Company, another Ukrainian airline that
like, Ukrainian Mediterranean Airlines,
was added to BIS’s Entity List on
August 15, 2011, for acting contrary to
the national security and foreign policy
interests of the United States.16 These
Airbus 320 aircraft are also subject to
the EAR.17
14 Supplement No. 4 to Part 744 of the
Regulations. See 76 FR 50407 (Aug. 15, 2011).
15 The BAE regional jets are powered with U.S.origin engines. The engines are subject to the EAR
and classified under ECCN 9A991.d. These aircraft
contain controlled U.S.-origin items valued at more
than 10 percent of the total value of the aircraft and
as a result are subject to the EAR. They are
classified under ECCN 9A991.b. The reexport of
these aircraft to Iran requires U.S. Government
authorization pursuant to Section 746.7 of the
Regulations.
16 Supplement No. 4 to Part 744 of the
Regulations. See 76 FR 50407 (Aug. 15, 2011).
17 The Airbus A320s are powered with U.S.-origin
engines. The engines are subject to the EAR and
classified under ECCN 9A991.d. These aircraft
contain controlled U.S.-origin items valued at more
than 10 percent of the total value of the aircraft and
as a result are subject to the EAR. They are
classified under ECCN 9A991.b. The reexport of
these aircraft to Iran requires U.S. Government
authorization pursuant to Section 746.7 of the
Regulations.
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This evidence shows that Mahan
Airways has continued its pattern of
acquiring and attempting to acquire, via
third countries, both U.S.-origin jet
aircraft and other jet aircraft subject to
the Regulations with the intent to own,
control and/or operate the aircraft in
violation of both the TDO and
Regulations. Mahan Airways similarly
continues to publically list a number of
other such aircraft including at least one
Boeing 747 and Airbus 310s in its active
fleet.
C. Findings
Under the applicable standard set
forth in Section 766.24 of the
Regulations and my review of the entire
record, I find that the evidence
presented by BIS convincingly
demonstrates that Mahan Airways has
continually violated the EAR and the
TDO, that such knowing violations have
been significant, deliberate and covert,
and that there is a likelihood of future
violations. OEE’s on-going investigation
continues to reveal or discover
additional attempts by Mahan to acquire
items subject to the Regulations through
its extensive network of agents and
affiliates in third countries. Therefore,
renewal of the TDO is necessary to
prevent imminent violation of the EAR
and to give notice to companies and
individuals in the United States and
abroad that they should continue to
cease dealing with Mahan Airways and
the other denied persons under the TDO
in export transactions involving items
subject to the EAR.
IV. ORDER
It is therefore ordered: First, that
MAHAN AIRWAYS, Mahan Tower, No.
21, Azadegan St., M.A. Jenah Exp. Way,
Tehran, Iran; GATEWICK LLC, A/K/A
GATEWICK FREIGHT & CARGO
SERVICES, A/K/A GATEWICK
AVIATION SERVICE, G#22 Dubai
Airport Free Zone, P.O. Box 393754,
Dubai, United Arab Emirates, and P.O.
Box 52404, Dubai, United Arab
Emirates, and Mohamed Abdulla Alqaz
Building, Al Maktoum Street, Al Rigga,
Dubai, United Arab Emirates; PEJMAN
MAHMOOD KOSARAYANIFARD
A/K/A KOSARIAN FARD, P.O. Box
52404, Dubai, United Arab Emirates;
MAHMOUD AMINI, G#22 Dubai
Airport Free Zone, P.O. Box 393754,
Dubai, United Arab Emirates, and P.O.
Box 52404, Dubai, United Arab
Emirates, and Mohamed Abdulla Alqaz
Building, Al Maktoum Street, Al Rigga,
Dubai, United Arab Emirates; KERMAN
AVIATION A/K/A GIE KERMAN
AVIATION, 42 Avenue Montaigne
75008, Paris, France; SIRJANCO
TRADING LLC, P.O. Box 8709, Dubai,
PO 00000
Frm 00006
Fmt 4703
Sfmt 4703
44005
United Arab Emirates; ALI ESLAMIAN,
4th Floor, 33 Cavendish Square, London
W1G0PW, United Kingdom, and 2
Bentinck Close, Prince Albert Road St.
Johns Wood, London NW87RY, United
Kingdom; MAHAN AIR GENERAL
TRADING LLC, 19th Floor Al Moosa
Tower One, Sheik Zayed Road, Dubai
40594, United Arab Emirates; SKYCO
(UK) LTD., 4th Floor, 33 Cavendish
Square, London, W1G 0PV, United
Kingdom; EQUIPCO (UK) LTD., 2
Bentinck Close, Prince Albert Road,
London, NW8 7RY, United Kingdom;
and MEHDI BAHRAMI, Mahan
Airways—Istanbul Office, Cumhuriye
Cad. Sibil Apt No: 101 D:6, 34374
Emadad, Sisli Istanbul, Turkey; and
when acting for or on their behalf, any
successors or assigns, agents, or
employees (each a ‘‘Denied Person’’ and
collectively the ‘‘Denied Persons’’) may
not, directly or indirectly, participate in
any way in any transaction involving
any commodity, software or technology
(hereinafter collectively referred to as
‘‘item’’) exported or to be exported from
the United States that is subject to the
Export Administration Regulations
(‘‘EAR’’), or in any other activity subject
to the EAR including, but not limited to:
A. Applying for, obtaining, or using
any license, License Exception, or
export control document;
B. Carrying on negotiations
concerning, or ordering, buying,
receiving, using, selling, delivering,
storing, disposing of, forwarding,
transporting, financing, or otherwise
servicing in any way, 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; or
C. Benefitting in any way from 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.
Second, that no person may, directly
or indirectly, do any of the following:
A. Export or reexport to or on behalf
of a Denied Person any item subject to
the EAR;
B. Take any action that facilitates the
acquisition or attempted acquisition by
a Denied Person of the ownership,
possession, or control of any item
subject to the EAR that has been or will
be exported from the United States,
including financing or other support
activities related to a transaction
whereby a Denied Person acquires or
attempts to acquire such ownership,
possession or control;
C. Take any action to acquire from or
to facilitate the acquisition or attempted
acquisition from a Denied Person of any
E:\FR\FM\29JYN1.SGM
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rmajette on DSK2TPTVN1PROD with NOTICES
44006
Federal Register / Vol. 79, No. 145 / Tuesday, July 29, 2014 / Notices
item subject to the EAR that has been
exported from the United States;
D. Obtain from a Denied Person in the
United States any item subject to the
EAR with knowledge or reason to know
that the item will be, or is intended to
be, exported from the United States; or
E. Engage in any transaction to service
any item subject to the EAR that has
been or will be exported from the
United States and which is owned,
possessed or controlled by a Denied
Person, or service any item, of whatever
origin, that is owned, possessed or
controlled by a Denied Person if such
service involves the use of any item
subject to the EAR that has been or will
be exported from the United States. For
purposes of this paragraph, servicing
means installation, maintenance, repair,
modification or testing.
Third, that, after notice and
opportunity for comment as provided in
section 766.23 of the EAR, any other
person, firm, corporation, or business
organization related to a Denied Person
by affiliation, ownership, control, or
position of responsibility in the conduct
of trade or related services may also be
made subject to the provisions of this
Order.
Fourth, that this Order does not
prohibit any export, reexport, or other
transaction subject to the EAR where the
only items involved that are subject to
the EAR are the foreign-produced direct
product of U.S.-origin technology.
In accordance with the provisions of
Sections 766.24(e) of the EAR, Mahan
Airways may, at any time, appeal this
Order by filing a full written statement
in support of the appeal with the Office
of the Administrative Law Judge, U.S.
Coast Guard ALJ Docketing Center, 40
South Gay Street, Baltimore, Maryland
21202–4022. In accordance with the
provisions of Sections 766.23(c)(2) and
766.24(e)(3) of the EAR, Gatewick LLC,
Mahmoud Amini, Pejman Mahmood
Kosarayanifard, Kerman Aviation,
Sirjanco Trading LLC, Ali Eslamian,
Mahan Air General Trading LLC, Skyco
(UK) Ltd., Equipco (UK) Ltd., and/or
Mehdi Bahrami may, at any time, appeal
their inclusion as a related person by
filing a full written statement in support
of the appeal with the Office of the
Administrative Law Judge, U.S. Coast
Guard ALJ Docketing Center, 40 South
Gay Street, Baltimore, Maryland 21202–
4022.
In accordance with the provisions of
Section 766.24(d) of the EAR, BIS may
seek renewal of this Order by filing a
written request not later than 20 days
before the expiration date. A renewal
request may be opposed by Mahan
Airways as provided in Section
766.24(d), by filing a written submission
VerDate Mar<15>2010
15:02 Jul 28, 2014
Jkt 232001
with the Assistant Secretary of
Commerce for Export Enforcement,
which must be received not later than
seven days before the expiration date of
the Order.
A copy of this Order shall be provided
to Mahan Airways and each related
person, and shall be published in the
Federal Register. This Order is effective
immediately and shall remain in effect
for 180 days.
Dated: July 22, 2014.
David W. Mills,
Assistant Secretary of Commerce for Export
Enforcement.
[FR Doc. 2014–17798 Filed 7–28–14; 8:45 a.m.]
BILLING CODE P
DEPARTMENT OF COMMERCE
International Trade Administration
[A–520–803]
Polyethylene Terephthalate Film,
Sheet, and Strip From the United Arab
Emirates: Initiation of AntiCircumvention Inquiry on Antidumping
Duty Order
Enforcement and Compliance,
International Trade Administration,
Department of Commerce.
SUMMARY: In response to a request from
Polyplex USA LLC and Flex USA, Inc.,
(collectively Domestic Producers), the
Department of Commerce (the
Department) is initiating an anticircumvention inquiry pursuant to
section 781(b) of the Tariff Act of 1930,
as amended (the Act), to determine
whether certain imports of polyethylene
terephthalate film, sheet, and strip (PET
Film) are circumventing the
antidumping duty (AD) order on PET
Film from the United Arab Emirates
(UAE).1
DATES: Effective Date: July 29, 2014.
FOR FURTHER INFORMATION CONTACT:
Andrew Huston, AD/CVD Operations,
Office VII, Enforcement and
Compliance, International Trade
Administration, U.S. Department of
Commerce, 14th Street and Constitution
Avenue NW., Washington, DC 20230;
telephone: (202) 482–4261.
SUPPLEMENTARY INFORMATION:
AGENCY:
Background
On September 28, 2007, DuPont
Teijin Films; Mitsubishi Polyester Film
Polyethylene Terephthalate Film, Sheet, and
Strip From Brazil, the People’s Republic of China
and the United Arab Emirates: Antidumping Duty
Orders and Amended Final Determination of Sales
at Less Than Fair Value for the United Arab
Emirates, 73 FR 66595 (November 10, 2008)
(Order).
PO 00000
1 See
Frm 00007
Fmt 4703
Sfmt 4703
of America; SKC, Inc.; and Toray
Plastics (America), Inc., (collectively
Petitioners) filed a petition seeking the
imposition of antidumping duties on
imports of PET film from Brazil, the
People’s Republic of China (China),
Thailand, and the UAE. Following the
Department’s affirmative finding of
dumping and the U.S. International
Trade Commission (ITC) finding of
threat of injury, the Department issued
AD orders on imports of the subject
merchandise. In the first administrative
review of the Order, Petitioners
requested a review of JBF RAK LLC (JBF
RAK), and JBF RAK also requested a
review of itself. On December 23, 2009,
the Department initiated an
administrative review of JBF RAK.2 The
company has also been reviewed in
each subsequent administrative review.
JBF RAK’s current cash deposit rate is
1.41 percent.3
On May 27, 2014, pursuant to section
781(b) of the Act and section 19 CFR
351.225(h), Domestic Producers
submitted a request for the Department
to initiate an anti-circumvention inquiry
to determine whether JBF RAK is
circumventing the Order on PET Film
from the UAE by exporting to the
United States products completed or
assembled in its Bahrain facility, JBF
Bahrain S.P.C. (JBF Bahrain), from
inputs sourced from the subject
countries India and the UAE.
Scope of the Order
The products covered by the order are
all gauges of raw, pre-treated, or primed
polyethylene terephthalate film,
whether extruded or co-extruded.
Excluded are metallized films and other
finished films that have had at least one
of their surfaces modified by the
application of a performance-enhancing
resinous or inorganic layer more than
0.00001 inches thick. Also excluded is
roller transport cleaning film which has
at least one of its surfaces modified by
application of 0.5 micrometers of SBR
latex. Tracing and drafting film is also
excluded. Polyethylene terephthalate
film is classifiable under subheading
3920.62.00.90 of the Harmonized Tariff
Schedule of the United States (HTSUS).
While HTSUS subheadings are provided
for convenience and customs purposes,
our written description of the scope of
the order is dispositive.
2 See Initiation of Antidumping and
Countervailing Duty Administrative Reviews and
Request for Revocation in Part, 74 FR 68229, 68232
(December 23, 2009).
3 See Polyethylene Terephthalate Film, Sheet, and
Strip from the United Arab Emirates: Final Results
of Antidumping Duty Administrative Review; 2011–
2012, 79 FR 24401 (April 30, 2014).
E:\FR\FM\29JYN1.SGM
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Agencies
[Federal Register Volume 79, Number 145 (Tuesday, July 29, 2014)]
[Notices]
[Pages 44002-44006]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-17798]
=======================================================================
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DEPARTMENT OF COMMERCE
Bureau of Industry and Security
Order Renewing Order Temporarily Denying Export Privileges
Mahan Airways, Mahan Tower, No. 21, Azadegan St., M.A. Jenah Exp. Way,
Tehran, Iran
Gatewick LLC, a/k/a Gatewick Freight & Cargo Services, a/k/a/Gatewick
Aviation Services, G22 Dubai Airport Free Zone, P.O. Box
393754, Dubai, United Arab Emirates, and P.O. Box 52404, Dubai, United
Arab Emirates, and, Mohamed Abdulla Alqaz Building, Al Maktoum Street,
Al Rigga, Dubai, United Arab Emirates
Pejman Mahmood Kosarayanifard, a/k/a Kosarian Fard, P.O. Box 52404,
Dubai, United Arab Emirates
Mahmoud Amini, G22 Dubai Airport Free Zone, P.O. Box 393754,
Dubai, United Arab Emirates, and P.O. Box 52404, Dubai, United Arab
Emirates, and Mohamed Abdulla Alqaz Building, Al Maktoum Street, Al
Rigga, Dubai, United Arab Emirates
Kerman Aviation, a/k/a GIE Kerman Aviation, 42 Avenue Montaigne 75008,
Paris, France
Sirjanco Trading LLC, P.O. Box 8709, Dubai, United Arab Emirates
Ali Eslamian, 4th Floor, 33 Cavendish Square, London, W1G0PW, United
Kingdom, and 2 Bentinck Close, Prince Albert Road St. Johns Wood,
London NW87RY, United Kingdom
Mahan Air General Trading LLC, 19th Floor Al Moosa Tower One, Sheik
Zayed Road, Dubai 40594, United Arab Emirates
Skyco (UK) Ltd., 4th Floor, 33 Cavendish Square, London, W1G 0PV,
United Kingdom
Equipco (UK) Ltd., 2 Bentinck Close, Prince Albert Road, London, NW8
7RY, United Kingdom
Mehdi Bahrami, Mahan Airways-Istanbul Office, Cumhuriye Cad. Sibil Apt
No: 101 D:6, 34374 Emadad, Sisli Istanbul, Turkey
Pursuant to Section 766.24 of the Export Administration
Regulations, 15 CFR Parts 730-774 (2014) (``EAR'' or the
``Regulations''), I hereby grant the request of the Office of Export
Enforcement (``OEE'') to renew the January 24, 2014 Order Temporarily
Denying the Export Privileges of Mahan Airways, Gatewick LLC, Pejman
Mahmood Kosarayanifard, Mahmoud Amini, Kerman Aviation, Sirjanco
Trading LLC, Ali Eslamian, Mahan Air General Trading LLC, Skyco (UK)
Ltd., Equipco (UK) Ltd., and Mehdi Bahrami.\1\ I find that renewal of
the Temporary Denial Order (``TDO'') is necessary in the public
interest to prevent an imminent violation of the EAR.
---------------------------------------------------------------------------
\1\ See note 3, infra.
---------------------------------------------------------------------------
I. Procedural History
On March 17, 2008, Darryl W. Jackson, the then-Assistant Secretary
of Commerce for Export Enforcement (``Assistant Secretary''), signed a
TDO denying Mahan Airways' export privileges for a period of 180 days
on the grounds that its issuance was necessary in the public interest
to prevent an imminent violation of the Regulations. The TDO also named
as denied persons Blue Airways, of Yerevan, Armenia (``Blue Airways of
Armenia''), as well as the ``Balli Group Respondents,'' namely, Balli
Group PLC, Balli Aviation, Balli Holdings, Vahid Alaghband, Hassan
Alaghband, Blue Sky One Ltd., Blue Sky Two Ltd., Blue Sky Three Ltd.,
Blue Sky Four Ltd., Blue Sky Five Ltd., and Blue Sky Six Ltd., all of
the United Kingdom. The TDO was issued ex parte pursuant to Section
766.24(a), and went into effect on March 21, 2008, the date it was
published in the Federal Register.
The TDO subsequently has been renewed in accordance with Section
766.24(d), including most recently on
[[Page 44003]]
January 24, 2014.\2\ As of March 9, 2010, the Balli Group Respondents
and Blue Airways were no longer subject to the TDO. As part of the
February 25, 2011 TDO renewal, Gatewick LLC, Mahmoud Amini, and Pejman
Mahmood Kosarayanifard (``Kosarian Fard'') were added as related
persons in accordance with Section 766.23 of the Regulations. On July
1, 2011, the TDO was modified by adding Zarand Aviation as a respondent
in order to prevent an imminent violation. As part of the August 24,
2011 renewal, Kerman Aviation, Sirjanco Trading LLC, and Ali Eslamian
were added to the TDO as related persons. Mahan Air General Trading
LLC, Skyco (UK) Ltd., and Equipco (UK) Ltd. were added as related
persons on April 9, 2012. Mehdi Bahrami was added to the TDO as a
related person as part of the February 4, 2013 renewal order.
---------------------------------------------------------------------------
\2\ The January 24, 2014 Order was published in the Federal
Register on January 30, 2014. 79 FR 4871 (Jan. 30, 2014). The TDO
previously had been renewed on September 17, 2008, March 16, 2009,
September 11, 2009, March 9, 2010, September 3, 2010, February 25,
2011, August 24, 2011, February 15, 2012, August 9, 2012, February
4, 2013, and July 31, 2013. The August 24, 2011 renewal followed the
modification of the TDO on July 1, 2011, which added Zarand Aviation
as a respondent. Each renewal or modification order was published in
the Federal Register.
---------------------------------------------------------------------------
On July 1, 2014, BIS, through its Office of Export Enforcement
(``OEE''), submitted a written request for renewal of the TDO.\3\ The
current TDO dated January 24, 2014, will expire on July 22, 2014,
unless renewed on or before that date. Notice of the renewal request
was provided to Mahan Airways in accordance with Sections 766.5 and
766.24(d) of the Regulations. No opposition to the renewal of the TDO
has been received from Mahan. Furthermore, no appeal of the related
person determinations I made as part of the September 3, 2010, February
25, 2011, August 24, 2011, April 9, 2012, and February 4, 2013 renewal
or modification orders has been made by Gatewick LLC, Kosarian Fard,
Mahmoud Amini, Kerman Aviation, Sirjanco Trading LLC, Ali Eslamian,
Mahan Air General Trading LLC, Skyco (UK) Ltd., Equipco (UK) Ltd., or
Mehdi Bahrami.\4\
---------------------------------------------------------------------------
\3\ The July 1, 2014 renewal request sought renewal as to all
parties subject to the January 24, 2014 Order, including Zarand
Aviation. Upon further review and consideration, OEE has withdrawn
its request that the TDO be renewed as to Zarand Aviation. No other
aspect of the renewal request is affected by the withdrawal as to
Zarand.
\4\ A party named or added as a related person may not oppose
the issuance or renewal of the underlying temporary denial order,
but may file an appeal of the related person determination in
accordance with Section 766.23(c).
---------------------------------------------------------------------------
II. Renewal of the TDO
A. Legal Standard
Pursuant to Section 766.24, BIS may issue or renew an order
temporarily denying a respondent's export privileges upon a showing
that the order is necessary in the public interest to prevent an
``imminent violation'' of the Regulations. 15 CFR Sec. Sec.
766.24(b)(1) and 776.24(d). ``A violation may be `imminent' either in
time or degree of likelihood.'' 15 CFR Sec. 766.24(b)(3). BIS may show
``either that a violation is about to occur, or that the general
circumstances of the matter under investigation or case under criminal
or administrative charges demonstrate a likelihood of future
violations.'' Id. As to the likelihood of future violations, BIS may
show that the violation under investigation or charge ``is significant,
deliberate, covert and/or likely to occur again, rather than technical
or negligent[.]'' Id. A ``lack of information establishing the precise
time a violation may occur does not preclude a finding that a violation
is imminent, so long as there is sufficient reason to believe the
likelihood of a violation.'' Id.
B. The TDO and BIS's Request for Renewal
OEE's request for renewal is based upon the facts underlying the
issuance of the initial TDO and the TDO renewals in this matter and the
evidence developed over the course of this investigation indicating a
blatant disregard of U.S. export controls and the TDO. The initial TDO
was issued as a result of evidence that showed that Mahan Airways and
other parties engaged in conduct prohibited by the EAR by knowingly re-
exporting to Iran three U.S.-origin aircraft, specifically Boeing 747s
(``Aircraft 1-3''), items subject to the EAR and classified under
Export Control Classification Number (``ECCN'') 9A991.b, without the
required U.S. Government authorization. Further evidence submitted by
BIS indicated that Mahan Airways was involved in the attempted re-
export of three additional U.S.-origin Boeing 747s (``Aircraft 4-6'')
to Iran.
As discussed in the September 17, 2008 renewal order, evidence
presented by BIS indicated that Aircraft 1-3 continued to be flown on
Mahan Airways' routes after issuance of the TDO, in violation of the
Regulations and the TDO itself.\5\ It also showed that Aircraft 1-3 had
been flown in further violation of the Regulations and the TDO on the
routes of Iran Air, an Iranian Government airline. Moreover, as
discussed in the March 16, 2009, September 11, 2009 and March 9, 2010
Renewal Orders, Mahan Airways registered Aircraft 1-3 in Iran, obtained
Iranian tail numbers for them (including EP-MNA and EP-MNB), and
continued to operate at least two of them in violation of the
Regulations and the TDO,\6\ while also committing an additional knowing
and willful violation of the Regulations and the TDO when it negotiated
for and acquired an additional U.S.-origin aircraft. The additional
acquired aircraft was an MD-82 aircraft, which subsequently was painted
in Mahan Airways' livery and flown on multiple Mahan Airways' routes
under tail number TC-TUA.
---------------------------------------------------------------------------
\5\ Engaging in conduct prohibited by a denial order violates
the Regulations. 15 CFR Sec. Sec. 764.2(a) and (k).
\6\ The third Boeing 747 appeared to have undergone significant
service maintenance and may not have been operational at the time of
the March 9, 2010 renewal order.
---------------------------------------------------------------------------
The March 9, 2010 Renewal Order also noted that a court in the
United Kingdom (``U.K.'') had found Mahan Airways in contempt of court
on February 1, 2010, for failing to comply with that court's December
21, 2009 and January 12, 2010 orders compelling Mahan Airways to remove
the Boeing 747s from Iran and ground them in the Netherlands. Mahan
Airways and the Balli Group Respondents had been litigating before the
U.K. court concerning ownership and control of Aircraft 1-3. In a
letter to the U.K. court dated January 12, 2010, Mahan Airways'
Chairman indicated, inter alia, that Mahan Airways opposes U.S.
Government actions against Iran, that it continued to operate the
aircraft on its routes in and out of Tehran (and had 158,000 ``forward
bookings'' for these aircraft), and that it wished to continue to do so
and would pay damages if required by that court, rather than ground the
aircraft.
The September 3, 2010 renewal order discussed the fact that Mahan
Airways' violations of the TDO extended beyond operating U.S.-origin
aircraft in violation of the TDO and attempting to acquire additional
U.S.-origin aircraft. In February 2009, while subject to the TDO, Mahan
Airways participated in the export of computer motherboards, items
subject to the Regulations and designated as EAR99, from the United
States to Iran, via the United Arab Emirates (``UAE''), in violation of
both the TDO and the Regulations, by transporting and/or forwarding the
computer motherboards from the UAE to Iran. Mahan Airways' violations
were facilitated by Gatewick LLC, which not
[[Page 44004]]
only participated in the transaction, but also has stated to BIS that
it acts as Mahan Airways' sole booking agent for cargo and freight
forwarding services in the UAE.
Moreover, in a January 24, 2011 filing in the U.K. court, Mahan
Airways asserted that Aircraft 1-3 were not being used, but stated in
pertinent part that the aircraft were being maintained in Iran
especially ``in an airworthy condition'' and that, depending on the
outcome of its U.K. court appeal, the aircraft ``could immediately go
back into service . . . on international routes into and out of Iran.''
Mahan Airways' January 24, 2011 submission to U.K. Court of Appeal, at
p. 25, ]] 108, 110. This clearly stated intent, both on its own and in
conjunction with Mahan Airways' prior misconduct and statements,
demonstrated the need to renew the TDO in order to prevent imminent
future violations. Two of these three 747s subsequently were removed
from Iran and are no longer in Mahan Airway's possession. The third of
these 747s, with Manufacturer's Serial Number (``MSN'') 23480 and
Iranian tail number EP-MNE, remains in Iran under Mahan's control.
Pursuant to Executive Order 13324, it was designated a Specially
Designated Global Terrorist (``SDGT'') by the U.S. Department of the
Treasury's Office of Foreign Assets Control (``OFAC'') on September 19,
2012.\7\ Furthermore, as discussed in the February 4, 2013 Order, open
source information indicated that this 747, which is painted in the
livery and logo of Mahan Airways, has been flown between Iran and
Syria, and was suspected of ferrying weapons and/or other equipment to
the Syrian Government from Iran's Islamic Revolutionary Guard Corps.
Open source information showed that this aircraft remained in active
operation in Mahan Airways' fleet and had flown from Iran to Syria as
recently as June 30, 2013.
---------------------------------------------------------------------------
\7\ See https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/pages/20120919.aspx.
---------------------------------------------------------------------------
In addition, as first detailed in the July 1, 2011 and August 24,
2011 orders, and discussed in subsequent renewal orders in this matter,
Mahan Airways also continued to evade U.S. export control laws by
operating two Airbus A310 aircraft, bearing Mahan Airways' livery,
colors and logo, on flights into and out of Iran.\8\ At the time of the
July 1, 2011 and August 24, 2011 Orders, these Airbus A310s were
registered in France, with tail numbers F-OJHH and F-OJHI,
respectively.\9\
---------------------------------------------------------------------------
\8\ The Airbus A310s are powered with U.S.-origin engines. The
engines are subject to the EAR and classified under Export Control
Classification (``ECCN'') 9A991.d. The Airbus A310s contain
controlled U.S.-origin items valued at more than 10 percent of the
total value of the aircraft and as a result are subject to the EAR.
They are classified under ECCN 9A991.b. The reexport of these
aircraft to Iran requires U.S. Government authorization pursuant to
Section 746.7 of the Regulations.
\9\ OEE subsequently presented evidence that after the August
24, 2011 renewal, Mahan Airways worked along with Kerman Aviation
and others to de-register the two Airbus A310 aircraft in France and
to register both aircraft in Iran (with, respectively, Iranian tail
numbers EP-MHH and EP-MHI). It was determined subsequent to the
February 15, 2012 renewal order that the registration switch for
these A310s was cancelled and that Mahan Airways then continued to
fly the aircraft under the original French tail numbers (F-OJHH and
F-OJHI, respectively).
---------------------------------------------------------------------------
The August 2012 renewal order also found that Mahan Airways had
acquired another Airbus A310 aircraft subject to the Regulations,\10\
with MSN 499 and Iranian tail number EP-VIP, in violation of the TDO
and the Regulations. On September 19, 2012, all three Airbus A310
aircraft (tail numbers F-OJHH, F-OJHI, and EP-VIP) were designated as
SDGTs.\11\
---------------------------------------------------------------------------
\10\ See note 8, supra.
\11\ See https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/pages/20120919.aspx. Mahan Airways was previously
designated by OFAC as a SDGT on October 18, 2011. 77 FR 64,427
(October 18, 2011).
---------------------------------------------------------------------------
The February 4, 2013 Order laid out further evidence of continued
and additional efforts by Mahan Airways and other persons acting in
concert with Mahan, including Kral Aviation and another Turkish
company, to procure U.S.-origin engines (MSNs 517621 and 517738) and
other aircraft parts in violation of the TDO and the Regulations.\12\
The February 4, 2013 renewal order also added Mehdi Bahrami as a
related person in accordance with Section 766.23 of the Regulations.
Bahrami, a Mahan Vice-President and the head of Mahan's Istanbul
Office, also was involved in Mahan's acquisition of the original three
Boeing 747s (Aircraft 1-3) that resulted in the original TDO, and has
had a business relationship with Mahan dating back to 1997.
---------------------------------------------------------------------------
\12\ Kral Aviation was referenced in the February 4, 2013 Order
as ``Turkish Company No. 1.'' Kral Aviation purchased a GE CF6-50C2
aircraft engine (MSN517621) from the United States in July 2012, on
behalf of Mahan Airways. OEE was able to prevent this engine from
reaching Mahan by issuing a redelivery order to the freight
forwarder in accordance with Section 758.8 of the Regulations. OEE
also issued Kral Aviation a redelivery order for the second CF6-50C2
engine (MSN 517738) on July 30, 2012. The owner of the second engine
subsequently cancelled the item's sale to Kral Aviation. In
September 2012, OEE was alerted by a U.S. exporter that another
Turkish company (``Turkish Company No. 2'') was attempting to
purchase aircraft spare parts intended for re-export by Turkish
Company No. 2 to Mahan Airways. See February 4, 2013 Order.
On December 31, 2013, Kral Aviation was added to BIS's Entity
List, Supplement No. 4 to Part 744 of the Regulations. See 78
FR75458 (Dec. 12, 2013). Companies and individuals are added to the
Entity List for engaging in activities contrary to the national
security or foreign policy interests of the United States. See 15
CFR Sec. 744.11.
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The July 31, 2013 Order detailed additional evidence obtained by
OEE showing efforts by Mahan Airways to obtain another GE CF6-50C2
aircraft engine (MSN 528350) from the United States via Turkey.
Multiple Mahan employees, including Mehdi Bahrami, were involved in or
aware of matters related to the engine's arrival in Turkey from the
United States, plans to visually inspect the engine, and prepare it for
shipment from Turkey.
Mahan sought to obtain this U.S.-origin engine through Pioneer
Logistics Havacilik Turizm Yonetim Danismanlik (``Pioneer Logistics''),
an aircraft parts supplier located in Turkey, and its director/
operator, Gulnihal Yegane, a Turkish national who previously has
conducted Mahan related business with Mehdi Bahrami and Ali Eslamian.
Moreover, as referenced in the July 31, 2013 Order, a sworn affidavit
by Kosol Surinanda, also known as Kosol Surinandha, Managing Director
of Mahan's General Sales Agent in Thailand, stated that the shares of
Pioneer Logistics for which he is the listed owner are ``actually the
property of and owned by Mahan.'' He further stated that he held
``legal title to the shares until otherwise required by Mahan'' but
would ``exercise the rights granted to [him] exactly and only as
instructed by Mahan and [his] vote and/or decisions [would] only and
exclusively reflect the wills and demands of Mahan[.]'' \13\
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\13\ Pioneer Logistics, Gulnihal Yegane, and Kosol Surinanda
also were added to the Entity List on December 12, 2013. See 78 FR
75458 (Dec. 12, 2013).
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The January 24, 2014 Order outlines OEE's continued investigation
of Mahan Airways' activities and detailed an attempt by Mahan, which
OEE thwarted, to obtain, via an Indonesian aircraft parts supplier, two
U.S.-origin Honeywell ALF-502R-5 aircraft engines (MSNs LF5660 and
LF5325), items subject to the Regulations, from a U.S. company located
in Texas. An invoice of the Indonesian aircraft parts supplier dated
March 27, 2013, listed Mahan Airways as the purchaser of the engines
and included a Mahan ship-to address. OEE also obtained a Mahan air
waybill dated March 12, 2013, listing numerous U.S.-origin aircraft
parts, including, but not limited to, a vertical navigation gyroscope,
a transmitter, and a power control unit, items subject to the
[[Page 44005]]
Regulations, being transported by Mahan from Turkey to Iran in
violation of the TDO.
OEE's on-going investigation and current renewal request include
evidence discovered or obtained after the January 24, 2014 Order was
issued that further establishes Mahan Airways' efforts to obtain and
operate aircraft subject to the EAR in violation of the TDO and the
Regulations. Open source evidence from the March-June 2014 time period
shows two BAE regional jets painted in the livery and logo of Mahan
Airways and operating under Iranian tail numbers EP-MOK and EP-MOI,
respectively. In addition, aviation industry resources indicate that
these aircraft were obtained by Mahan Airways in late November 2013 and
June 2014, from Ukrainian Mediterranean Airline, a Ukrainian airline
that was added to BIS's Entity List on August 15, 2011, for acting
contrary to the national security and foreign policy interests of the
United States.\14\ These BAE jets are subject to the EAR and their
acquisition and/or operation by Mahan Airways violates the TDO.\15\
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\14\ Supplement No. 4 to Part 744 of the Regulations. See 76 FR
50407 (Aug. 15, 2011).
\15\ The BAE regional jets are powered with U.S.-origin engines.
The engines are subject to the EAR and classified under ECCN
9A991.d. These aircraft contain controlled U.S.-origin items valued
at more than 10 percent of the total value of the aircraft and as a
result are subject to the EAR. They are classified under ECCN
9A991.b. The reexport of these aircraft to Iran requires U.S.
Government authorization pursuant to Section 746.7 of the
Regulations.
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Open source evidence from the April-June 2014 time period likewise
shows two Airbus 320 aircraft painted in the livery and logo of Mahan
Airways and operating under Iranian tail numbers EP-MMK and EP-MML,
respectively. OEE's investigation also shows that Mahan obtained these
aircraft in November 2013, from Khors Air Company, another Ukrainian
airline that like, Ukrainian Mediterranean Airlines, was added to BIS's
Entity List on August 15, 2011, for acting contrary to the national
security and foreign policy interests of the United States.\16\ These
Airbus 320 aircraft are also subject to the EAR.\17\
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\16\ Supplement No. 4 to Part 744 of the Regulations. See 76 FR
50407 (Aug. 15, 2011).
\17\ The Airbus A320s are powered with U.S.-origin engines. The
engines are subject to the EAR and classified under ECCN 9A991.d.
These aircraft contain controlled U.S.-origin items valued at more
than 10 percent of the total value of the aircraft and as a result
are subject to the EAR. They are classified under ECCN 9A991.b. The
reexport of these aircraft to Iran requires U.S. Government
authorization pursuant to Section 746.7 of the Regulations.
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This evidence shows that Mahan Airways has continued its pattern of
acquiring and attempting to acquire, via third countries, both U.S.-
origin jet aircraft and other jet aircraft subject to the Regulations
with the intent to own, control and/or operate the aircraft in
violation of both the TDO and Regulations. Mahan Airways similarly
continues to publically list a number of other such aircraft including
at least one Boeing 747 and Airbus 310s in its active fleet.
C. Findings
Under the applicable standard set forth in Section 766.24 of the
Regulations and my review of the entire record, I find that the
evidence presented by BIS convincingly demonstrates that Mahan Airways
has continually violated the EAR and the TDO, that such knowing
violations have been significant, deliberate and covert, and that there
is a likelihood of future violations. OEE's on-going investigation
continues to reveal or discover additional attempts by Mahan to acquire
items subject to the Regulations through its extensive network of
agents and affiliates in third countries. Therefore, renewal of the TDO
is necessary to prevent imminent violation of the EAR and to give
notice to companies and individuals in the United States and abroad
that they should continue to cease dealing with Mahan Airways and the
other denied persons under the TDO in export transactions involving
items subject to the EAR.
IV. ORDER
It is therefore ordered: First, that MAHAN AIRWAYS, Mahan Tower,
No. 21, Azadegan St., M.A. Jenah Exp. Way, Tehran, Iran; GATEWICK LLC,
A/K/A GATEWICK FREIGHT & CARGO SERVICES, A/K/A GATEWICK AVIATION
SERVICE, G22 Dubai Airport Free Zone, P.O. Box 393754, Dubai,
United Arab Emirates, and P.O. Box 52404, Dubai, United Arab Emirates,
and Mohamed Abdulla Alqaz Building, Al Maktoum Street, Al Rigga, Dubai,
United Arab Emirates; PEJMAN MAHMOOD KOSARAYANIFARD A/K/A KOSARIAN
FARD, P.O. Box 52404, Dubai, United Arab Emirates; MAHMOUD AMINI,
G22 Dubai Airport Free Zone, P.O. Box 393754, Dubai, United
Arab Emirates, and P.O. Box 52404, Dubai, United Arab Emirates, and
Mohamed Abdulla Alqaz Building, Al Maktoum Street, Al Rigga, Dubai,
United Arab Emirates; KERMAN AVIATION A/K/A GIE KERMAN AVIATION, 42
Avenue Montaigne 75008, Paris, France; SIRJANCO TRADING LLC, P.O. Box
8709, Dubai, United Arab Emirates; ALI ESLAMIAN, 4th Floor, 33
Cavendish Square, London W1G0PW, United Kingdom, and 2 Bentinck Close,
Prince Albert Road St. Johns Wood, London NW87RY, United Kingdom; MAHAN
AIR GENERAL TRADING LLC, 19th Floor Al Moosa Tower One, Sheik Zayed
Road, Dubai 40594, United Arab Emirates; SKYCO (UK) LTD., 4th Floor, 33
Cavendish Square, London, W1G 0PV, United Kingdom; EQUIPCO (UK) LTD., 2
Bentinck Close, Prince Albert Road, London, NW8 7RY, United Kingdom;
and MEHDI BAHRAMI, Mahan Airways--Istanbul Office, Cumhuriye Cad. Sibil
Apt No: 101 D:6, 34374 Emadad, Sisli Istanbul, Turkey; and when acting
for or on their behalf, any successors or assigns, agents, or employees
(each a ``Denied Person'' and collectively the ``Denied Persons'') may
not, directly or indirectly, participate in any way in any transaction
involving any commodity, software or technology (hereinafter
collectively referred to as ``item'') exported or to be exported from
the United States that is subject to the Export Administration
Regulations (``EAR''), or in any other activity subject to the EAR
including, but not limited to:
A. Applying for, obtaining, or using any license, License
Exception, or export control document;
B. Carrying on negotiations concerning, or ordering, buying,
receiving, using, selling, delivering, storing, disposing of,
forwarding, transporting, financing, or otherwise servicing in any way,
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; or
C. Benefitting in any way from 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.
Second, that no person may, directly or indirectly, do any of the
following:
A. Export or reexport to or on behalf of a Denied Person any item
subject to the EAR;
B. Take any action that facilitates the acquisition or attempted
acquisition by a Denied Person of the ownership, possession, or control
of any item subject to the EAR that has been or will be exported from
the United States, including financing or other support activities
related to a transaction whereby a Denied Person acquires or attempts
to acquire such ownership, possession or control;
C. Take any action to acquire from or to facilitate the acquisition
or attempted acquisition from a Denied Person of any
[[Page 44006]]
item subject to the EAR that has been exported from the United States;
D. Obtain from a Denied Person in the United States any item
subject to the EAR with knowledge or reason to know that the item will
be, or is intended to be, exported from the United States; or
E. Engage in any transaction to service any item subject to the EAR
that has been or will be exported from the United States and which is
owned, possessed or controlled by a Denied Person, or service any item,
of whatever origin, that is owned, possessed or controlled by a Denied
Person if such service involves the use of any item subject to the EAR
that has been or will be exported from the United States. For purposes
of this paragraph, servicing means installation, maintenance, repair,
modification or testing.
Third, that, after notice and opportunity for comment as provided
in section 766.23 of the EAR, any other person, firm, corporation, or
business organization related to a Denied Person by affiliation,
ownership, control, or position of responsibility in the conduct of
trade or related services may also be made subject to the provisions of
this Order.
Fourth, that this Order does not prohibit any export, reexport, or
other transaction subject to the EAR where the only items involved that
are subject to the EAR are the foreign-produced direct product of U.S.-
origin technology.
In accordance with the provisions of Sections 766.24(e) of the EAR,
Mahan Airways may, at any time, appeal this Order by filing a full
written statement in support of the appeal with the Office of the
Administrative Law Judge, U.S. Coast Guard ALJ Docketing Center, 40
South Gay Street, Baltimore, Maryland 21202-4022. In accordance with
the provisions of Sections 766.23(c)(2) and 766.24(e)(3) of the EAR,
Gatewick LLC, Mahmoud Amini, Pejman Mahmood Kosarayanifard, Kerman
Aviation, Sirjanco Trading LLC, Ali Eslamian, Mahan Air General Trading
LLC, Skyco (UK) Ltd., Equipco (UK) Ltd., and/or Mehdi Bahrami may, at
any time, appeal their inclusion as a related person by filing a full
written statement in support of the appeal with the Office of the
Administrative Law Judge, U.S. Coast Guard ALJ Docketing Center, 40
South Gay Street, Baltimore, Maryland 21202-4022.
In accordance with the provisions of Section 766.24(d) of the EAR,
BIS may seek renewal of this Order by filing a written request not
later than 20 days before the expiration date. A renewal request may be
opposed by Mahan Airways as provided in Section 766.24(d), by filing a
written submission with the Assistant Secretary of Commerce for Export
Enforcement, which must be received not later than seven days before
the expiration date of the Order.
A copy of this Order shall be provided to Mahan Airways and each
related person, and shall be published in the Federal Register. This
Order is effective immediately and shall remain in effect for 180 days.
Dated: July 22, 2014.
David W. Mills,
Assistant Secretary of Commerce for Export Enforcement.
[FR Doc. 2014-17798 Filed 7-28-14; 8:45 a.m.]
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