Order Renewing Order Temporarily Denying Export Privileges, 3552-3556 [2015-01215]
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Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Notices
CFR 400.2(c)) as an option for the
establishment or reorganization of
zones;
Whereas, the Cleveland Cuyahoga
County Port Authority, grantee of
Foreign-Trade Zone 40, submitted an
application to the Board (FTZ Docket B–
70–2014, docketed 10/1/2014) for
authority to expand the service area of
the zone to include Lake County, Ohio,
as described in the application, adjacent
to the Cleveland, Ohio Customs and
Border Protection port of entry;
Whereas, notice inviting public
comment was given in the Federal
Register (79 FR 61050, 10/9/2014) and
the application has been processed
pursuant to the FTZ Act and the Board’s
regulations; and,
Whereas, the Board adopts the
findings and recommendations of the
examiner’s report, and finds that the
requirements of the FTZ Act and the
Board’s regulations are satisfied;
Now, therefore, the Board hereby
orders:
The application to reorganize FTZ 40
to expand the service area under the
ASF is approved, subject to the FTZ Act
and the Board’s regulations, including
Section 400.13, and to the Board’s
standard 2,000-acre activation limit for
the zone.
Signed at Washington, DC, this 9th day of
January 2015.
Paul Piquado,
Assistant Secretary of Commerce for
Enforcement and Compliance, Alternate
Chairman, Foreign-Trade Zones Board.
ATTEST:
Andrew McGilvray,
Executive Secretary.
[FR Doc. 2015–01230 Filed 1–22–15; 8:45 am]
BILLING CODE 3510–DS–P
DEPARTMENT OF COMMERCE
Bureau of Industry and Security
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Order Renewing Order Temporarily
Denying Export Privileges
Mahan Airways, Mahan Tower, No. 21,
Azadegan St., M.A. Jenah Exp. Way,
Tehran, Iran;
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;
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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 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’’),1 I hereby grant the
request of the Office of Export
Enforcement (‘‘OEE’’) to renew the July
22, 2014 Order Temporarily Denying the
Export Privileges of Mahan Airways,
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.2 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
1 The Regulations, currently codified at 15 CFR
parts 730–774 (2014), originally issued pursuant to
the Export Administration Act of 1979, as amended
(50 U.S.C. app. §§ 2401–2420 (2000)). Since August
21, 2001, the Act has been in lapse and the
President, through Executive Order 13222 of August
17, 2001 (3 CFR, 2001 Comp. 783 (2002)), which
has been extended by successive Presidential
Notices, the most recent being that of August 7,
2014 (79 FR 46,959 (Aug. 11, 2014)), has continued
the Regulations in effect under the International
Emergency Economic Powers Act (50 U.S.C. 1701,
et seq. (2006 & Supp. IV 2010)).
2 See note 5, infra.
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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
July 22, 2014.3 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 (a/k/a
Gatewick Freight and Cargo Services, a/
k/a Gatewick Aviation Services),
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.4 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 December 24, 2014, BIS, through
its Office of Export Enforcement
(‘‘OEE’’), submitted a written request for
renewal of the TDO.5 The written
request was made more than 20 days
before the scheduled expiration of the
current TDO dated July 22, 2014. Notice
of the renewal request also 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.
3 The July 22, 2014 Order was published in the
Federal Register on July 29, 2014. 79 FR 44002 (Jul.
29, 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, July 31,
2013, and January 24, 2014. 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.
4 As of July 22, 2014, Zarand Aviation was no
longer subject to the TDO.
5 The December 24, 2014 renewal request does
not include Gatewick LLC. On August 13, 2014, BIS
and Gatewick LLC resolved administrative charges
against Gatewick, including a charge for acting
contrary to the terms of a BIS denial order (15 CFR
764.2(k)). In addition to the payment of a civil
penalty, the settlement includes a seven-year denial
order. The first two years of the denial period are
active, with the remaining five years suspended on
condition that Gatewick LLC pays the civil penalty
in full and timely fashion and commits no further
violation of the Regulations during the seven-year
denial period. The Gatewick LLC Final Order was
published in the Federal Register on August 20,
2014. See 79 FR 49283 (Aug. 20, 2014).
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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
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.6
II. Renewal of the TDO
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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
6 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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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.7 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 (EP–MNA,
EP–MNB, and EP–MNE, respectively),
and continued to operate at least two of
them in violation of the Regulations and
the TDO,8 while also committing an
additional knowing and willful
violation 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 and
7 Engaging in conduct prohibited by a denial
order violates the Regulations. 15 CFR 764.2(a) and
(k).
8 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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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 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 Airways’ possession. The third
of these 747s, with Manufacturer’s
Serial Number (‘‘MSN’’) 23480 and
Iranian tail number EP–MNE, remained
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, 2012.9 Furthermore, as
discussed in the February 4, 2013 Order,
open source information indicated that
this 747, painted in the livery and logo
of Mahan Airways, had 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 had flown from Iran to Syria as
recently as June 30, 2013, and continues
to show that it remains in active
operation in Mahan Airways’ fleet.
9 See https://www.treasury.gov/resource-center/
sanctions/OFAC-Enforcement/pages/
20120919.aspx.
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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 and logo, on flights into and out
of Iran.10 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.11
The August 2012 renewal order also
found that Mahan Airways had acquired
another Airbus A310 aircraft subject to
the Regulations,12 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.13
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.14 The February 4, 2013
10 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 Sections 742.8 and 746.7 of the
Regulations.
11 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). Both aircraft
apparently remain in Mahan Airways’ possession.
12 See note 10, supra.
13 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).
14 Kral Aviation was referenced in the February
4, 2013 Order as ‘‘Turkish Company No. 1.’’ Kral
Aviation purchased a GE CF6–50C2 aircraft engine
(MSN 517621) 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
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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
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 was 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[.]’’ 15
The January 24, 2014 Order outlined
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
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 FR 75458 (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.
15 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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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 subject to the
Regulations—including, among other
items, a vertical navigation gyroscope, a
transmitter, and a power control unit—
being transported by Mahan from
Turkey to Iran in violation of the TDO.
The July 22, 2014 Order discusses
open source evidence from the MarchJune 2014 time period regarding two
BAE regional jets, items subject to the
Regulations, that were 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
indicated 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 (Supplement No. 4 to
Part 744 of the Regulations) on August
15, 2011, for acting contrary to the
national security and foreign policy
interests of the United States.16 OEE’s
on-going investigation indicates that
both BAE regional jets remain active in
Mahan’s fleet, with open source
information showing EP–MOI being
used on flights into and out of Iran as
recently as January 12, 2015. The
continued operation of these aircraft by
Mahan Airways violates the TDO.
In addition to the continued operation
of aircraft such as EP–MOI, OEE’s
December 24, 2014 renewal request
includes evidence of additional
attempts by Mahan Airways to acquire
items subject the Regulations in further
violation of the TDO. In March 2014,
OEE became aware of an inertial
reference unit bearing serial number
1231 (‘‘the IRU’’) that had been sent to
the United States for repair. The IRU is
subject to the Regulations, classified
under ECCN 7A103, and controlled for
16 See 76 FR 50407 (Aug. 15, 2011). The July 22,
2014 TDO renewal order also referenced two Airbus
A320 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 showed 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. Open
source evidence indicates the two Airbus A320
aircraft may be been transferred by Mahan Airways
to another Iranian airline in October 2014, and
issued Iranian tail numbers EP–APE and EP–APF,
respectively.
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missile technology reasons. Upon closer
inspection, it was determined that IRU
came from or had been installed on an
Airbus A340 aircraft bearing MSN 056.
Further investigation has revealed that
as of approximately February 2014, this
aircraft was registered under Iranian tail
number EP–MMB and had been painted
in the livery and logo of Mahan
Airways. On August 14, 2014, the
United States Attorney’s Office for the
District of Maryland filed a civil
forfeiture complaint for the IRU
pursuant to 22 U.S.C. 401(b). The Court
issued an Order of Forfeiture for the IRU
on December 2, 2014. EP–MMB remains
listed as active in Mahan Airways’ fleet.
Finally on August 29, 2014, the U.S.
Department of Treasury’s Office of
Foreign Assets Control (‘‘OFAC’’)
blocked the property and interests in
property of Asian Aviation Logistics of
Thailand, a Mahan Airways affiliate or
front company, pursuant to Executive
Order 13224. In doing so, OFAC
described Mahan Airway’s use of Asian
Aviation Logistics to evade sanctions by
making payments on behalf of Mahan
Air for the purchase of engines and
other equipment.17
C. Findings
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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
repeatedly 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 connection with export transactions
involving items subject to the EAR.
17 See https://www.treasury.gov/resource-center/
sanctions/OFAC-Enforcement/Pages/
20140829.aspx. See 79 FR 55073 (Sep. 15, 2014).
OFAC also blocked the property and property
interests of Pioneer Logistics of Turkey on August
29, 2014. Id. Mahan Airways’ use of Pioneer
Logistics in an effort to evade the TDO and the
Regulations was discussed in a prior renewal order,
as summarized, supra, at 10. BIS added both Asian
Aviation Logistics and Pioneer Logistics to the
Entity List on December 12, 2013. See 78 FR 75458
(Dec. 12, 2013).
VerDate Sep<11>2014
18:05 Jan 22, 2015
Jkt 235001
IV. Order
It is therefore ordered:
First, that MAHAN AIRWAYS, Mahan
Tower, No. 21, Azadegan St., M.A.
Jenah Exp. Way, Tehran, Iran; 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; 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.
PO 00000
Frm 00009
Fmt 4703
Sfmt 4703
3555
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
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, Mahmoud
Amini, Pejman Mahmood
Kosarayanifard, Kerman Aviation,
E:\FR\FM\23JAN1.SGM
23JAN1
3556
Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Notices
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: January 16, 2015.
David W. Mills,
Assistant Secretary of Commerce for Export
Enforcement.
[FR Doc. 2015–01215 Filed 1–22–15; 8:45 a.m.]
BILLING CODE P
DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric
Administration
Proposed Information Collection;
Comment Request; International
Dolphin Conservation Program
National Oceanic and
Atmospheric Administration (NOAA),
Commerce.
ACTION: Notice.
AGENCY:
The Department of
Commerce, as part of its continuing
effort to reduce paperwork and
respondent burden, invites the general
public and other Federal agencies to
take this opportunity to comment on
proposed and/or continuing information
collections, as required by the
Paperwork Reduction Act of 1995.
DATES: Written comments must be
submitted on or before March 24, 2015.
ADDRESSES: Direct all written comments
to Jennifer Jessup, Departmental
Paperwork Clearance Officer,
Department of Commerce, Room 6616,
14th and Constitution Avenue NW.,
tkelley on DSK3SPTVN1PROD with NOTICES
SUMMARY:
VerDate Sep<11>2014
18:05 Jan 22, 2015
Jkt 235001
Washington, DC 20230 (or via the
Internet at JJessup@doc.gov).
FOR FURTHER INFORMATION CONTACT:
Requests for additional information or
copies of the information collection
instrument and instructions should be
directed to: Justin Greenman, (562) 980–
3264 or justin.greenman@noaa.gov.
SUPPLEMENTARY INFORMATION:
I. Abstract
National Oceanic and Atmospheric
Administration (NOAA) collects
information to implement the
International Dolphin Conservation
Program Act (Act). The Act allows entry
of yellowfin tuna into the United States
(U.S.), under specific conditions, from
nations in the International Dolphin
Conservation Program that would
otherwise be under embargo. The Act
also allows U.S. fishing vessels to
participate in the yellowfin tuna fishery
in the eastern tropical Pacific Ocean
(ETP) on terms equivalent with the
vessels of other nations. NOAA collects
information to allow tracking and
verification of ‘‘dolphin safe’’ and ‘‘nondolphin safe’’ tuna products from catch
through the U.S. market.
The regulations implementing the Act
are at 50 CFR parts 216 and 300. The
recordkeeping and reporting
requirements at 50 CFR parts 216 and
300 form the basis for this collection of
information. This collection includes
permit applications, notifications, tuna
tracking forms, reports, and
certifications that provide information
on vessel characteristics and operations
in the ETP, the origin of tuna and tuna
products, and certain other information
necessary to implement the Act.
II. Method of Collection
Paper applications, other paper
records, electronic and facsimile
reports, and telephone calls are required
from participants. Methods of submittal
include transmission of paper forms via
regular mail and facsimile as well as
electronic submission via email or an
FTP site (password protected).
III. Data
OMB Number: 0648–0387.
Form Number: None.
Type of Review: Regular submission
(extension of a current information
collection).
Affected Public: Business or other forprofit organizations; individuals or
households.
Estimated Number of Respondents:
144.
Estimated Time per Response: 35
minutes for a vessel permit application;
10 minutes for an operator permit
application, a notification of vessel
PO 00000
Frm 00010
Fmt 4703
Sfmt 9990
arrival or departure, a change in permit
operator; a notification of a net
modification or a monthly tuna storage
removal report; 30 minutes for a request
for a waiver to transit the ETP without
a permit (and subsequent radio
reporting) or for a special report
documenting the origin of tuna (if
requested by the NOAA Administrator);
10 hours for an experimental fishing
operation waiver; 15 minutes for a
request for a Dolphin Mortality Limit;
35 minutes for written notification to
request active status for a small tuna
purse seine vessel; 5 minutes for written
notification to request inactive status for
a small tuna purse seine vessel or for
written notification of the intent to
transfer a tuna purse seine vessel to
foreign registry and flag; 60 minutes for
a tuna tracking form or for a monthly
tuna receiving report.
Estimated Total Annual Burden
Hours: 341.
Estimated Total Annual Cost to
Public: $1,250.
IV. Request for Comments
Comments are invited on: (a) Whether
the proposed collection of information
is necessary for the proper performance
of the functions of the agency, including
whether the information shall have
practical utility; (b) the accuracy of the
agency’s estimate of the burden
(including hours and cost) of the
proposed collection of information; (c)
ways to enhance the quality, utility, and
clarity of the information to be
collected; and (d) ways to minimize the
burden of the collection of information
on respondents, including through the
use of automated collection techniques
or other forms of information
technology.
Comments submitted in response to
this notice will be summarized and/or
included in the request for OMB
approval of this information collection;
they also will become a matter of public
record.
Dated: January 16, 2015.
Glenna Mickelson,
Management Analyst, Office of the Chief
Information Officer.
[FR Doc. 2015–01060 Filed 1–22–15; 8:45 am]
BILLING CODE 3510–22–P
E:\FR\FM\23JAN1.SGM
23JAN1
Agencies
[Federal Register Volume 80, Number 15 (Friday, January 23, 2015)]
[Notices]
[Pages 3552-3556]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2015-01215]
-----------------------------------------------------------------------
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;
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;
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''),\1\ I hereby grant the request of the Office of Export
Enforcement (``OEE'') to renew the July 22, 2014 Order Temporarily
Denying the Export Privileges of Mahan Airways, 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.\2\ 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\ The Regulations, currently codified at 15 CFR parts 730-774
(2014), originally issued pursuant to the Export Administration Act
of 1979, as amended (50 U.S.C. app. Sec. Sec. 2401-2420 (2000)).
Since August 21, 2001, the Act has been in lapse and the President,
through Executive Order 13222 of August 17, 2001 (3 CFR, 2001 Comp.
783 (2002)), which has been extended by successive Presidential
Notices, the most recent being that of August 7, 2014 (79 FR 46,959
(Aug. 11, 2014)), has continued the Regulations in effect under the
International Emergency Economic Powers Act (50 U.S.C. 1701, et seq.
(2006 & Supp. IV 2010)).
\2\ See note 5, 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 July 22, 2014.\3\ 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 (a/k/a Gatewick Freight and Cargo Services, a/k/a Gatewick
Aviation Services), 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.\4\ 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.
---------------------------------------------------------------------------
\3\ The July 22, 2014 Order was published in the Federal
Register on July 29, 2014. 79 FR 44002 (Jul. 29, 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, July 31, 2013, and January 24, 2014. 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.
\4\ As of July 22, 2014, Zarand Aviation was no longer subject
to the TDO.
---------------------------------------------------------------------------
On December 24, 2014, BIS, through its Office of Export Enforcement
(``OEE''), submitted a written request for renewal of the TDO.\5\ The
written request was made more than 20 days before the scheduled
expiration of the current TDO dated July 22, 2014. Notice of the
renewal request also 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.
[[Page 3553]]
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 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.\6\
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\5\ The December 24, 2014 renewal request does not include
Gatewick LLC. On August 13, 2014, BIS and Gatewick LLC resolved
administrative charges against Gatewick, including a charge for
acting contrary to the terms of a BIS denial order (15 CFR
764.2(k)). In addition to the payment of a civil penalty, the
settlement includes a seven-year denial order. The first two years
of the denial period are active, with the remaining five years
suspended on condition that Gatewick LLC pays the civil penalty in
full and timely fashion and commits no further violation of the
Regulations during the seven-year denial period. The Gatewick LLC
Final Order was published in the Federal Register on August 20,
2014. See 79 FR 49283 (Aug. 20, 2014).
\6\ 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.\7\ 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 (EP-MNA, EP-MNB, and EP-MNE,
respectively), and continued to operate at least two of them in
violation of the Regulations and the TDO,\8\ while also committing an
additional knowing and willful violation 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.
---------------------------------------------------------------------------
\7\ Engaging in conduct prohibited by a denial order violates
the Regulations. 15 CFR 764.2(a) and (k).
\8\ 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 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 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 Airways' possession. The third of
these 747s, with Manufacturer's Serial Number (``MSN'') 23480 and
Iranian tail number EP-MNE, remained 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.\9\ Furthermore, as discussed in the February 4, 2013 Order, open
source information indicated that this 747, painted in the livery and
logo of Mahan Airways, had 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 had flown from Iran to Syria as
recently as June 30, 2013, and continues to show that it remains in
active operation in Mahan Airways' fleet.
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\9\ See https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/pages/20120919.aspx.
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[[Page 3554]]
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 and
logo, on flights into and out of Iran.\10\ 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.\11\
---------------------------------------------------------------------------
\10\ 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
Sections 742.8 and 746.7 of the Regulations.
\11\ 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). Both aircraft apparently remain in Mahan
Airways' possession.
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The August 2012 renewal order also found that Mahan Airways had
acquired another Airbus A310 aircraft subject to the Regulations,\12\
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.\13\
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\12\ See note 10, supra.
\13\ 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).
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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.\14\
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.
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\14\ Kral Aviation was referenced in the February 4, 2013 Order
as ``Turkish Company No. 1.'' Kral Aviation purchased a GE CF6-50C2
aircraft engine (MSN 517621) 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 FR
75458 (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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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 was 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[.]'' \15\
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\15\ 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 outlined 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 subject to the Regulations--including, among other items, a
vertical navigation gyroscope, a transmitter, and a power control
unit--being transported by Mahan from Turkey to Iran in violation of
the TDO.
The July 22, 2014 Order discusses open source evidence from the
March-June 2014 time period regarding two BAE regional jets, items
subject to the Regulations, that were 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 indicated
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 (Supplement No. 4 to Part
744 of the Regulations) on August 15, 2011, for acting contrary to the
national security and foreign policy interests of the United
States.\16\ OEE's on-going investigation indicates that both BAE
regional jets remain active in Mahan's fleet, with open source
information showing EP-MOI being used on flights into and out of Iran
as recently as January 12, 2015. The continued operation of these
aircraft by Mahan Airways violates the TDO.
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\16\ See 76 FR 50407 (Aug. 15, 2011). The July 22, 2014 TDO
renewal order also referenced two Airbus A320 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 showed 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. Open source evidence indicates the two Airbus A320
aircraft may be been transferred by Mahan Airways to another Iranian
airline in October 2014, and issued Iranian tail numbers EP-APE and
EP-APF, respectively.
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In addition to the continued operation of aircraft such as EP-MOI,
OEE's December 24, 2014 renewal request includes evidence of additional
attempts by Mahan Airways to acquire items subject the Regulations in
further violation of the TDO. In March 2014, OEE became aware of an
inertial reference unit bearing serial number 1231 (``the IRU'') that
had been sent to the United States for repair. The IRU is subject to
the Regulations, classified under ECCN 7A103, and controlled for
[[Page 3555]]
missile technology reasons. Upon closer inspection, it was determined
that IRU came from or had been installed on an Airbus A340 aircraft
bearing MSN 056. Further investigation has revealed that as of
approximately February 2014, this aircraft was registered under Iranian
tail number EP-MMB and had been painted in the livery and logo of Mahan
Airways. On August 14, 2014, the United States Attorney's Office for
the District of Maryland filed a civil forfeiture complaint for the IRU
pursuant to 22 U.S.C. 401(b). The Court issued an Order of Forfeiture
for the IRU on December 2, 2014. EP-MMB remains listed as active in
Mahan Airways' fleet.
Finally on August 29, 2014, the U.S. Department of Treasury's
Office of Foreign Assets Control (``OFAC'') blocked the property and
interests in property of Asian Aviation Logistics of Thailand, a Mahan
Airways affiliate or front company, pursuant to Executive Order 13224.
In doing so, OFAC described Mahan Airway's use of Asian Aviation
Logistics to evade sanctions by making payments on behalf of Mahan Air
for the purchase of engines and other equipment.\17\
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\17\ See https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20140829.aspx. See 79 FR 55073 (Sep. 15, 2014).
OFAC also blocked the property and property interests of Pioneer
Logistics of Turkey on August 29, 2014. Id. Mahan Airways' use of
Pioneer Logistics in an effort to evade the TDO and the Regulations
was discussed in a prior renewal order, as summarized, supra, at 10.
BIS added both Asian Aviation Logistics and Pioneer Logistics to the
Entity List on December 12, 2013. See 78 FR 75458 (Dec. 12, 2013).
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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 repeatedly 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 connection with 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; 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; 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 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,
Mahmoud Amini, Pejman Mahmood Kosarayanifard, Kerman Aviation,
[[Page 3556]]
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: January 16, 2015.
David W. Mills,
Assistant Secretary of Commerce for Export Enforcement.
[FR Doc. 2015-01215 Filed 1-22-15; 8:45 a.m.]
BILLING CODE P