Aviation

According to its Form 20-F filed for the year 2019 on April 8, 2020 with the SEC:

During 2019, we conducted limited Iran-related activities and transactions that can be qualified as dealings with the government of Iran, or with persons or entities designated under certain executive orders, as defined by Section 13(r) of the Exchange Act. 

These dealings all relate to the operation of the Zvartnots Airport by AIA, our Armenian subsidiary, and in particular in connection with certain international flights that Mahan Air operated from Iran to Armenia. Mahan Air is a private airline based in Teheran, Iran, which operated 123 flights to and from the Zvartnots Airport during 2019. In 2011, pursuant to Executive Order No. 13224, Mahan Air was designated as a Specially Designated National (SDN). Despite this designation, based on information available on its website, Mahan Air continues to have operations in several cities around the world, such as, Barcelona, Milan and Moscow. 

Under the Armenian Concession Agreement, AIA is required and cannot refuse to operate all commercial flights and deal with all airlines authorized by the Armenian Government to fly from or to the Zvartnots Airport. 

In August 2019, Mahan Air stopped operating flights at the Zvartnots Airport. Since then, no Mahan Air flights have been handled by AIA.

While in operation, in connection with flights to and from the Zvartnots Airport, AIA collected aeronautical, fueling and cargo fees from Mahan Air as authorized under the Armenian Concession Agreement. During 2019, and until such flights were discontinued, the total revenue derived from aeronautical and fueling fees charged to Mahan Air amounted to approximately €0.5 million. Revenue derived from other fees charged to Mahan Air, such as cargo fees, cannot be determined because they are impacted by general cost and expenses not allocable to a particular airline or customer. Overall, the revenue derived from the operation of Mahan Air’s flights is not material.     

In response to our inquiry, Zvartnots Handling informed us that until August 2019, Zvartnots Handling supplied handling services to Mahan Air, as agreed under a Standard Ground Handling Agreement, in connection with the flights from Teheran, Iran to the Zvartnot Airport. Moreover, Zvartnots Handling entered into a Standard Ground Handling Agreement for the provision of these handling services with Mahan Air. We were informed that during 2019, and until such services were discontinued, Zvartnots Handling collected an aggregate amount of approximately €0.3 million for services under this agreement.

Trip.com features Mahan Air on its website.

Booking Holdings Inc. brand KAYAK features Iran’s Mahan Air on a dedicated web-page. Mahan Air has been subject to two United States Executive Orders (“E.O.”) and is banned from landing in airports in Germany, France and Italy.

"Aercap Holdings NV, the world’s biggest aircraft lessor, said it’s cooperating with a U.S. investigation into the supply of Airbus Group NV jetliners to Iran and that it previously sold some of the nine planes concerned. The aircraft were purchased by Tehran-based Mahan Air from Al-Naser Airlines of Iraq, which appears to have sourced two of them from Aercap, the lessor said in a filing, adding that it is assisting in the U.S. Office of Foreign Asset Control-led probe." (2015)

Atlasglobal continues to provide flights from Adana to Tehran.

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Atlasglobal has agreed to be an “Official Travel Partner” at the 4th Europe-Iran Forum (“EIF4”) in Zürich on October 3-4, 2017. According to its official website, Atlasglobal is partnering with EIF4 for the purpose of “bringing business leaders, policymakers, and members of the international press into direct conversation about the challenges, opportunities, and broader social responsibilities of commercial activity in Iran.” (EIF4 Website, “An Unparalleled Project in ‘Business Diplomacy’”).

The ERC determined to add Dart Aviation to the Entity List under the destinations of France, Iran, Senegal and the U.K., because this entity has transshipped U.S.-origin items to sanctioned destinations and entities without the required authorizations. (Bureau of Industry and Commerce, 11/13/2019).

Emirates Hermes General Trading operated by Basha Asmath Shaikh and Manohar Nair, procured U.S.-origin items for Mahan Air, an Iranian airline that is subject to a BIS temporary denial order and has been designated a Specially Designated Global Terrorist by the U.S. Department of Treasury’s Office of Foreign Assets Control;

The Hermes is a private, multinational enterprise with diverse commercial and industrial operations in the Middle East and an actively managed portfolio of international investments. Emirates Hermes General trading seeks to become long-term partners with exceptional management teams and employees who share our goal of significant long-term growth while simultaneously leaving a lasting and positive impact on the communities in which we operate;

Also Emirates Hermes General Trading procured U.S.-origin items for Complete Freight Solutions, a listed entity on the Entity List; (Source: Federal Registry, 5/14/2019).

Air Canada's website lists flights from Canada to Iran.

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In October 2016, the Financial Tribute reported, “Negotiations are underway with Air India, Korean Airline and Air Canada to establish new flights to Imam Khomeini Airport.” (Financial Tribute, “Iran in Talks to Establish Direct Canada Flights,” 10/3/2016). 

"Iran Airports Company has signed a multilateral memorandum of understanding with German companies for expansion of Iranian airports. The agreement was signed with Munich Airports, Frankfurt Airport and Dornier Consulting International GmbH, which is a consulting and project management company that operates in the field of aviation, among other sectors, IRNA reported. The MoU concerns airport operations management, airport development, navigation infrastructures and consultation regarding commercialization of the airports." (January 18, 2017)

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In January 2017 Munich Airports signed an MOU with Iran Airports and Air Navigation Company to boost airport and aviation ties.

German airline Eurowings, a subsidiary of Lufthansa, launched flights to Tehran in October 2015.

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According to Aero Telegraph, Eurowings was set to launch flights to Tehran in March 2017 following a postponement of the same service that was set to commence in 2016. (Aero Telegraph, “Eurowings will probably fly to Tehran in 2017,” 3/31/2016).

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This report followed an official announcement that from Summer 2016, “the new Eurowings will fly to five new long-haul destinations including Miami, Boston and Las Vegas, all the in US, as well as Tehran, Iran.” (Lufthansa Website, “The new Eurowings has taken off”).

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Eurowings’ participated at the Iranian Aviation Confex 2017 in Tehran, Iran from April 18-19, 2017. (Iranian Aviation Confex Website, “Speaker Lineup”).