Iran’s Misuse of Civilian Aircraft


In the July 2015 Joint Comprehensive Plan of Action (JCPOA), the United States committed to “allow for the sale of commercial passenger aircraft and related parts and services to Iran by licensing the (i) export, re-export, sale, lease or transfer to Iran of commercial passenger aircraft for exclusively civil aviation end-use.” Since the nuclear deal took effect, Chicago-based aircraft manufacturer Boeing entered into a December 2016 contract with Iran’s national airline, the government-owned Iran Air, for 80 civilian airliners valued at $16.6 billion. In June 2017, Boeing inked another deal with Iran’s third largest airline, Aseman Air, for 30 Boeing aircraft. Aseman’s CEO, Hossein Alaei, has longstanding ties to the Islamic Revolutionary Guard Corps (IRGC).

Boeing’s attempts to enter the Iranian civilian aviation market expose the company to serious legal, political, financial, and reputational risks associated with doing business in Iran, where much of the economy is dominated by the IRGC. The IRGC is sanctioned by the U.S. Government and the international community of nations as a terrorist organization, and was designated in its entirety by the U.S. in October 2017. The IRGC has entered virtually every sector of the Iranian economy, and experts peg its share of Iran’s overall economy at around 15% to 30% of Iran’s legitimate GDP. Furthermore, the IRGC has an outsize role in Iran’s underground economy, which includes funds from smuggling, drug trafficking, and related criminal ventures. 

Iran’s civil aviation industry in particular has a sordid and ongoing history of partnering with the IRGC in exploiting civilian airliners in order to obtain proscribed ballistic missile components and to supply weapons and military personnel to its terrorist proxies, Hezbollah and Syria’s Assad regime. Through its role in these malign activities, Iran’s civil aviation industry is a complicit partner in ballistic missile proliferation, terrorism and human rights abuses. Surely, Boeing would not wish for planes it delivers to be associated with restocking Assad’s weaponry to use against his own citizenry, the provision of advanced weaponry to Hezbollah, or the transport of ballistic missile components or even nuclear materials on the Pyongyang-Tehran route.

Given Iran’s history, and the history of Iran Air itself, it strains credibility to believe that passenger aircraft delivered to Iran can be guaranteed to be for “exclusively civil aviation end-use,” as required under the JCPOA. Indeed, in a June 2016 press briefing, former State Department Spokesman John Kirby was unwilling or unable to confirm that Iran Air had taken any action to merit the lifting of sanctions against it or that it was no longer engaged in sanctionable activities. Ultimately, if Iran Air or Aseman Air are proven to partake in sanctionable activities or the resale or transfer of aircraft to currently-designated individuals or entities, such as Mahan Air, then they could face new sanctions and the revocation of the licenses for aircraft sales that were granted by the Treasury Department’s Office of Financial Asset Control (OFAC), potentially leaving Boeing holding the tab.

Iran Air’s aircraft buying spree raises red flags that it is not the final destination for all the aircraft it is seeking to acquire. Tehran is reportedly seeking to purchase 500 civilian airliners over the next decade, a massive expansion considering that Iran Air and its subsidiary currently operate around 50 aircraft. With no clear need for the number of planes it is seeking, there is a high likelihood that some of the planes delivered will be resold or transferred to the Iranian air force, or to other Iranian air carriers still under sanctions such as Mahan Air and Pouya Air (formerly Yas Air, a long sanctioned airline operated by the IRGC and its Pars Aviation Company).  

Iran’s civil aviation industry’s troubling and ongoing history of abuses and exploitation, chronicled below, underscore the immense risks of entering into the Iranian market. The hazards of conducting business with Iran Air, an entity implicated in the provision of material support to the terrorism and human rights abuses of the IRGC-Quds Force, Hezbollah, and Assad, far outweigh any theoretical benefit of commercial engagement in the Iranian civil aviation market.

History of Abuses:

  • In August 2017, Congressional leaders were provided photographic evidence of an Iran Air passenger plane with the company’s logo visible on the headrest being used to transport militants affiliated with the Fatemiyoun Brigade, an Afghan Shia mercenary militia trained and funded by the IRGC, to Syria. The photographs depicting Iran Air engaged in sanctionable activity were reportedly taken during 2016 and 2017, well after the lifting of sanctions against it.

    The revelation of these photographs prompted four Republican lawmakers, Reps. Peter Rosakam (R-IL), Lee Zeldin (R-NY), Andy Barr (R-KY), and David Reichert (R-WA) to write a letter to Treasury Secretary Steven Mnuchin calling for an investigation into the photos and the re-designation of Iran Air if found to have engaged in illicit military transports. In the letter, the Congressmen wrote, “These photos offer strong evidence of Iran Air’s noncommercial and illicit use of commercial aircraft to materially support the IRGC and the Assad Regime.”

  • Following the January 2016 implementation of the JCPOA, Iran Air ceased operating the Iran-Syria route for a time. However, in June 2016, Emanuele Ottolenghi, an expert on Iran’s history of sanctions evasion, observed three flights using publicly available flight data indicating the resumption of the well-known weapons resupply route. On June 9, an Iran Air plane spent an hour in Abadan, Iran, the logistical hub of the IRGC’s airlifts to Assad and Hezbollah before continuing on to Damascus. On June 8 and 15, Iran Air operated flights from Tehran to Damascus utilizing a Najaf-Tehran flight number in an effort to disguise their true destination.  

    Iran Air’s flights to Syria continued to multiply. Between Implementation Day of the JCPOA in January 2016 and August 2017, over 1000 flights, including 134 such flights by Iran Air, departed from points in Iran and landed in Syria, indicating an ongoing complex logistical operation to resupply the Assad regime. In one two-month period alone during 2017, Iranian and Syrian airlines delivered an estimated 21,000 passengers and 5,000 tons of supplies from Tehran and Abadan to Damascus.  In sum, Iran operated 11 commercial flights per week to Syria during this period, with two flights per week operated by Iran Air. Lending credence to the nefarious nature of these Iran Air flights, the flights occur at irregular intervals and Iran Air’s website does not have tickets to Damascus available to the general public on its website. Nor is Damascus even listed as a possible destination.

  • Any civilian airliners purchased by Iran Air are at risk of being resold or transferred to Mahan Air. Mahan Air was designated by the Treasury Department in October 2011 for “providing travel services to IRGC-QF personnel flown to and from Iran and Syria for military training.” Furthermore, the designation alleged that “Mahan Air has transported personnel, weapons and goods on behalf of Hizballah and omitted from Mahan Air cargo manifests secret weapons shipments bound for Hizballah.”

    Mahan Air remains sanctioned to this day. In the months after the JCPOA was reached, Mahan Air intensified its service between Iran and Syria, conducting nearly daily flights between Tehran and Damascus and Latakia, an Assad regime stronghold.

  • In January 2017, Ukrainian authorities announced the seizure of a shipment of Russian-made anti-tank guided missile components bound for Iran, a violation of Annex B of United Nations Security Council Resolution 2231 forbidding the supply, sale and transfer of missiles or missile systems to Iran without the council’s prior approval. The illicit shipment was found on board aircraft operated by Ukrainian-Mediterranean (UM) Airlines, which has officially partnered with Mahan Air on daily flights from Ukraine to Iran since the JCPOA took effect. UM was designated by the Treasury Department in 2013 for leasing aircraft to Mahan Air. Rep. Roskam responded to the seizure, saying, “This is yet another example of the Islamic Republic using commercial aircraft for military purposes. Airbus and Boeing cannot claim ignorance on this—the Regime’s behavior is on full display before the world."

  • In November 2016, Israel’s Ambassador the United Nations sent an urgent letter to the Security Council alleging, based on Israeli intelligence, that “The Iranian Al-Quds Force packs weapons, ammunition and missile technology to Hezbollah in suitcases and puts them on Mahan Air flights. … These planes fly directly to the airport in Lebanon or Damascus and from there the weapons are transferred on the ground to Hezbollah."

  • Another risk of delivering civilian airliners to Iran is Iran’s history of repurposing commercial aircraft for use in its air force. At least six Boeing airliners sold to Iran Air during the 1970s were subsequently transferred to Iran’s air force.

  • In October 2012, the Treasury Department designated 117 aircraft operated by Iran Air, Mahan Air, and Yas Air as blocked property. Treasury found that, “In the summer of 2012, Iran used Iran Air and Mahan Air flights between Tehran and Damascus to send military and crowd control equipment to the Syrian regime. This activity was coordinated with Hizballah.”

  • A 2011 report by a U.N. expert panel on North Korea found that, “Prohibited ballistic missile-related items are suspected to have been transferred between the Democratic People's Republic of Korea and the Islamic Republic of Iran on regular scheduled flights of Air Koryo and Iran Air, with trans-shipment through a neighboring third country.”

  • In 2011, the U.S. Treasury Department designated Iran Air, finding that the commercial airline was “used by the IRGC and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) to transport military related equipment.” The designation further alleged that, “Iran Air has shipped military-related equipment on behalf of the IRGC since 2006. … Additionally, commercial Iran Air flights have also been used to transport missile or rocket components to Syria.”