Treasury has sanctioned the travel agents that sell tickets and cargo space for Mahan Air in China, India and Russia
Somebody has to sell the tickets.
That is the premise of Thursday's action, and the Treasury release spells it out before it names anybody: a general sales agent provides an airline with sales and customer support services and deals with freight forwarders and shippers on the airline's behalf. Mahan Air has been under United States sanctions since October 2011. Its sales agents, until Thursday, were not.
Six entities and individuals in China, India, Russia and Iran were designated by the Office of Foreign Assets Control under Executive Order 13224, the counterterrorism authority.
The agents
Treasury named Shanghai Wings International Logistics Co, which it says serves as a general sales agent for Mahan Air and has coordinated the transport of electronics from China to Iran. It named Tang Xin, the managing director of that company, who Treasury says has coordinated travel for the airline and is the executive director and half owner of Shanghai Elite International Travel Co, a second Chinese company Treasury says also represents Mahan Air. Shanghai Elite was designated for being owned or controlled by Tang Xin rather than for anything Treasury attributes to the company itself.
The other two agents are Skiez Travels and Logistics Private Limited, in India, and Air Cargo Pro Limited, in Russia.
The sixth name is not a travel company
DadeNegar Startup Studio is described in the release as a front company affiliated with the Islamic Revolutionary Guard Corps that supported military targeting through a website. Treasury says it solicited the locations of American and Israeli equipment, and that in coordination with the Guard it received strike requests for United States targets in the Middle East.
Those are Treasury's characterisations, made in a designation notice. No court has examined them.
Where the reach is
The blocking provisions are the standard ones. Property and interests in property in the United States or in the possession of United States persons are frozen, and anything owned 50 percent or more in the aggregate by blocked persons is blocked automatically, whether or not it appears on a list.
The paragraph with the longest reach is the one addressed to nobody in particular. OFAC states that foreign financial institutions knowingly conducting or facilitating significant transactions on behalf of designated parties can have their United States correspondent accounts restricted or prohibited, and that its civil penalties are imposed on a strict liability basis.
Scott Bessent, the Treasury secretary, said in the release that firms providing "financial services, logistics, or commercial support to the IRGC or Mahan Air are helping sustain a terrorist enterprise."
The release sets the action in the context of Iranian attacks on regional states and on commercial vessels in the Strait of Hormuz, which is the same waterway where this desk has been tracking an incident log that has recorded nothing new since 27 July.