On September 8, Treasury announced sanctions against 36 entities and individuals under “Operation Economic Outcast” for allegedly supporting Iran’s aviation sector, which Treasury says the regime uses to transport weapons, personnel, and illicit cargo. The action, taken pursuant to Executive Order 13224 and Executive Order 13902, designated 27 Iranian airlines operating in the aviation sector and targeted third-country intermediaries and “front” companies that facilitated a sanctioned Iranian airline’s procurement of U.S.-origin aircraft through deceptive transshipment routes. OFAC also suspended Iran-related aviation authorizations including overflights and non-U.S. airlines flying U.S.-origin or U.S.-controlled commercial aircraft into Iran. Concurrently, FinCEN issued an alert outlining red flag indicators to help financial institutions identify and report procurement networks supporting Iran’s illicit acquisition of U.S.-origin aircraft through front companies in Europe, the Middle East, Africa and Asia. FinCEN noted that institutions should consider “the totality of available facts and circumstances” when assessing the indicators, such as a customer’s historical financial activity.

The red flags include: (i) opaque ownership structure and limited online presence; (ii) listing a residential address as a business address or sharing ownership with an unusual number of companies; (iii) indication that an aircraft has been in storage for an extended period of time or has repeatedly changed ownership; (iv) customers claiming OFAC or Bureau of Industry and Security authorization without providing copies of any such authorizations; (v) uncharacteristic attempts to place orders for U.S.- or Western-origin aircraft parts or components; (vi) a customer located in a jurisdiction of concern for Iranian aviation procurement placing orders for U.S.- or Western-origin aircraft parts from firms in one country for delivery to firms in a second country; and (vii) aircraft parts that are handled by a company that does business in Iran or works with sanctioned Iranian or Russian airlines or aviation companies. FinCEN requested that financial institutions include the key term “FIN-2026-IRANAIR” in SAR field 2 when filing suspicious activity reports related to this activity.