The Biden administration periodically promulgates new sanctions against Iran and its proxies. That is a sound policy. But sanctions without enforcement are easy to circumvent.
Case in point: Last Tuesday, the Biden administration announced new sanctions against Iran Air, the Islamic Republic of Iran’s flagship airline, and its 67 aircraft. The reason: Iran Air transported weapons to Russia, including long-range missiles, in support of Moscow’s murderous aggression against Ukraine. European allies have also suspended bilateral air service agreements.
Iran Air will now likely lose all its eight current routes to Europe. It is an important step, but it will only affect Iran’s malign behavior if the Biden administration now implements these sanctions by seizing aircraft at any international airport. Washington must also punish ground service providers and intermediaries with sanctions for providing material support to Iran’s aircraft.
Yet a key precedent in U.S. sanctions enforcement is not encouraging.
Consider the case of Mahan Air. In the past, the regime in Iran has relied on Mahan aircraft, in addition to Iran Air’s fleet, to transport military personnel to war-torn Syria in support of the regime of Bashar Assad. That was one of the reasons Mahan Air could not benefit from the sanctions relief the Obama administration offered Iran under the 2015 nuclear deal. Iran Air, in contrast, was delisted under the agreement, and was able to buy brand-new Airbus aircraft before the Trump administration left the nuclear deal in 2018.
Mahan has been heavily sanctioned in the past — mostly under the Obama and Trump administrations. Washington put most (but not all) Mahan aircraft on its Office of Foreign Assets Control blacklist. The U.S. also repeatedly sanctioned general service agencies representing Mahan and providing it assistance around the world.
However, Mahan just didn’t care, as Washington largely failed to enforce the sanctions.
Mahan flies among the largest fleet of Airbus A340s in the world. Earlier this year, Mahan arranged for the transfer of three widebody long-haul Airbus A340 that were registered with a Gambian leasing company and were stored in Lithuania. Two of the three planes took off, ostensibly heading to Sri Lanka and the Philippines, but eventually landed in Iran. Local authorities managed to ground the third plane, reportedly loaded with aircraft spare parts, before it could take off.
According to open-source data, the two planes Mahan has successfully procured through Lithuania in 2024 to date were not the only ones it managed to acquire since President Biden took office. In 2023, two more A340, formerly owned by Turkish Airlines, joined the Mahan Air fleet. These were likely acquired to replace three A340s that, in 2021, Mahan agreed to transfer to the Venezuelan, U.S.-sanctioned airline Conviasa through a Dubai-based broker, alongside an old Boeing 747 cargo plane. The planes duly reached Caracas, and while the U.S. Department of Justice was able to seize the Boeing 747 in Argentina, the others are operational, regularly flying to both Moscow and Tehran.
To be sure, Lithuanian authorities blocked one of these aircrafts from making its way to Iran and the Biden administration seized another in Argentina. But the intermediaries Mahan Air relied upon — those who brokered aircraft transfers and sales to a U.S.-sanctioned malign actor and may have also assisted in the procurement of vital spare parts for Iran’s aviation sector — have suffered no consequences so far.
Not only did Mahan, then, manage to procure new aircraft to its fleet through intermediaries and even transfer some of its aircraft to Venezuela, but it has also done these things largely without consequences. These days, Mahan also relies on this newly acquired aircraft to send arms to Hezbollah on regular commercial flights to Lebanon. Mahan has no problem doing this, because the limited losses incurred due to U.S. sanctions have done little to disrupt its operations.
This is a major flaw in the Biden administration’s sanctions policy which, unless rectified, will diminish the impact of these new sanctions. Once malign Iranian actors take consignment of their aircraft, there is little that U.S. authorities can do to disrupt their flights to Moscow or Beirut.
What the U.S. can do, and did quite effectively until 2020, is target intermediaries and service providers.
Mahan, after all, does not fly only to destinations whose authorities are hostile to America. The same Mahan aircraft that fly to Beirut and Moscow, likely transporting military equipment in their cargo while posing as passenger flights, also fly to many destinations in Asia, including India and Thailand. The U.S. can try to seize these aircraft at least at some of these destinations. It can sanction companies that refuel them, handle their cargo and passenger luggage, sell their tickets, and provide other ground services. It should certainly go after the intermediaries that brokered aircraft sales to Mahan — something the Biden administration has yet to do.
Sanctions are not a silver bullet; they rarely take down a target with just one attempt. Patient, long-term follow-up enforcement is what makes these measures bite. Sanctioning Iran Air was an important step. Now comes the hard part.
Emanuele Ottolenghi is a senior fellow at the Foundation for Defense of Democracies, a non-partisan research foundation based in Washington, D.C., that focuses on national security and foreign policy.