Orrick, Herrington & Sutcliffe·SANCTIONS / EXPORT CONTROLS

Treasury and FinCEN Target Iran's Aviation Procurement Networks

The U.S. Treasury sanctioned 36 entities and individuals for supporting Iran's aviation sector, while FinCEN issued a parallel alert with red flags for financial institutions to spot illicit procurement.

The U.S. Treasury Department sanctioned 36 entities and individuals for allegedly supporting Iran's aviation sector, which it says the regime uses to transport weapons and illicit cargo. The action, part of "Operation Economic Outcast," targets 27 Iranian airlines and various third-country front companies accused of facilitating the procurement of U.S.-origin aircraft. Concurrently, the Financial Crimes Enforcement Network (FinCEN) issued an alert for financial institutions, outlining specific red-flag indicators of illicit procurement schemes. Sophisticated clients care because this coordinated action significantly expands sanctions risk for the aviation, logistics, and finance industries. The new designations require immediate updates to screening protocols, while FinCEN’s alert establishes a higher bar for anti-money laundering compliance and due diligence. This signals intensified enforcement against intermediaries and facilitators of sanctions evasion. Financial institutions should immediately integrate the new red flags into their monitoring systems and use the requested keyword in suspicious activity reports, while other global businesses should reassess their supply-chain and counterparty risk.

sanctionsiranofacfincenamlaviationexport-controls
Read the original firm alert → Wednesday, September 23, 2026

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