On September 8, 2026, FinCEN issued an Alert to assist financial institutions in identifying and reporting procurement networks supporting Iran’s aviation industry, which the Iranian regime uses to transport weapons, funds, and personnel in support of the Islamic Revolutionary Guard Corps (IRGC) and its terrorist proxies. In conjunction with the alert, OFAC sanctioned 36 targets, including 27 Iranian airlines, for supporting Iran’s aviation sector, which the regime uses to move weapons, personnel, and illicit cargo.
FinCEN has identified the following red flag indicators to help financial institutions detect, prevent, and report potentially suspicious activity involving Iran’s procurement of aircraft and aircraft parts, including when Iran’s direct involvement is not readily identifiable in transaction details:
A recently incorporated technology, aviation, or logistics company with an opaque ownership structure and a limited online presence in a jurisdiction at high risk for transshipment to Iran makes a large number of purchases of aircraft parts or other components that may be used in the commercial aviation industry from U.S. or Western technology and aeronautics companies.
A recently incorporated technology, aviation, or logistics company in a jurisdiction at high risk for transshipment to Iran lists a residential address as its business address, shares beneficial ownership information with an unusual number of other companies, or is co-located at the same physical address or shares a PO Box with other companies that fit a similar profile and were established at or around the same time.
Documentation or due diligence associated with the sale of an aircraft indicates that the aircraft has been in storage for an extended period of time or has undergone frequent reregistrations, layered changes in ownership by companies in multiple jurisdictions, or an unusual number of moves between jurisdictions, particularly in Central Asia, in the lead up to the sale.
A customer with a nexus to Iran engaged in commercial aviation procurement claims that their activities are authorized by OFAC or BIS without providing copies of any OFAC or BIS authorizations, particularly if open-source aviation databases indicate that aircraft previously owned or handled by the company were subsequently transferred to Iran through one or more intermediary jurisdictions.
A company, particularly a general trading company, located in a free trade zone or a jurisdiction at high risk for Iranian commercial aviation procurement which does not ordinarily appear to deal in aviation goods attempts to place orders for U.S.- or Western-origin aircraft parts or components.
A customer located in a jurisdiction of concern for Iranian aviation procurement places orders for U.S.- or Western-origin aircraft parts or components from firms in one country for delivery to freight forwarding or logistics firms in a second country.
The movement of aircraft parts is handled by a logistics or air freight company that does business in Iran or works with sanctioned Iranian or Russian airlines or aviation companies.
Read FinCEN’s press release here.
Read the Treasury’s full press release here.
The Alert can be found here.