Expanding Iran Sanctions to Aviation

A new list of sanctioned parties in the aviation industry could be on the horizon!

There is an existing Executive Order from the first Trump Administration that authorizes the Treasury Department to identify target persons and businesses as Specially Designated Nationals (SDNs) when the Secretary finds that the targets operate in certain sectors of the Iranian economy. This has traditionally included construction, mining, manufacturing, and textiles.

In a new order, the Treasury Department is adding aviation to the list of affected sectors. The new order is expected to be published in the Federal Register, tomorrow.

“I hereby determine that section 1(a)(i) of E.O. 13902 shall apply to the aviation, digital asset, gold, shipping, and technology sectors of the Iranian economy. Any person determined to operate in these sectors shall be subject to sanctions pursuant to section 1(a)(i).”

Publication of a Determination Issued Pursuant to Executive Order 13902, Federal Register (August 27, 2026).

This does not automatically impose sanctions – instead it authorizes the Secretary of the Treasury to add people and/or businesses ot the list of Specially Designated Nationals. It is typically illegal to export goods to Iran without a license, so naming Iranians as SDNs may have relatively little practical effect for American businesses. This new determination will authorize the Secretary to name SDNs from other countries who participate in the Iranian economy, and this could allow an expansion of sanctions to include more people and more companies from third countries who are doing business with Iran, especially those supporting the Iranian aviation industry.

When a person is named as an SDN, that person (and that person’s property) is blocked. This typically prevents all transactions with the blocked person. This is not just export transactions – the SDN sanctions programs typically apply to any other sort of transactions as well. Someone in the U.S. who is holding the blocked person’s property must retain that property and must file periodic reports with the Treasury notifying them of the blocked property that is held.

We expect to see more aviation companies being added to the Treasury sanctions lists as SDNs. This action highlights the importance of checking your export business partners against the US sanctions lists on every transaction.