The Islamic Revolutionary Guard Corps (IRGC) often plays anti-sanctions Three Card Monte by renaming designated companies. After the United Nations, United States, and European countries sanctioned the Pars Aviation Service Company due to its IRGC links, the company changed its name, first to Yas Air in 2008 and, after the UN and various governments caught up, to Pouya Air in 2014. At its core, Pars Air was a cargo airline that would carry dangerous goods no other Iranian airline could carry, such as shipments of illicit weaponry to the Levant, Ethiopia, and Sudan, and refurbished engines for the Venezuelan Air Force’s C-130H Hercules transport aircraft of the Venezuelan Air Force. With time, however, it has expanded its operations in a number of different directions. Unfortunately, sanctioning authorities have failed to keep up with Pouya’s varied activities.
True, there have been some sanctions. The U.S. Department of the Treasury’s Office of Foreign Assets Control has designated a number of aircraft belonging to Pouya Air for shuttling weaponry to Russia. Between March 27, 2022, and April 25, 2024, for example, Pouya Air flew most of the 161 known cargo and transport flights from Tehran to Moscow. That, however, ignores how the IRGC profits off other Pouya Air charters or how the airlines transports IRGC personnel and weapons elsewhere to support Iran’s malign activities. For example, Russian interests sometimes contract Pouya Air to transport weaponry if not personnel for the Wagner Group.
The IRGC has increasingly sought to enter the civilian airline industry, at first using its small fleet of Antonov An-74T-200 transport aircraft and An-74TK-200 passenger aircraft to transport both IRGC personnel and civilians within Iran. The Treasury Department’s listing of the An-74s did not stop their use, but war in Ukraine did, both because Russia horded spare parts for its own use and because the conflict interrupted operations at the company’s Kyiv headquarters.
With the An-74s grounded, and a Dassault Falcon 20F business jet also grounded, the IRGC purchased two aging Embraer ERJ-145EP regional jets and a Challenger 604 business jet from Hossein Hafez Amini, a Qods Force-affiliated businessman in Turkey. Replacement of sanctioned aircraft with new planes remains a loophole Iran exploits.
Pouya Air officially operated the three jets. The Embraers ferried both IRGC members and passengers between bases while IRGC generals and government officials used the business jets. Mahan Air, also sanctioned by the U.S. Department of the Treasury due to its IRGC affiliation, helped Pouya Air hire non-Iranian pilots and maintenance engineers to train IRGC pilots and technicians to fly and maintain the ERJ-145EPs.
In 2020, as the ERJ-145EPs useful life neared their end, Mahan Air’s front companies in Russia procured three ERJ-145LRs, the long-range variant of ERJ-145EPs, as well an ERJ-145LU, a model that allows for increased take-off weight, from a Namibian airline. The aircraft flew via Algeria, Spain, and Russia prior to their arrival in Iran between February and May 2021. Mahan Air received a fourth ERJ-145LR in December 2023. The IRGC trained former An-74 and Il-76 pilots to fly the newly acquired aircraft. In preparation for the new planes’ arrival, they trained in one of Lufthansa’s Aviation Training Centers in Germany. This too, represents a sanctions loophole, albeit a vulnerability the regime seeks to end by establishing its own indigenous simulators.
The new aircraft increased Pouya Air’s profitability significantly as they as doubled the number of passengers flown on domestic routes over a year, and increased Pouya Air’s total domestic flights by more than half. Pouya can cannibalize its aging and retired aircraft to keep the ERJ-145LR/LU aloft for perhaps a year. The failure to sanction the Pouya’s five remaining Embraers makes it easier for the IRGC-linked company to obtain spare parts from abroad to keep the fleet shuttling contraband for far longer.
Another loophole the IRGC exploits is to have the Iranian Civil Aviation Organization assign its Ilyushin-76TD transport aircraft sham or temporary registration codes to enable them to shuttle weaponry to Russia and Syria. Designating Iran’s entire Ilyushin fleet regardless of specific registration codes would end this Iranian fraud. Likewise, designating the Antonov-74 fleet would cease Pouya Air’s ability to use them to fly missions to Iraq and Syria on behalf of the IRGC and Qods Force.
When Western diplomats debate whether sanctions are effective in constraining the IRGC and the Iranian arms trade, too often they address the issue philosophically rather than identify how Iran evades sanctions and exploits loopholes. Pouya Air continues to operate despite sanctions not because sanctions are necessarily ineffective, but rather because those seeking to constrain the regime’s behavior do not act proactively to constrain the IRGC’s aviation racket.
