China Is the Last Major Runway Open to Iran’s Sanctioned Airlines

Mahan Air, which Washington sanctioned in 2011 for ferrying weapons and operatives for the Islamic Revolutionary Guard Corps, is still landing in China. On September 23, hours after the U.S. Treasury Department’s deadline for foreign firms to stop servicing Iranian airlines expired, a Mahan flight from Tehran landed at Guangzhou. China is now the biggest gap in Washington’s effort to ground Iran’s airlines, less by Beijing’s decision than because Washington has not yet forced one.

On August 24, Treasury identified Iran’s aviation sector under Executive Order 13902, a 2020 order that lets Treasury sanction entire sectors of Iran’s economy. On September 8, it designated all 27 remaining Iranian airlines and nine of Mahan’s foreign enablers with a wind-down period that ended September 23. Treasury Secretary Scott Bessent was blunt: “If they land, you cannot provide them with fuel, you cannot provide them with landing services, you cannot sell them tickets, or you will be knocked out of the dollar system.”

The Region Is Closing Its Skies to Tehran; China Is Not

Most of Iran’s neighbors got the message. Turkey barred Mahan Air on September 21, and Turkish Airlines, Pegasus, and AJet suspended all Iran flights until March 2027. Oman halted Mahan flights. Iraq halted all Iran flights at four airports, including Baghdad. On September 24, the United Arab Emirates suspended every Iranian airline “until further notice,” citing the U.S. ban.

China moved the other way. A foreign ministry spokesman declared that Beijing “consistently opposes illegal unilateral sanctions.” Mahan’s route map still lists Beijing, Shanghai, Guangzhou, and Shenzhen, and Tehran’s main airport confirmed on September 26 that flights to China continue. Yet Bessent said the same week that Chinese officials had been “very engaged” on Iran sanctions after his talks with Vice Premier He Lifeng.

Every Mahan Landing in China Runs Through a Few Identifiable Providers

A Mahan aircraft cannot land, refuel, and depart without local partners, and China’s aviation-services market is unusually concentrated. Washington has already designated Mahan’s commercial network in China: Shanghai Saint Logistics, its Shanghai cargo agent, in 2020, and, on July 30, Shanghai Wings International Logistics and Shanghai Elite International Travel, identified by Treasury as its general sales agent and representative, respectively.

Fuel is the chokepoint. China National Aviation Fuel Group (CNAF) controls more than 95 percent of the country’s airport fueling infrastructure under an exclusive national franchise and, since July, has been a wholly owned subsidiary of China Petrochemical Corporation, or Sinopec. That leaves few candidates to fuel a Mahan jet: South China Bluesky at Guangzhou and Shenzhen Chengyuan at Shenzhen, both CNAF joint ventures that count BP among their shareholders, and possibly Shanghai Pudong International Airport Aviation Fuel, Pudong’s sole-source supplier.

No public record ties any of them to a specific Mahan flight. But if Mahan keeps landing, some are likely providing the “airline ground services,” “catering,” and “refueling contracts” that Treasury’s 2019 aviation advisory warned put providers “at risk of sanctions actions.” Consequently, they could face designation for materially supporting a sanctioned airline. CNAF, Sinopec, and BP have far more at stake, and none should risk those licit businesses over a handful of weekly Mahan rotations.

Washington Should Make Beijing’s Choice Easy

Washington should give Beijing the chance to comply quietly by presenting Chinese aviation authorities with flight-level evidence and a private deadline. The State Department should also engage the providers directly, as it did in 2019, when it conducted what a spokesperson called “extensive outreach” to ship captains and shipping companies “warning them of the consequences of providing support to a foreign terrorist organization.” A letter to CNAF, Sinopec, and the airport operators would let their compliance departments do the rest.

Treasury’s Financial Crimes Enforcement Network (FinCEN) should broaden its September 8 alert, which asked banks to flag suspicious purchases of aircraft parts for Iranian airlines, to cover payments for fuel, ground handling, and ticketing. If the flights continue, the next designations should reach the providers themselves, as in Turkey and Malaysia. As Iran’s carriers lose the Gulf and Turkey, every remaining route to China becomes the regime’s most valuable one.

Miad Maleki is a senior fellow at the Foundation for Defense of Democracies (FDD) and a former senior sanctions official at the U.S. Department of the Treasury. For more analysis from the author and FDD, please subscribe HERE. Follow Miad on X @miadmaleki. Follow FDD on X @FDD and @FDD_Iran. FDD is a Washington, DC-based, nonpartisan research institute focusing on national security and foreign policy.