"US sanctions Indian firm for supporting Iran's IRGC-linked Mahan Air"
Secondary Sanctions
penalties imposed on non-US entities for transacting with US-designated parties, even without a direct US nexus
OFAC (Office of Foreign Assets Control)
US Treasury body that administers and enforces economic and trade sanctions
The United States has maintained one of the world's most extensive unilateral sanctions architectures against Iran, built on decades of concern over Iran's nuclear programme, its support for designated terrorist organisations, and the activities of the Islamic Revolutionary Guard Corps (IRGC). The IRGC was designated a Foreign Terrorist Organisation (FTO) by the US in 2019 — a historically rare step applied to a state military body — making any material support to it a potential criminal and civil liability under American law. The legal backbone of this system is the International Emergency Economic Powers Act (IEEPA), which grants the executive branch broad authority to regulate international commerce in response to declared national emergencies. The Office of Foreign Assets Control (OFAC) within the US Department of the Treasury is the primary enforcement body, maintaining the Specially Designated Nationals (SDN) list that effectively cuts designated entities off from the US financial system and dollar-denominated transactions globally.
Mahan Air, Iran's largest private airline, has been on the OFAC SDN list since 2011, designated for providing logistical and transportation support to the IRGC's Quds Force — the external operations arm responsible for Iran's proxy networks across West Asia. Despite this long-standing designation, Mahan Air has continued to operate internationally through a network of General Sales Agents (GSAs): third-party commercial entities that sell tickets, manage bookings, and provide logistical support on behalf of the airline in foreign markets. Systematically targeting these GSA networks has become a key instrument in the US strategy of maximum pressure against Iran, because it disrupts the airline's commercial viability without requiring direct military action.
The concept of secondary sanctions is central to understanding why this development matters far beyond the US-Iran bilateral relationship. Primary sanctions prohibit US persons and entities from transacting with designated targets. Secondary sanctions, by contrast, threaten to penalise non-US entities — including those in India, China, or Russia — that do business with SDN-listed parties, even when those transactions have no direct US nexus. The threat is powerful: any entity placed on the SDN list loses access to the US financial system, cannot transact in US dollars, and is effectively cut off from the global banking infrastructure that runs on dollar clearing. For a private Indian travel firm, this means potential loss of correspondent banking relationships, inability to process international payments, and reputational damage with global partners.
The GSA model is particularly significant. …
With reference to the US sanctions architecture, consider the following statements:
1.Primary sanctions prohibit US persons from transacting with designated entities, while secondary sanctions can penalise non-US entities for similar transactions.
2.The Office of Foreign Assets Control (OFAC) operates under the US Department of State.
3.The Specially Designated Nationals (SDN) list effectively cuts designated entities off from dollar-denominated transactions globally.
Which of the statements given above is/are correct?
Which of the following best describes a 'General Sales Agent (GSA)' in the context of US sanctions on Iran's Mahan Air?
Consider the following pairs:
Institution / Instrument — Function
1.OFAC / SDN List — Enforces US economic sanctions; blacklists designated entities
2.IEEPA — Grants US Congress authority to impose tariffs on foreign goods
3.EU Blocking Statute — Protects EU firms from extraterritorial application of US sanctions
Which of the pairs given above is/are correctly matched?
Which of the following statements about the Islamic Revolutionary Guard Corps (IRGC) is/are correct?
1.The IRGC was designated a Foreign Terrorist Organisation (FTO) by the United States in 2019.
2.The IRGC's Quds Force is its external operations arm responsible for proxy networks across West Asia.
3.Mahan Air was placed on the US SDN list in 2019 simultaneously with the IRGC's FTO designation.
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