Notable "Derivative" Designations - Flight Travel LLC (Armenia)

Date issued: Jan. 24 2019

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TURBOFAC Commentary (1131 words)

Notes:

1) See Introductory Note Common to all Derivative Designation Notices Included in the Research System (System Ed. Note), explaining the criteria for including designation notices in the Research System. See also General Note on Secondary Sanctions and “Derivative Designation” Criteria; Identification of the Gap Between the Theoretical and Practical Scopes of Authorities Targeting Transactions with no U.S. Nexus; Enforcement Risk Management (System Ed. Note).

2) Consolidated note on:

*Notable "Derivative" Designations - Flight Travel LLC (Armenia)
*Notable "Derivative" Designations - Mahan Travel and Tourism Sdn Bhd (Malaysia)
*Notable "Derivative" Designations - My Aviation Company Limited (Thailand)
*Notable "Derivative" Designations - Shanghai Saint Logistics Limited (China)

*BACKGROUND

These three designation actions are based on actions taken by non-Iranian "GSAs" of Mahan Air. As noted in the announcements,...