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S E C R E T STATE 018255 
 
SIPDIS 
 
NOFORN 
SIPDIS 
 
E.O. 12958: DECL: 02/22/2018 
TAGS: EAIR ETRD ETTC IR KS PARM PREL UK
SUBJECT: REQUEST FOR KOREA TO HOLD CIVILIAN U.S.-ORIGIN 
COMMERCIAL AIRCRAFT BOUND FOR IRAN 
 
Classified By: Classified by EEB/ESC/TFS Director Steve Bondy for reasons 1.4 (b) and (d). 1. (U) This is a request for immediate action. Please see para 2. 

¶2. (S/NF) Summary and Action Request: According to reporting, there are three Boeing 747-400 aircraft owned by the UK's Balli Group currently undergoing maintenance in South Korea. We have strong reason to believe the aircraft are intended for delivery to Iranian civil airline Mahan Air. Delivery of the aircraft to Mahan Air would violate the U.S. Export Administration Regulations and Iranian Transactions Regulations. Post is requested to approach the ROKG on an immediate basis and, drawing on the points in para 3, seek its assistance in grounding the identified aircraft and facilitating a U.S. Department of Commerce redelivery order on Balli Group. 

¶3. (S/REL South Korea) Begin text of points: -- We value our strong bilateral dialogue and relationship with the ROKG. In that context, we want to raise our concerns about a potential transfer to Iran of several U.S.-origin commercial passenger aircraft that, if completed, could constitute a violation by the UK-based Balli Group of the U.S. Export Administration Regulations and Iranian Transactions Regulations. -- We recently learned that there are three Boeing 747-400 aircraft in South Korea undergoing maintenance that we believe are intended for delivery to an Iranian civil airline. Two are at the Incheon International Airport, tail numbers N106UA and N192UA, and one is at the Kimhae International Airport, tail number N185UA. -- Public aviation databases show that the planes at Incheon will be registered to Blue Airways of Armenia. The true owner of the planes is the Balli Group of the UK. All three planes are painted in the livery of Blue Sky, which is a subsidiary of the Balli Group. The Balli Group is composed of expatriate Iranian owners who maintain ties to Iranian regime members. -- We have strong reason to believe the three planes are destined for Iran. Three other airplanes in Blue Sky livery that were acquired over a year ago by Balli Group have gone into service with Mahan Air, which leases the planes from Blue Airways. Blue Airways leases all of its aircraft to Mahan Air. Mahan Air is associated with the Iranian Islamic Revolutionary Guard Corps (IRGC). -- On October 25, 2007, the United States designated the IRGC pursuant to U.S. Executive Order 13382 (Proliferation Finance) for its support to Iranian ballistic missile and nuclear programs. In addition, several IRGC entities and individuals are sanctioned under UN Security Council Resolutions 1737 and 1747. -- Given Iran's continued sponsorship of international terrorism as well as its missile program, we remain concerned about its ability to misuse civilian aircraft for nefarious activities. Iran's control of additional aircraft could enhance its military capabilities or facilitate its support for international terrorism. -- The Iranian Transactions Regulations (31 CFR section 560.205) and the Export Administration Regulations (15 CFR section 746.7) prohibit the reexportations being contemplated in these cases. -- On February 22, 2008, the U.S. Department of Commerce's Office of Export Enforcement served an order on the Balli Group requiring the Balli Group to deliver the three Boeing 747 aircraft to the United States for inspection. This order was made pursuant to authorities in the United States Export Administration Regulations (15 CFR 758.8). The order was hand delivered to Balli Group's office in Houston, Texas. -- We strongly request your government's assistance in taking immediate steps to keep the three aircraft grounded while the United States Government considers law enforcement alternatives. We also request that your government facilitate a U.S. Department of Commerce redelivery order requiring Balli Group to return the aircraft to the United States. -- We look forward to continued consultation with your government on this matter. We value our close and ongoing cooperation with the Government of South Korea. End text of points. 

¶4. (U) Washington appreciates post's assistance. Please include SIPDIS in all replies and slug for EEB/ESC/TFS, ISN/CPI, EAP/K, TREASURY/OFAC, COMMERCE/OEE. POCS for this activity are Paul Loh and David Bendana. RICE 0 02/23/2008 4549 EAIR,ETRD,ETTC,IR,KS,PARM,PREL,UK