state-owned air carrier. These licenses included authorization for United States financial institutions to engage in all transactions necessary to provide financing or other financial services in order to effectuate the sales. In November 2016, OFAC licensed an additional 106 aircraft for purchase by Iran Air, which are also eligible for financing authorized by OFAC. (6) The Department of the Treasury had sanctioned Iran Air in 2011 for its use of commercial passenger aircraft to transport rockets, missiles, and other military cargo on behalf of the Islamic Revolutionary Guard Corps (in this section referred to as the IRGC ) and Iran’s Ministry of Defense and Armed Forces Logistics, both of which had been designated under Executive Order 13382 for weapons proliferation-related activities. In October 2017, the IRGC went on to be designated under Executive Order 13224 for its support of the IRGC-Qods Force, which has provided support to terrorist groups such as Hizballah, Hamas, and the Taliban. (7) Among Iran Air’s sanctionable activities, the air carrier delivered missile or rocket components to the regime of Bashar al-Assad in Syria, which like Iran is classified as a state sponsor of terrorism. (8) The Assad regime is responsible for a civil conflict that has claimed an estimated 400,000 lives, including through the regime's deployment of chemical weapons and barrel bombs against unarmed civilians and children. (9) Despite being delisted in 2016, Iran Air has continued to fly known weapons resupply routes to government-controlled areas of Syria. According to research by the Foundation for Defense of Democracies, between Implementation Day of the JCPOA on January 16, 2016, and May 4, 2017, Iran Air operated at least 134 flights to Syria, which included stops in Abadan, Iran, a suspected IRGC logistical hub for airlifts to the Assad regime. (10) In November 2016 correspondence to the Chairman of the Committee on Financial Services of the House of Representatives, the Department of the Treasury noted that the