Farzin Nadimi, a Senior Fellow with The Washington Institute, is a Washington-based analyst specializing in the security and defense affairs of Iran and the Persian Gulf region.
Brief Analysis
President Raisi’s fatal crash put a spotlight on the dire state of aviation safety in Iran, but the regime’s gross mismanagement and corrupt profiteering are to blame, not foreign sanctions.
On May 19, two Canadian-made Bell 212 helicopters and one Russian-made Mil Mi-171 helicopter were flying to Tabriz, Iran, from the Aras border region with Azerbaijan when one of the Bells suddenly went missing. Among its eight passengers and crewmembers were President Ebrahim Raisi and Foreign Minister Hossein Amir-Abdollahian. After a frantic search effort, the wreckage was finally found eighteen hours later in a densely forested mountainous region. Unsurprisingly, the rumor mill has been in full swing ever since, with commentators inside Iran and abroad speculating about the cause of the accident. One such narrative—frequently repeated by Iranian officials—is that U.S. sanctions on the country’s aviation sector are responsible. Yet even a cursory look at the details of the incident and Iran’s poor aviation safety record makes clear that the regime itself is to blame.
Tehran’s Narrative Ignores Context
Since 1980, the Iranian regime has been subjected to a variety of U.S., UN, and European sanctions for numerous reasons, such as seizing the U.S. embassy in Tehran, committing and supporting acts of terrorism, running a secret nuclear program, and violating the basic rights of its citizens. In each case, the objective was to change Tehran’s illicit behavior and curb its ability to produce or obtain military and nuclear materiel. Inevitably, these sanctions also affected civilian aviation—for the simple reason that Iran’s murky, military-affiliated aviation sector has played an extensive role in supporting its destabilizing actions abroad. Yet the regime’s gross mismanagement of available assets, resources, and sanctions exemptions is what truly wound up putting Raisi and everyday Iranian air travelers at risk, whether due to corruption, inadequate training, lack of a robust maintenance culture, or all of the above.
During multiple U.S. administrations, Iran was offered opportunities to obtain newer aircraft, parts for crucial repairs, and Supplemental Type Certificate upgrades for its commercial aircraft. Indeed, the purchase of helicopters from Bell Textron Canada in the early 1990s would not have been possible without this U.S. greenlight—including the very helicopter that crashed on May 19. In January 2016, the Joint Comprehensive Plan of Action lifted all UN sanctions and many U.S. sanctions, giving Iran further chances to purchase hundreds of new jetliners. Yet very few of those deals went through, in part because international financial institutions still regarded Iran as a high-risk jurisdiction.
Moreover, Tehran decided long before to purchase secondhand planes and spare parts using an elaborate network of front companies and murky financial arrangements around the world. Part of the reason for favoring this practice is because it yields higher commissions for the Iranian fixers who negotiate the purchases—who in many cases either hold government positions in the aviation sector or are family members of such officials. Today, Western manufacturers no longer support their aviation-related products in Iran, and many of the country’s planes and helicopters continue to fly with questionable airworthiness and maintenance records. Indeed, once the regime went down this path, it never felt the need to return to legitimate, safe ways of conducting its aviation business.
This stance persisted despite the fact that U.S. regulations have long given Iran a window to request licenses on a case-by-case basis for exporting and re-exporting goods, services, and technology intended to bolster the safety of its civil aviation sector and its U.S.-origin commercial passenger aircraft. Tehran has repeatedly hesitated to file such requests—partly because of its hostile anti-American stance, rigid “revolutionary” goals, and militant foreign policy, but also because its “dual-use” airline industry served its regional adventurism more than anything else.
For example, in 2014 and 2018, the U.S. Treasury Department issued sanctions against Meraj Air and the Iran Helicopter Support and Renewal Company, the country’s main support center for helicopters. These entities oversee the “Islamic Republic Hangar,” the facility that manages the helicopters involved in the May 19 crash. Both were designated because of the logistical support they provide to the Islamic Revolutionary Guard Corps-Qods Force, including long-term efforts to ferry weapons and other illicit cargo to the Assad regime in Syria.
The Crash and Unanswered Safety Questions
The regime’s narrative about Raisi’s accident conveniently ignores crucial technical details as well. The Bell 212 is regarded as a safe helicopter, and the one that crashed on May 19 (serial no. 6-9204) was not built during the 1970s or purchased by the shah, contrary to recent claims. As noted above, it was produced in Canada and sent to Iran as part of a larger delivery in the 1990s.
In its latest brief update on May 29, the investigation committee appointed by Iran’s Armed Forces General Staff dismissed mechanical malfunction, sabotage, or any form of external interference as possible causes of the crash. Yet looking at the incident more closely reveals a host of mistakes that likely combined to doom the flight, prolong the search effort, and prevent precise assessments of what went wrong:
The convoy of three helicopters was cleared to take off despite a bad weather forecast and low cloud cover along the route.
The Bell 212 carrying Raisi was apparently the least-equipped of the three and the least-suitable for flying in adverse weather. The VIP passengers had the option of riding in the larger and better-equipped Russian-made Mi-171 but chose the Bell instead.
Other helicopters available in the Islamic Republic Hangar would have been more capable options as well, including two Bell 412s with more powerful engines, a four-blade rotor system, faster maximum speed, higher service ceiling, and more modern avionics.
The other two helicopters in the convoy were equipped with weather radars that should have provided forewarning of unsafe conditions ahead.
Apparently, neither Raisi’s aircraft nor any of the other helicopters operated by the Islamic Republic Hangar are equipped with functional emergency locator transmitters or ADS-B transponders, which could have led rescuers to the crash site fairly quickly. The Iranian government is responsible for equipping all of its aircraft with such vital safety equipment, and sanctions are no excuse for this lapse. Although it is unclear if Tehran ever applied to obtain U.S. emergency locators for its helicopters, all of the equipment in question is readily available from suppliers in numerous other countries.
Many civilian helicopters are equipped with cockpit voice recorders or flight data recorders, but it is unknown if Raisi’s Bell 212—which was originally purchased in civilian configuration—had these technologies (notably, the Mi-171 in his convoy did). If the 212 had been so equipped, the United States and various international aviation safety organizations could have offered Tehran help with downloading and decoding the data.
To get ahead of any further accusations that U.S. policy is somehow responsible for Raisi’s crash, the Biden administration should publicly put the onus back on Tehran where it belongs. In particular, it should emphasize that any sanctions-related effects on Iran’s aviation sector stem directly from the regime’s decades-long practice of using civilian airlines and aircraft to transport weapons, ammunition, and military personnel throughout the region in support of terrorism and other destabilizing activities. The Iranian public needs to know that its leaders have deliberately chosen to continue operating aging, unsafe, and unsupported aircraft—often for their own financial gain—despite being given multiple avenues for upgrading the sector and mitigating the risks of disaster.
Farzin Nadimi is a senior fellow with The Washington Institute.
