Audit log

Every state-changing event for Babak Zanjani Network — Expanded OFAC Designations (July 2026): moderation decisions on community submissions, plus corrections and updates from the news pipeline. URL-based decisions are designed to carry three independent witnesses — the original source, an Internet Archive snapshot, and a Solana memo signed by our publicly-disclosed publisher key. Archive coverage is still being backfilled, so each decision below reports its own snapshot status rather than assuming one exists.

1. #1publishby system:backfill

   2026-07-29 17:27:13Z
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   {"actor":"system:backfill","investigation_id":"bcc27c32-d908-481f-bc22-6b47a6d8bf2d","kind":"publish","page_slug":"babak-zanjani-network-expanded-ofac-designations-july-2026","published_at":"2026-07-29T17:27:12.946Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"Babak Zanjani Network — Expanded OFAC Designations (July 2026)","sections":[{"content":"Babak Morteza Zanjani is an Iranian businessman with an estimated pre-arrest fortune of $14 billion. He built an international commercial network stretching from Turkey to Malaysia and the UAE that he used to route Iranian oil proceeds during the Ahmadinejad era. In late 2013, Iranian authorities arrested him for allegedly withholding $2.7 billion owed to the Ministry of Petroleum. In March 2016, an Iranian court sentenced him to death for embezzlement and 'spreading corruption on earth' in connection with funds taken from the National Iranian Oil Company (NIOC). Iran's Supreme Court confirmed the sentence; however, following the alleged repatriation of approximately $2.1 billion in assets, the sentence was commuted on April 30, 2024, to 20 years of imprisonment. Following release on reduced terms, Zanjani reemerged as the CEO of Dot One Value Creation Group, a conglomerate spanning logistics, telecommunications, aviation, rail construction, ride-sharing, gold production, and digital assets. In April 2025, Dot One Rail Company publicly announced an $800 million contract with the Islamic Republic of Iran Railways, which Zanjani promoted on social media.","heading":"Background: Babak Zanjani and the Dot One Conglomerate","severity":"critical","sources":[{"credibility":1,"name":"Treasury Further Dismantles Iranian Financier Zanjani's Network — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":2,"name":"Babak Zanjani — Wikipedia","type":"other","url":"https://en.wikipedia.org/wiki/Babak_Zanjani"},{"credibility":2,"name":"Iran Billionaire Businessman Sentenced to Death Over Embezzlement — The Quint","type":"news_article","url":"https://www.thequint.com/news/world/iran-billionaire-businessman-sentenced-to-death-over-embezzlement"},{"credibility":2,"name":"One Iranian Tycoon's Roller-Coaster: An Oil Empire, a Death Sentence, Freedom and Now Western Sanctions — Kharon","type":"research","url":"https://www.kharon.com/brief/iran-news-babak-zanjani-us-uk-sanctions-dotone"}]},{"content":"On January 30, 2026, OFAC designated Zanjani alongside two UK-registered digital asset exchanges he controlled: Zedcex Exchange Limited and Zedxion Exchange Limited. This marked the first time OFAC had ever designated digital asset exchanges specifically linked to IRGC activities. Seven TRON blockchain wallet addresses attributed to Zedcex were included in the designation. Elliptic's blockchain analysis documented that those seven addresses had processed over $389 million combined, with a single address (TLvuvpfBKdxddxSsJefeiGCe9eVY8HUroE) having received $149.3 million. One address was previously blacklisted by Tether in June 2025. TRM Labs subsequently published analysis documenting approximately $1 billion in total IRGC-linked flows through Zedcex infrastructure: approximately $23.7 million in 2023, $619.1 million in 2024, and $410.4 million in 2025. The primary asset used was USDT (Tether) on the TRON blockchain. Over $10 million in USDT was transferred directly from wallets attributed to both Zedcex and the IRGC to addresses controlled by Sa'id Ahmad Muhammad al-Jamal, an OFAC-designated Houthi financier, with no intermediary routing through mixers. Funds from Zedcex also reached Iran's largest domestic cryptocurrency exchanges, including Nobitex, Wallex, and Aban Tether. Zedxion operated a proprietary stablecoin called USDZ, marketed as dollar-pegged and promoted via Persian-language Telegram channels. Both exchanges used ChainUp, a Singapore-based white-label crypto infrastructure provider, for custody, wallet management, and trading backend systems. OCCRP's investigation revealed that Zedxion listed a fabricated CEO named 'Elizabeth Newman,' portrayed using stock footage of a hired model from a Shutterstock video titled 'Pretty black woman talking to camera.' Corporate records showed Zanjani himself previously served as listed controller under the name 'Babak Morteza' until August 2022. The exchanges allegedly processed over $94 billion in total transactions since 2022.","heading":"January 2026 OFAC Designation: Zedcex and Zedxion","severity":"critical","sources":[{"credibility":2,"name":"OFAC sanctions exchanges Zedcex and Zedxion for assisting in Iranian sanctions evasion — Elliptic","type":"research","url":"https://www.elliptic.co/blog/ofac-sanctions-exchanges-zedcex-and-zedxion-for-assisting-in-iranian-sanctions-evasion-and-irgc-operations"},{"credibility":2,"name":"How Two UK-registered Companies Moved Over a Billion in Stablecoins for the IRGC — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/how-two-uk-registered-companies-moved-over-a-billion-in-stablecoins-for-the-irgc"},{"credibility":1,"name":"The Cat and the Stock-Footage CEO: How a Digital Trail Helped Unmask an Iranian Money Machine — OCCRP","type":"news_article","url":"https://www.occrp.org/en/investigation/the-cat-and-the-stock-footage-ceo-how-a-digital-trail-helped-unmask-an-iranian-money-machine"},{"credibility":2,"name":"Crypto exchanges sanctioned alongside Iranian officials in Trump administration's Iran crackdown — The Block","type":"news_article","url":"https://www.theblock.co/post/387935/crypto-exchanges-sanctioned-alongside-iranian-officials-in-trump-administrations-iran-crackdown"},{"credibility":2,"name":"OFAC Sanctions Zedcex and Zedxion in First-ever Designation of an IRGC-linked Digital Asset Exchange — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-zedcex-and-zedxion-in-first-ever-designation-of-an-irgc-linked-digital-asset-exchange"}]},{"content":"The July 24, 2026 OFAC action designated four individuals under Executive Order 13902 for acting on behalf of or materially assisting the Zanjani network. Mehdi Rezazadeh served as chairperson of Zedpay Finansal Sistem Ve Hizmetleri Anonim Sirketi, the Istanbul-based fintech. He was individually designated for having 'acted or purported to act for or on behalf of' Zedpay. He had previously appeared in records linked to UK corporate structures and international mining-investment forums involving Iran, Russia, China, and Africa. Sukhrob Oimakhmadov was designated as manager of Zedx DMCC, the Dubai-registered entity that acted on Zedcex's behalf regarding exchange wallets. He was designated for having 'acted or purported to act for or on behalf of' Zedx DMCC. Bahareh Morteza Zanjani, Babak Zanjani's sister and an Iranian national residing in the UAE, was designated for managing BZ Diamond FZCO, a Dubai-based dealer in lab-grown and natural diamonds. Treasury alleged that BZ Diamond promoted Zedxion's NFT marketplace and issued the BZ Diamond token on the Zedxion blockchain, constituting material support to the designated exchange. Solmaz Bani, described as Zanjani's significant other and a Dutch national based in Dubai, was designated for materially assisting the network's operations. OCCRP reporting established operational connections between Bani and Zanjani's exchanges through shared social media imagery, including a distinctive purple-collared cat appearing in both Bani's personal social media and Zedxion's official Telegram channel. Bani allegedly served as website registrant for multiple Zanjani-controlled companies.","heading":"July 24, 2026 OFAC Expansion: Designated Individuals","severity":"critical","sources":[{"credibility":1,"name":"Treasury Further Dismantles Iranian Financier Zanjani's Network — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":1,"name":"US Sanctions Family of Iranian Tycoon in Crackdown on Alleged IRGC Crypto Network — OCCRP","type":"news_article","url":"https://www.occrp.org/en/news/us-sanctions-family-of-iranian-tycoon-in-crackdown-on-alleged-irgc-crypto-network"},{"credibility":2,"name":"Treasury Expands Sanctions Against Babak Zanjani's Network — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/treasury-expands-sanctions-against-babak-zanjanis-network-targeting-the-commercial-ecosystem-behind-zedcex"},{"credibility":2,"name":"US sanctions İstanbul fintech linked to Iranian sanctions evasion network — Turkish Minute","type":"news_article","url":"https://www.turkishminute.com/2026/07/25/us-sanctions-istanbul-fintech-linked-to-iranian-sanctions-evasion-network/"}]},{"content":"Nine entities were designated in the July 24, 2026 action. The Dot One Value Creation Group was designated as the primary holding company for Zanjani's conglomerate, covering logistics, telecommunications, aviation, transportation, and digital assets with Zanjani serving as CEO. DotOne Gold Company was designated for gold bar minting, production, and custody operations; Treasury identified it as integral to the operations of Tala Token, an allegedly gold-backed digital asset operating within Zedcex's ecosystem. DotOne Rail Company was designated following its April 2025 $800 million contract with the Islamic Republic of Iran Railways, which Zanjani publicized on social media. DotOne Barter Company was designated for serving as a clearing house for the conglomerate's financial flows. DotOne Airlines Company and DotOne Trip (a ride-sharing service) were also designated as components of the conglomerate's diversified revenue base. On the international support side, Zedpay Finansal Sistem Ve Hizmetleri Anonim Sirketi — registered on May 24, 2022, and operating from Tekstilkent Plaza in Istanbul's Esenler district — was designated for providing digital wallets and cross-border payment services integrated into the Zedxion platform, enabling fiat settlement and international payment capabilities the exchange otherwise lacked. Zedx DMCC, a Dubai-registered entity, was designated for acting on Zedcex's behalf regarding exchange wallet infrastructure. BZ Diamond FZCO, also Dubai-registered, was designated for promoting Zedxion's NFT marketplace and issuing the BZ Diamond token on the Zedxion blockchain. Treasury also designated Iranian support entities Bonyan Rasaneh Ertebat Gostar, Pouya Tarh Pars, Saman Tejarat Barman Trading Co., and Saman Tejarat Barman Holding Co., which provided additional operational and financial support within Iran. All designations were made under Executive Order 13902.","heading":"July 24, 2026 OFAC Expansion: Designated Entities","severity":"critical","sources":[{"credibility":1,"name":"Treasury Further Dismantles Iranian Financier Zanjani's Network — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":1,"name":"Iran-related Designations — OFAC Recent Actions July 24, 2026","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20260724"},{"credibility":2,"name":"US Treasury Broadens Sanctions On Babak Zanjani Network — Crowdfund Insider","type":"news_article","url":"https://www.crowdfundinsider.com/2026/07/293941-us-treasury-broadens-sanctions-on-babak-zanjani-network-hitting-wider-commercial-support-structure-for-zedcex/"},{"credibility":2,"name":"Istanbul Fintech Firm Zedpay Blacklisted By US Over Links To Iran Sanctions Evasion Network — Crowdfund Insider","type":"news_article","url":"https://www.crowdfundinsider.com/2026/07/293778-istanbul-fintech-firm-zedpay-blacklisted-by-us-over-links-to-iran-sanctions-evasion-network/"},{"credibility":2,"name":"US sanctions Turkish, UAE subsidiaries in Iran's Zanjani crypto network — Turkiye Today","type":"news_article","url":"https://www.turkiyetoday.com/business/us-sanctions-turkish-uae-subsidiaries-in-irans-zanjani-crypto-network-3224589"},{"credibility":2,"name":"US Treasury adds ZEDX DMCC, ZedPay, BZ Diamond to Babak Zanjani sanctions list — Coin Turk","type":"news_article","url":"https://en.coin-turk.com/us-treasury-adds-zedx-dmcc-zedpay-bz-diamond-to-babak-zanjani-sanctions-list/"}]},{"content":"Elliptic's analysis of the January 2026 OFAC designation documented seven TRON wallet addresses attributed to Zedcex with combined processed volumes exceeding $389 million. The seven designated TRON addresses are: TGsNFrgWfbGN2gX25Wcf8oTejtxtQkvmEx, TTS9o5KkpGgH8cK9LofLmMAPYb5zfQvSNa, TCzq6m2zxnQkrZrf8cqYcK6bbXQYAfWYKC, TLvuvpfBKdxddxSsJefeiGCe9eVY8HUroE, TNuA5CQ6LB4jTHoNrjEeQZJmcmhQuHMbQ7, TASWbk6X1wiTku5TMmMQYqYFvshVEtfJy8, and TCA9vmjsYw9MtPKEwRBtGhKFRfr4CLxJAv. One of these addresses was blacklisted by Tether in June 2025 prior to the OFAC designation. TRM Labs' analysis identified direct USDT transfers from Zedcex-attributed wallets to wallets designated by Israeli authorities as IRGC property, and documented over $10 million transferred without intermediary routing to Sa'id Ahmad Muhammad al-Jamal, an OFAC-designated Houthi financier. The July 2026 action's queue context notes that Elliptic confirmed on-chain transaction links between newly designated entities and January 2026 Zedcex/Zedxion wallet infrastructure, though specific wallet addresses or transaction hashes for the newly designated July 2026 entities have not been independently verified in publicly available sources at the time of this investigation. Zanjani also allegedly disclosed documents describing purchases of at least $507 million in USDT by Iran's central bank, which Elliptic's analysis connected to efforts to support the value of the Iranian rial.","heading":"On-Chain Evidence and Blockchain Analytics","severity":"critical","sources":[{"credibility":2,"name":"OFAC sanctions exchanges Zedcex and Zedxion — Elliptic","type":"on_chain","url":"https://www.elliptic.co/blog/ofac-sanctions-exchanges-zedcex-and-zedxion-for-assisting-in-iranian-sanctions-evasion-and-irgc-operations"},{"credibility":2,"name":"How Two UK-registered Companies Moved Over a Billion in Stablecoins for the IRGC — TRM Labs","type":"on_chain","url":"https://www.trmlabs.com/resources/blog/how-two-uk-registered-companies-moved-over-a-billion-in-stablecoins-for-the-irgc"},{"credibility":2,"name":"OFAC Designates Iranian-Linked Crypto Exchanges — Chainalysis","type":"on_chain","url":"https://www.chainalysis.com/blog/ofac-designates-iranian-crypto-exchanges-january-2026/"}]},{"content":"Treasury and investigative outlets documented multiple layers of obfuscation employed by the network. Zedxion listed a fabricated CEO, 'Elizabeth Newman,' in UK company filings; OCCRP established the individual was a stock-footage model whose image appeared in a Shutterstock video titled 'Pretty black woman talking to camera.' No passport records, migration history, or other corroborating evidence of her existence were found. Zanjani himself was previously listed as controller under the alias 'Babak Morteza' until August 2022, after which the fictitious executive replaced him in company records. Zedcex and Zedxion filed representations of dormancy to UK Companies House authorities while allegedly processing hundreds of millions of dollars in active transactions. OCCRP and TRM Labs documented that shared domain infrastructure, email addresses, and corporate rotation cycles were used systematically across entities in the network. The Dot One conglomerate's diversification across aviation, rail, ride-sharing, gold, and diamond sectors is described by Treasury as serving the purpose of obscuring ownership, laundering revenue, and expanding covert fund movement capacity. Solmaz Bani's connection to the operation was partly established through a distinctive purple-collared cat appearing in both her personal social media accounts and Zedxion's official Telegram channel.","heading":"Network Obfuscation and Corporate Deception","severity":"high","sources":[{"credibility":1,"name":"The Cat and the Stock-Footage CEO — OCCRP","type":"news_article","url":"https://www.occrp.org/en/investigation/the-cat-and-the-stock-footage-ceo-how-a-digital-trail-helped-unmask-an-iranian-money-machine"},{"credibility":2,"name":"Fake CEO and cat photos help uncover billion-dollar IRGC crypto network — Iran International","type":"news_article","url":"https://www.iranintl.com/en/202602279443"},{"credibility":2,"name":"Fake UK executive fronted $1b IRGC crypto scheme — Jerusalem Post","type":"news_article","url":"https://www.jpost.com/middle-east/iran-news/article-888675"},{"credibility":2,"name":"Treasury Expands Sanctions Against Babak Zanjani's Network — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/treasury-expands-sanctions-against-babak-zanjanis-network-targeting-the-commercial-ecosystem-behind-zedcex"}]},{"content":"All designations in both the January 30, 2026 and July 24, 2026 OFAC actions were made under Executive Order 13902, which targets individuals and entities operating in Iran's construction, mining, manufacturing, and textiles sectors and those providing material support to designated persons. As a result of these designations, all property and interests in property of the designated individuals and entities within U.S. jurisdiction are blocked. U.S. persons are generally prohibited from engaging in transactions with the designated parties. The July 2026 action represents Treasury's second enforcement wave against the Zanjani network within six months. As of the date of this investigation, no criminal indictments in U.S. courts have been identified in publicly available sources in connection with the July 2026 expansion. Babak Zanjani remains subject to a 20-year imprisonment sentence in Iran, though the degree to which this restricts his operational control of the Dot One network is unclear from public reporting. The UK's Companies House registration status of Zedcex Exchange Limited and Zedxion Exchange Limited following the designations has not been confirmed in publicly available sources as of the date of this investigation.","heading":"Regulatory and Legal Status","severity":"critical","sources":[{"credibility":1,"name":"Treasury Further Dismantles Iranian Financier Zanjani's Network — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":1,"name":"Iran-related Designations — OFAC Recent Actions July 24, 2026","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20260724"},{"credibility":2,"name":"Last Week's Major Developments in Sanctions — July 20 to July 24, 2026","type":"research","url":"https://www.sanctionsexpert.com/post/last-week-s-major-developments-in-sanctions-july-20-to-july-24-2026"}]},{"content":"The combined January and July 2026 OFAC actions create substantial compliance obligations for any digital asset platform that may have processed transactions involving Zedcex Exchange Limited, Zedxion Exchange Limited, Zedpay, Zedx DMCC, BZ Diamond, or any of the designated Dot One entities. Zedcex's use of ChainUp's white-label infrastructure raises questions for other ChainUp clients regarding shared wallet infrastructure exposure, though no ChainUp designation or allegation has been identified in publicly available sources. The designation of TRON-based wallet addresses underscores the use of the TRON blockchain and USDT for sanctions evasion. AML Intelligence and TRM Labs both noted that the network's use of integrated fiat-rail providers such as Zedpay — providing conventional currency settlement alongside crypto trading — represents a pattern of hybrid evasion that complicates blockchain-only screening. Compliance teams are advised to screen all seven OFAC-designated TRON addresses and to review any counterparty relationships with Istanbul- or Dubai-based entities offering integrated digital wallet and payment services to crypto exchanges operating in or proximate to Iranian markets.","heading":"Compliance Implications for Crypto Platforms","severity":"high","sources":[{"credibility":2,"name":"NEWS: US hits network of Iranian financier Zanjani with more sanctions — AML Intelligence","type":"news_article","url":"https://www.amlintelligence.com/2026/07/us-hits-network-of-iranian-financier-zanjani-with-more-sanctions/"},{"credibility":2,"name":"Treasury Expands Sanctions Against Babak Zanjani's Network — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/treasury-expands-sanctions-against-babak-zanjanis-network-targeting-the-commercial-ecosystem-behind-zedcex"},{"credibility":2,"name":"US Targets Iran's Financial Shadow Network With New Sanctions on Babak Zanjani — CEOWORLD","type":"news_article","url":"https://ceoworld.biz/2026/07/25/us-targets-irans-financial-shadow-network-with-new-sanctions-on-babak-zanjani/"}]}],"sources_used":[{"credibility":1,"name":"Treasury Further Dismantles Iranian Financier Zanjani's Network — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":1,"name":"Iran-related Designations — OFAC Recent Actions July 24, 2026","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20260724"},{"credibility":1,"name":"US Sanctions Family of Iranian Tycoon in Crackdown on Alleged IRGC Crypto Network — OCCRP","type":"news_article","url":"https://www.occrp.org/en/news/us-sanctions-family-of-iranian-tycoon-in-crackdown-on-alleged-irgc-crypto-network"},{"credibility":1,"name":"The Cat and the Stock-Footage CEO — OCCRP","type":"news_article","url":"https://www.occrp.org/en/investigation/the-cat-and-the-stock-footage-ceo-how-a-digital-trail-helped-unmask-an-iranian-money-machine"},{"credibility":2,"name":"OFAC sanctions exchanges Zedcex and Zedxion for assisting in Iranian sanctions evasion — Elliptic","type":"on_chain","url":"https://www.elliptic.co/blog/ofac-sanctions-exchanges-zedcex-and-zedxion-for-assisting-in-iranian-sanctions-evasion-and-irgc-operations"},{"credibility":2,"name":"How Two UK-registered Companies Moved Over a Billion in Stablecoins for the IRGC — TRM Labs","type":"on_chain","url":"https://www.trmlabs.com/resources/blog/how-two-uk-registered-companies-moved-over-a-billion-in-stablecoins-for-the-irgc"},{"credibility":2,"name":"Treasury Expands Sanctions Against Babak Zanjani's Network — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/treasury-expands-sanctions-against-babak-zanjanis-network-targeting-the-commercial-ecosystem-behind-zedcex"},{"credibility":2,"name":"OFAC Sanctions Zedcex and Zedxion in First-ever Designation of an IRGC-linked Digital Asset Exchange — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-zedcex-and-zedxion-in-first-ever-designation-of-an-irgc-linked-digital-asset-exchange"},{"credibility":2,"name":"OFAC Designates Iranian-Linked Crypto Exchanges — Chainalysis","type":"on_chain","url":"https://www.chainalysis.com/blog/ofac-designates-iranian-crypto-exchanges-january-2026/"},{"credibility":2,"name":"US Treasury sanctions four individuals, nine entities linked to Babak Zanjani's sanctions evasion network — Crypto Briefing","type":"news_article","url":"https://cryptobriefing.com/us-treasury-sanctions-zanjani-crypto-network/"},{"credibility":2,"name":"US Treasury Broadens Sanctions On Babak Zanjani Network — Crowdfund Insider","type":"news_article","url":"https://www.crowdfundinsider.com/2026/07/293941-us-treasury-broadens-sanctions-on-babak-zanjani-network-hitting-wider-commercial-support-structure-for-zedcex/"},{"credibility":2,"name":"Istanbul Fintech Firm Zedpay Blacklisted By US — Crowdfund Insider","type":"news_article","url":"https://www.crowdfundinsider.com/2026/07/293778-istanbul-fintech-firm-zedpay-blacklisted-by-us-over-links-to-iran-sanctions-evasion-network/"},{"credibility":2,"name":"US sanctions Turkish, UAE subsidiaries in Iran's Zanjani crypto network — Turkiye Today","type":"news_article","url":"https://www.turkiyetoday.com/business/us-sanctions-turkish-uae-subsidiaries-in-irans-zanjani-crypto-network-3224589"},{"credibility":2,"name":"US sanctions İstanbul fintech linked to Iranian sanctions evasion network — Turkish Minute","type":"news_article","url":"https://www.turkishminute.com/2026/07/25/us-sanctions-istanbul-fintech-linked-to-iranian-sanctions-evasion-network/"},{"credibility":2,"name":"Crypto exchanges sanctioned alongside Iranian officials — The Block","type":"news_article","url":"https://www.theblock.co/post/387935/crypto-exchanges-sanctioned-alongside-iranian-officials-in-trump-administrations-iran-crackdown"},{"credibility":2,"name":"NEWS: US hits network of Iranian financier Zanjani with more sanctions — AML Intelligence","type":"news_article","url":"https://www.amlintelligence.com/2026/07/us-hits-network-of-iranian-financier-zanjani-with-more-sanctions/"},{"credibility":2,"name":"Fake CEO and cat photos help uncover billion-dollar IRGC crypto network — Iran International","type":"news_article","url":"https://www.iranintl.com/en/202602279443"},{"credibility":2,"name":"Fake UK executive fronted $1b IRGC crypto scheme — Jerusalem Post","type":"news_article","url":"https://www.jpost.com/middle-east/iran-news/article-888675"},{"credibility":2,"name":"One Iranian Tycoon's Roller-Coaster — Kharon","type":"research","url":"https://www.kharon.com/brief/iran-news-babak-zanjani-us-uk-sanctions-dotone"},{"credibility":2,"name":"US Treasury adds ZEDX DMCC, ZedPay, BZ Diamond to Babak Zanjani sanctions list — Coin Turk","type":"news_article","url":"https://en.coin-turk.com/us-treasury-adds-zedx-dmcc-zedpay-bz-diamond-to-babak-zanjani-sanctions-list/"},{"credibility":2,"name":"Last Week's Major Developments in Sanctions — July 20 to July 24, 2026","type":"research","url":"https://www.sanctionsexpert.com/post/last-week-s-major-developments-in-sanctions-july-20-to-july-24-2026"},{"credibility":2,"name":"Treasury Further Dismantles Iranian Financier Zanjani's Network — Global Security","type":"news_article","url":"https://www.globalsecurity.org/wmd/library/news/iran/2026/07/iran-260724-treasury01.htm"},{"credibility":2,"name":"US Targets Iran's Financial Shadow Network With New Sanctions on Babak Zanjani — CEOWORLD","type":"news_article","url":"https://ceoworld.biz/2026/07/25/us-targets-irans-financial-shadow-network-with-new-sanctions-on-babak-zanjani/"}],"summary":"On July 24, 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) designated four individuals and nine entities comprising the commercial support structure behind Iranian financier Babak Zanjani's sanctions evasion network. The action extended a January 30, 2026 designation of Zanjani and his two UK-registered digital asset exchanges, Zedcex Exchange Limited and Zedxion Exchange Limited, which had processed over $94 billion in transactions since 2022 and transferred funds to IRGC-linked and Houthi-affiliated wallets. The July 2026 expansion targeted Istanbul- and Dubai-based fintechs, Iranian conglomerate subsidiaries, and family members of Zanjani who provided material, technological, and financial support to the exchanges.","timeline":[{"date":"2013-01-01","event":"Babak Zanjani arrested in Iran for allegedly withholding $2.7 billion owed to the Ministry of Petroleum from oil sanctions evasion activities.","source":"Wikipedia / News archives","source_url":"https://en.wikipedia.org/wiki/Babak_Zanjani"},{"date":"2016-03-06","event":"Iranian court sentences Zanjani to death for embezzlement and 'spreading corruption on earth' linked to funds taken from the National Iranian Oil Company.","source":"HuffPost / Reuters","source_url":"https://www.huffpost.com/entry/billionaire-sentenced-to-death_n_56dc7fc4e4b0000de404fab1"},{"date":"2022-01-01","event":"Zedcex Exchange Limited and Zedxion Exchange Limited registered in the United Kingdom; Babak Zanjani listed as controller under alias 'Babak Morteza' in UK filings.","source":"OCCRP investigation","source_url":"https://www.occrp.org/en/investigation/the-cat-and-the-stock-footage-ceo-how-a-digital-trail-helped-unmask-an-iranian-money-machine"},{"date":"2022-03-01","event":"Zedcex and Zedxion release marketing video featuring 'Elizabeth Newman' as executive director, a fabricated persona using stock footage of a model.","source":"OCCRP investigation","source_url":"https://www.occrp.org/en/investigation/the-cat-and-the-stock-footage-ceo-how-a-digital-trail-helped-unmask-an-iranian-money-machine"},{"date":"2022-05-24","event":"Zedpay Finansal Sistem Ve Hizmetleri Anonim Sirketi registered in Turkey as a computer programming business; later integrated as payment processor for Zedxion.","source":"Turkish Minute / US Treasury","source_url":"https://www.turkishminute.com/2026/07/25/us-sanctions-istanbul-fintech-linked-to-iranian-sanctions-evasion-network/"},{"date":"2022-08-01","event":"Babak Zanjani removed from Zedcex/Zedxion UK company records as listed controller, replaced by the fictitious 'Elizabeth Newman' persona.","source":"OCCRP investigation","source_url":"https://www.occrp.org/en/investigation/the-cat-and-the-stock-footage-ceo-how-a-digital-trail-helped-unmask-an-iranian-money-machine"},{"date":"2024-04-30","event":"Iran commutes Zanjani's death sentence to 20 years of imprisonment following the alleged repatriation of approximately $2.1 billion in assets.","source":"Kharon / News archives","source_url":"https://www.kharon.com/brief/iran-news-babak-zanjani-us-uk-sanctions-dotone"},{"date":"2025-04-01","event":"Dot One Rail Company announces $800 million contract with Islamic Republic of Iran Railways; Zanjani promotes the deal on social media.","source":"U.S. Treasury press release","source_url":"https://home.treasury.gov/news/press-releases/sb0576"},{"date":"2025-06-01","event":"Tether blacklists one of the TRON wallet addresses subsequently designated by OFAC in connection with Zedcex.","source":"Elliptic analysis","source_url":"https://www.elliptic.co/blog/ofac-sanctions-exchanges-zedcex-and-zedxion-for-assisting-in-iranian-sanctions-evasion-and-irgc-operations"},{"date":"2026-01-30","event":"OFAC designates Babak Zanjani, Zedcex Exchange Limited, and Zedxion Exchange Limited; seven TRON wallet addresses included. First-ever OFAC designation of IRGC-linked digital asset exchanges.","source":"U.S. Department of the Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0576"},{"date":"2026-02-27","event":"OCCRP publishes 'The Cat and the Stock-Footage CEO' investigation exposing the fake Elizabeth Newman CEO persona and Solmaz Bani's operational ties via shared social media content.","source":"OCCRP","source_url":"https://www.occrp.org/en/investigation/the-cat-and-the-stock-footage-ceo-how-a-digital-trail-helped-unmask-an-iranian-money-machine"},{"date":"2026-07-24","event":"OFAC designates four individuals (Mehdi Rezazadeh, Sukhrob Oimakhmadov, Bahareh Morteza Zanjani, Solmaz Bani) and nine entities including Dot One Value Creation Group, DotOne Gold Company, DotOne Rail Company, DotOne Barter Company, DotOne Airlines Company, DotOne Trip, Zedpay, Zedx DMCC, and BZ Diamond FZCO under Executive Order 13902.","source":"U.S. Department of the Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0576"}]},"v":1}

   Verify offline (run on your own machine)

   python -m src.verify_decision 9fd5b32d-a7ff-4a76-bcd7-e479c0dce2f3copy