Fact-check findings

The reviewer could not reconcile the claim with the evidence it cited. This is a lead, not a ruling that the claim is false.

1. #12[disputed][awaiting moderator]in the timeline

   “Zedcex Exchange Limited and Zedxion Exchange Limited registered in the United Kingdom; Babak Zanjani listed as controller under alias 'Babak Morteza' in UK filings.”

   reviewerZedcex Exchange Limited and Zedxion Exchange Limited were both registered in the United Kingdom in 2022, with Zanjani listed as controller under the alias 'Babak Morteza' from the outsetThe page's own cited source contradicts the date it assigns: Zedxion was incorporated in May 2021, not 2022. Zedcex's registration date of August 2022 (per Treasury) appears accurate, but the entry conflates the two companies under a single incorrect year.
   Proposed correction (not yet applied)

   Zedxion Exchange Limited was incorporated in the United Kingdom in May 2021 (founded by a Dutch national before Babak Zanjani, as 'Babak Morteza,' took over as director roughly five months later); Zedcex Exchange Limited was registered separately, reportedly in August 2022.
   citedwww.occrp.org/en/investigation/the-cat-a…an-money-machine
2. #22[disputed][awaiting moderator]in section: On-Chain Evidence and Blockchain Analytics

   “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.”

   reviewerElliptic confirmed on-chain transaction links between the newly designated July 2026 entities and January 2026 Zedcex/Zedxion wallet infrastructureThis sentence also contains the internal phrase 'the July 2026 action's queue context,' which reads as pipeline/production terminology rather than sourced reporting and should not appear in published copy. The substantive claim that Elliptic verified on-chain links for the July entities could not be confirmed and is contradicted by the absence of any such claim in the TRM Labs report that actually covers the July action.
   Proposed correction (not yet applied)

   No wallet addresses or transaction hashes for the newly designated July 2026 entities have been identified in publicly available sources at the time of this investigation, and no on-chain transaction links between those entities and the January 2026 Zedcex/Zedxion wallet infrastructure have been independently confirmed.
   citedwww.trmlabs.com/resources/blog/treasury-…em-behind-zedcex
3. #23[disputed][awaiting moderator]in section: On-Chain Evidence and Blockchain Analytics

   “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.”

   reviewerZanjani 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 rialThe $507 million USDT figure and the rial-support framing are accurately drawn from Elliptic, but the attribution of the leaked documents to Zanjani appears to be invented — Elliptic's report draws no connection between this story and Zanjani's network at all.
   Proposed correction (not yet applied)

   Elliptic separately reported that leaked documents, whose source Elliptic did not identify, described 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.
   citedwww.elliptic.co/blog/ofac-sanctions-exch…-irgc-operations
4. #24[disputed][awaiting moderator]in section: Regulatory and Legal Status

   “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.”

   reviewerAll designations in both the January 30, 2026 and July 24, 2026 OFAC actions were made under Executive Order 13902The July 2026 entity/individual designations do appear to rest solely on E.O. 13902, matching other sections of the page, but the January 2026 action also invoked E.O. 13224 for the IRGC-support basis of the exchange designations — a fact the page states elsewhere ('designated digital asset exchanges specifically linked to IRGC activities') but then contradicts with this blanket EO claim.
   Proposed correction (not yet applied)

   The July 24, 2026 designations 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; the January 30, 2026 action designated Zanjani, Zedcex, and Zedxion under E.O. 13902 as well, but additionally cited Executive Order 13224, as amended, in designating Zedcex and Zedxion for materially assisting the IRGC.
   citedhome.treasury.gov/news/press-releases/sb0576ofac.treasury.gov/recent-actions/20260724

No source the reviewer could reach confirms or contradicts the claim.

1. #16[unverifiable][awaiting moderator]in section: July 24, 2026 OFAC Expansion: Designated Individuals

   “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.”

   reviewerMehdi Rezazadeh served as chairperson of Zedpay and was designated for acting on its behalf; he previously appeared in records linked to UK corporate structures and international mining-investment forums involving Iran, Russia, China, and AfricaThe chairperson/designation basis is confirmed by Treasury directly. The specific claim about 'UK corporate structures and international mining-investment forums involving Iran, Russia, China, and Africa' could not be traced to any primary source; only thin, unnamed secondary reporting alludes to something similar.
   citedwww.turkishminute.com/2026/07/25/us-sanc…evasion-network/
2. #28[unverifiable][awaiting moderator]in section: Regulatory and Legal Status

   “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.”

   reviewerNo criminal indictments in U.S. courts have been identified in connection with the July 2026 expansionReasonable hedge given available reporting; cannot be verified as a negative with full confidence.

The claim was accurate when written but events since have overtaken it.

1. #25[stale][awaiting moderator]in section: Regulatory and Legal Status

   “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.”

   reviewerThe UK's Companies House registration status of Zedcex and Zedxion following the designations has not been confirmed in publicly available sources as of the date of this investigationPublic reporting on Zedxion's Companies House dissolution predates both the July 2026 designation and the archive timestamps used throughout this page's own source list, so the 'has not been confirmed' hedge is outdated rather than merely cautious.
   Proposed correction (not yet applied)

   UK Companies House moved to dissolve Zedxion Exchange Limited, citing misleading, false or fraudulent incorporation information, with press reports of the dissolution appearing by March 2026; Zedcex Exchange Limited's Companies House status following the designations has not been confirmed in publicly available sources as of the date of this investigation.
   citedhome.treasury.gov/news/press-releases/sb0576

A cited source no longer resolves or no longer says what the page attributes to it.

1. #26[link rot][awaiting moderator]in the cited sources

   “https://web.archive.org/web/20260729202820/https://www.turkiyetoday.com/business/us-fed-holds-rates-steady-says-inflation-remains-elevated-3224949”

   reviewerArchived snapshot of the Turkiye Today article on US sanctions on Turkish/UAE subsidiaries in Zanjani's networkThe primary url field is live and correct; only the archive_url is mismatched to an unrelated article, indicating an archiving/pairing error. Recommend removing the bad archive_url (or re-archiving the correct live URL) rather than leaving a snapshot that does not support the citation.
   citedwww.turkiyetoday.com/business/us-sanctio…-network-3224589

The cited evidence supports part of the claim but not all of it.

1. #6[partially supported][awaiting moderator]in section: January 2026 OFAC Designation: Zedcex and Zedxion

   “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.”

   reviewerSeven TRON wallet addresses attributed to Zedcex were included in the January 2026 designation, processing over $389 million combined, with one address receiving $149.3 millionThe dollar figures check out, but the page overstates attribution by assigning all seven addresses to Zedcex specifically when Elliptic's own reporting splits attribution between the two exchanges and only five of seven.
   citedwww.elliptic.co/blog/ofac-sanctions-exch…-irgc-operations
2. #13[partially supported][awaiting moderator]in section: January 2026 OFAC Designation: Zedcex and Zedxion

   “The exchanges allegedly processed over $94 billion in total transactions since 2022.”

   reviewerThe two exchanges had processed over $94 billion in transactions since 2022Moderate confidence: based on a single fetch of the Treasury release's summarized content rather than a direct quote extraction; the page's framing implies the figure covers both exchanges collectively, which appears to overstate what Treasury said.
   citedhome.treasury.gov/news/press-releases/sb0576
3. #14[partially supported][awaiting moderator]in the summary

   “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.”

   reviewerSame $94 billion figure, repeated in the page summary as applying to both UK-registered exchanges collectivelySame underlying attribution issue as the finding in sections[1]; grouped under the same defect.
   citedhome.treasury.gov/news/press-releases/sb0576
4. #18[partially supported][awaiting moderator]in section: July 24, 2026 OFAC Expansion: Designated Individuals

   “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.”

   reviewerBahareh Morteza Zanjani, Zanjani's sister and an Iranian national residing in the UAE, was designated for managing BZ Diamond FZCOZanjani's relationship to Bahareh Morteza Zanjani and her role managing the diamond company are confirmed. The company suffix (FZCO vs. DMCC) differs between Treasury's press release and OFAC's own recent-actions/SDN notice; the page follows the press release wording, which is defensible, but the inconsistency in official records should be flagged rather than silently resolved.
   citedhome.treasury.gov/news/press-releases/sb0576

The cited evidence supports the claim as written.

1. #1[confirmed][no action needed]in section: Background: Babak Zanjani and the Dot One Conglomerate

   “Babak Morteza Zanjani is an Iranian businessman with an estimated pre-arrest fortune of $14 billion.”

   reviewerZanjani had an estimated pre-arrest fortune of $14 billionWidely reported figure across independent outlets at the time of his arrest/trial; treated as an estimate, consistent with page's own hedged phrasing.
   citeden.wikipedia.org/wiki/Babak_Zanjani
2. #2[confirmed][no action needed]in section: Background: Babak Zanjani and the Dot One Conglomerate

   “In late 2013, Iranian authorities arrested him for allegedly withholding $2.7 billion owed to the Ministry of Petroleum.”

   reviewerZanjani arrested in late 2013 for withholding $2.7 billion owed to the Ministry of PetroleumMatches contemporaneous reporting on the arrest.
   citedwww.thequint.com/news/world/iran-billion…ver-embezzlement
3. #3[confirmed][no action needed]in section: Background: Babak Zanjani and the Dot One Conglomerate

   “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.”

   reviewerMarch 2016 Iranian court death sentence for embezzlement/'spreading corruption on earth' tied to NIOC funds, later confirmed by Supreme Court, commuted April 30, 2024 to 20 years after ~$2.1B asset repatriationCore facts (date, new sentence, repatriation rationale) confirmed by independent reporting; the exact dollar repatriation figure varies by outlet ($2.1B-$3.5B), but the page's figure is traceable to a credible AP-based account.
   citedwww.kharon.com/brief/iran-news-babak-zan…sanctions-dotonewww.thequint.com/news/world/iran-billion…ver-embezzlement
4. #4[confirmed][no action needed]in section: Background: Babak Zanjani and the Dot One Conglomerate

   “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.”

   reviewerIn April 2025, Dot One Rail Company announced an $800 million contract with the Islamic Republic of Iran RailwaysConfirmed by the primary OFAC/Treasury source.
   citedhome.treasury.gov/news/press-releases/sb0576
5. #5[confirmed][no action needed]in section: January 2026 OFAC Designation: Zedcex and Zedxion

   “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.”

   reviewerOn January 30, 2026, OFAC designated Zanjani alongside Zedcex and Zedxion, the first-ever OFAC designation of IRGC-linked digital asset exchangesDate, targets, and 'first-ever' framing all confirmed by the primary Treasury release and independent blockchain-intelligence reporting.
   citedwww.trmlabs.com/resources/blog/ofac-sanc…l-asset-exchangewww.theblock.co/post/387935/crypto-excha…s-iran-crackdown
6. #7[confirmed][no action needed]in section: January 2026 OFAC Designation: Zedcex and Zedxion

   “One address was previously blacklisted by Tether in June 2025.”

   reviewerOne of the seven TRON addresses was blacklisted by Tether in June 2025, prior to the OFAC designationMatches Elliptic's reporting.
   citedwww.elliptic.co/blog/ofac-sanctions-exch…-irgc-operations
7. #8[confirmed][no action needed]in section: January 2026 OFAC Designation: Zedcex and Zedxion

   “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.”

   reviewerTRM Labs documented ~$1 billion in IRGC-linked flows through Zedcex: ~$23.7M (2023), ~$619.1M (2024), ~$410.4M (2025), primarily USDT on TRONFigures confirmed against the TRM Labs source.
   citedwww.trmlabs.com/resources/blog/how-two-u…ins-for-the-irgc
8. #9[confirmed][no action needed]in section: January 2026 OFAC Designation: Zedcex and Zedxion

   “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.”

   reviewerOver $10 million in USDT moved directly from Zedcex/IRGC-attributed wallets to Sa'id Ahmad Muhammad al-Jamal, an OFAC-designated Houthi financier, with no mixer routingConfirmed, though TRM dates this specifically to late 2024, a detail the page omits without contradicting it.
   citedwww.trmlabs.com/resources/blog/how-two-u…ins-for-the-irgc
9. #10[confirmed][no action needed]in section: January 2026 OFAC Designation: Zedcex and Zedxion

   “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.”

   reviewerFunds from Zedcex reached Nobitex, Wallex, and Aban Tether; Zedxion operated a dollar-pegged stablecoin 'USDZ'; both exchanges used Singapore-based ChainUp for backend infrastructureCore claim confirmed; the ChainUp sentence is phrased more definitively than TRM's own hedged language, a minor overstatement not significant enough to separately dispute.
   citedwww.trmlabs.com/resources/blog/how-two-u…ins-for-the-irgc
10. #11[confirmed][no action needed]in section: January 2026 OFAC Designation: Zedcex and Zedxion

    “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.”

    reviewerOCCRP revealed Zedxion listed a fabricated CEO 'Elizabeth Newman' using Shutterstock stock footage titled 'Pretty black woman talking to camera'; Zanjani was previously listed as controller under the alias 'Babak Morteza' until August 2022Matches OCCRP's investigation closely.
    citedwww.occrp.org/en/investigation/the-cat-a…an-money-machine
11. #15[confirmed][no action needed]in section: July 24, 2026 OFAC Expansion: Designated Individuals

    “The July 24, 2026 OFAC action designated four individuals under Executive Order 13902 for acting on behalf of or materially assisting the Zanjani network.”

    reviewerThe July 24, 2026 OFAC action designated four individuals (Rezazadeh, Oimakhmadov, Bahareh Morteza Zanjani, Solmaz Bani) under Executive Order 13902Confirmed by the primary source.
    citedhome.treasury.gov/news/press-releases/sb0576
12. #17[confirmed][no action needed]in section: July 24, 2026 OFAC Expansion: Designated Individuals

    “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.”

    reviewerSukhrob Oimakhmadov was designated as manager of Zedx DMCC, the Dubai-registered entity acting on Zedcex's behalf regarding exchange walletsConfirmed by primary source.
    citedhome.treasury.gov/news/press-releases/sb0576
13. #19[confirmed][no action needed]in section: July 24, 2026 OFAC Expansion: Designated Individuals

    “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.”

    reviewerSolmaz Bani, described as Zanjani's significant other and a Dutch national based in Dubai, was designated for materially assisting the network; her connection was partly established via a purple-collared cat shared between her social media and Zedxion's TelegramBoth the nationality detail and the cat-photo evidence are independently corroborated.
    citedwww.occrp.org/en/news/us-sanctions-famil…c-crypto-network
14. #20[confirmed][no action needed]in section: July 24, 2026 OFAC Expansion: Designated Entities

    “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.”

    reviewerNine entities were designated July 24, 2026, including Dot One Value Creation Group, DotOne Gold/Rail/Barter/Airlines/Trip, Zedpay, Zedx DMCC, and BZ Diamond FZCO, all under Executive Order 13902Entity list and legal basis confirmed against the official OFAC action notice.
    citedhome.treasury.gov/news/press-releases/sb0576ofac.treasury.gov/recent-actions/20260724
15. #21[confirmed][no action needed]in section: July 24, 2026 OFAC Expansion: Designated Entities

    “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.”

    reviewerZedpay was registered on May 24, 2022, operating from Tekstilkent Plaza in Istanbul's Esenler districtBoth the date and address are confirmed.
    citedwww.turkishminute.com/2026/07/25/us-sanc…evasion-network/
16. #27[confirmed][no action needed]in section: Network Obfuscation and Corporate Deception

    “Zedcex and Zedxion filed representations of dormancy to UK Companies House authorities while allegedly processing hundreds of millions of dollars in active transactions.”

    reviewerNetwork obfuscation tactics: dormancy filings to Companies House, shared domains/emails/corporate rotation, Dot One's diversification used to obscure ownership and launder revenueConfirmed.
    citedwww.occrp.org/en/investigation/the-cat-a…an-money-machine