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. #16[disputed][awaiting moderator]in section: Broader Sanctions Enforcement Context

   “Earlier in 2026, OFAC sanctioned other Iranian exchanges under Operation Economic Outcast, including Nobitex, Wallex, Bitpin and Ramzinex (June 2026) and Shelbit and Aban Tether (August 2026).”

   reviewerOther exchanges were sanctioned under Operation Economic Outcast (Nobitex etc. June 2026; Shelbit/Aban Tether August 2026)The exchanges and months are roughly right, but both actions predate the August 24, 2026 launch of Operation Economic Outcast, which the page itself gives. 'Under Operation Economic Outcast' is therefore wrong. Exact Aban Tether/Shelbit date taken from a CoinDesk link, not fetched directly.
   Proposed correction (not yet applied)

   Earlier in 2026, OFAC sanctioned other Iranian exchanges, including Nobitex, Wallex, Bitpin and Ramzinex (June 2026) and Shelbit and Aban Tether (August 2026).
   citedwww.coindesk.com/policy/2026/08/25/u-s-w…g-and-technology

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

1. #13[unverifiable][awaiting moderator]in section: Controlling Figure: Babak Zanjani

   “One page reports that the U.S. Treasury first designated him in 2013, alleging his network moved billions of dollars for the Iranian government via entities in Malaysia, Turkey, Tajikistan and the UAE; another describes his January 30, 2026 designation as his first by OFAC (see contradiction notes).”

   reviewerUS Treasury first designated Zanjani in 2013 (Sorinet network); another page calls the Jan 2026 designation his firstProse is unresolved editorial text: it leaves a contradiction unresolved and refers to 'contradiction notes' that are not on the page. The Wikipedia source was not independently confirmed here. Recommend resolving against OFAC's historical records or removing the Jan 2026 'first' clause. The timeline 2013 entry repeats the same claim.
   citeden.wikipedia.org/wiki/Babak_Zanjani
2. #14[unverifiable][awaiting moderator]in the timeline

   “Iranian authorities arrested Zanjani on charges of embezzling approximately $2.7 billion from NIOC; the U.S. Treasury also reportedly first designated him that year (Sorinet network), per one page.”

   reviewerTimeline 2013: Zanjani arrested and Treasury reportedly designated him that yearWikipedia was not fetched in this review and no primary source was reached for 2013. 'per one page' is a hedge that does not name the page. Tertiary source for a sanctions claim.
   citeden.wikipedia.org/wiki/Babak_Zanjani
3. #19[unverifiable][awaiting moderator]in section: Compliance Risk for Global Exchanges and Users

   “According to multiple sources, the September 17 SDN entries did not include specific Bitcoin wallet addresses, unlike some earlier Iranian crypto sanctions.”

   reviewerSeptember 17 SDN entries did not include specific Bitcoin wallet addressesNeither fetched source says this; the OFAC recent-actions entry itself was not checked. 'Multiple sources' is unnamed.
   citedwww.crypto-news-flash.com/us-blacklists-…iance-takeaways/

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

1. #5[partially supported][awaiting moderator]in section: OFAC Designation and Legal Status

   “BitBank was reportedly launched in 2024.”

   reviewerBitBank was launched in 2024The claim is supported by CoinDesk (already a page source), but the timeline entry cites AML Intelligence, which does not say it. Hedged with 'reportedly'. Citation mismatch only.
   citedwww.amlintelligence.com/2026/09/news-us-…xchange-bitbank/
2. #6[partially supported][awaiting moderator]in the timeline

   “https://www.amlintelligence.com/2026/09/news-us-sanctions-iranian-financiers-crypto-exchange-bitbank/”

   reviewerTimeline: 2024 BitBank launch sourced to AML IntelligenceSource field should point to CoinDesk; the source name field (timeline[2].source) would also need updating.
   citedwww.amlintelligence.com/2026/09/news-us-…xchange-bitbank/
3. #7[partially supported][awaiting moderator]in section: Strait of Hormuz Toll Scheme

   “since June 2026 Iran has charged shipping vessels between $1 million and $2 million for passage through the Strait of Hormuz”

   reviewerHormuz Authority charged vessels $1-2 million, designated July 29, 2026Designation date confirmed. The toll amount rests on CoinDesk and is not in sb0581. The sentence presents it as 'According to OFAC' and 'Iran has charged', which is slightly stronger than CoinDesk's wording.
   citedhome.treasury.gov/news/press-releases/sb0581home.treasury.gov/news/press-releases/sb0632
4. #15[partially supported][awaiting moderator]in section: Controlling Figure: Babak Zanjani

   “His sentence was commuted to 20 years in prison in April 2024, reportedly following repatriation of about $2.1 billion in assets.”

   reviewerZanjani sentenced to death March 2016; commuted April 2024 to 20 years after repatriating about $2.1BYear of sentence and commutation confirmed by Treasury; the March 2016 month, April 2024 month and the $2.1B/$2.7B figures were not independently confirmed.
   citedwww.iranintl.com/en/202404308410

The cited evidence supports the claim as written.

1. #1[confirmed][no action needed]in section: OFAC Designation and Legal Status

   “On September 17, 2026, OFAC designated BitBank (also known as BitBank3, operating at bitbank3.com) under Executive Order 13902”

   reviewerOFAC designated BitBank on September 17, 2026 under E.O. 13902Treasury release confirms date and authority. The bitbank3.com domain was not checked in the fetched sources.
   citedhome.treasury.gov/news/press-releases/sb0632
2. #2[confirmed][no action needed]in section: Alleged Role in IRGC Financing

   “According to OFAC, between June and July 2026 Babak Zanjani allegedly used BitBank to transfer hundreds of millions of dollars in Bitcoin to the Islamic Revolutionary Guard Corps (IRGC)”

   reviewerBetween June and July 2026 Zanjani used BitBank to move hundreds of millions in Bitcoin to the IRGC; Hormuz Authority used BitBank since JuneMatches Treasury release; page properly attributes as allegation.
   citedhome.treasury.gov/news/press-releases/sb0632
3. #3[confirmed][no action needed]in section: Alleged Role in IRGC Financing

   “Treasury stated that since at least 2024 Zanjani had advertised BitBank's services on his social media accounts.”

   reviewerTreasury stated Zanjani advertised BitBank on social media since at least 2024Confirmed.
   citedhome.treasury.gov/news/press-releases/sb0632
4. #4[confirmed][no action needed]in section: Alleged Role in IRGC Financing

   “with IRGC-linked flows about 56% of observed volume and peaking at roughly 87% in 2024”

   reviewerTRM figures: about $1B IRGC-linked, 56% of volume, 87% in 2024Matches TRM and is attributed to TRM on the page.
   citedwww.trmlabs.com/resources/blog/ofac-sanc…al-asset-network
5. #8[confirmed][no action needed]in the timeline

   “OFAC designated the Hormuz Safe Marine Services Authority for an IRGC-backed Bitcoin-payment extortion scheme on Strait of Hormuz shipping.”

   reviewerHormuz Safe Marine Services Authority designated July 2026 (timeline)Date consistent.
   citedhome.treasury.gov/news/press-releases/sb0581
6. #9[confirmed][no action needed]in section: Designated Individuals

   “Seyed Adel Heidari is vice chairman of Dot One's board.”

   reviewerThree individuals designated alongside BitBank with stated rolesRoles of all three individuals match Treasury. The 'central to Zanjani's sanctions-evasion activity' quote was not seen in the fetched text; Treasury called Hossein Ali a 'key lieutenant'. Quote not individually verified.
   citedhome.treasury.gov/news/press-releases/sb0632
7. #10[confirmed][no action needed]in section: Controlling Figure: Babak Zanjani

   “(reported as four individuals and nine entities, including ZEDX DMCC, ZedPay and BZ Diamond)”

   reviewerJuly 24, 2026 designation: four individuals and nine entities including ZEDX DMCC, ZedPay, BZ DiamondConfirmed.
   citedhome.treasury.gov/news/press-releases/sb0576
8. #11[confirmed][no action needed]in section: Developer and Corporate Infrastructure

   “its subsidiary DotOne Rail Company reportedly secured an $800 million rail contract with Iran Railways in April 2025”

   reviewerDotOne Rail $800M contract with Iran Railways in April 2025Confirmed.
   citedhome.treasury.gov/news/press-releases/sb0576
9. #12[confirmed][no action needed]in section: Controlling Figure: Babak Zanjani

   “On January 30, 2026, OFAC designated him together with the UK-registered exchanges Zedcex and Zedxion, accusing him of money laundering for the IRGC”

   reviewerZanjani designated January 30, 2026 along with Zedcex and ZedxionDate and entities confirmed. Note sb0375 is cited in the timeline but not in sources_used.
   citedhome.treasury.gov/news/press-releases/sb0375
10. #17[confirmed][no action needed]in section: OFAC Designation and Legal Status

    “The action was announced as part of Operation Economic Outcast, a whole-of-government economic campaign against the Iranian regime launched by Treasury Secretary Bessent on August 24, 2026.”

    reviewerOperation Economic Outcast launched by Bessent on August 24, 2026; sectoral determination lets OFAC designate any operator in Iran's digital asset sectorConfirmed. The claim that the determination works 'without proof of a direct link to a previously named Iranian designee' is from CoinDesk and not checked.
    citedhome.treasury.gov/news/press-releases/sb0613
11. #18[confirmed][no action needed]in section: Developer and Corporate Infrastructure

    “BitBank's website listed Pishtaz Simorgh and Avan Exchange as exchange partners, per TRM Labs.”

    reviewerBitBank website lists Pishtaz Simorgh and Avan Exchange as exchange partners; DOTO integrationMatches TRM. The wording 'Pishtaz Simorgh Tejarat' vs 'Electronic Trade Company' differs slightly; the page mapping is presumably the same entity. Treasury sb0576 does not mention Pishtaz Simorgh, so the claim that Dot One is its parent rests on sb0632/TRM.
    citedwww.trmlabs.com/resources/blog/ofac-sanc…al-asset-network