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{"actor":"system:backfill","investigation_id":"f773b798-c1e2-4616-8a76-3c4a30269449","kind":"publish","page_slug":"pishtaz-simorgh-electronic-trade-company","published_at":"2026-09-20T23:04:05.504Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"Pishtaz Simorgh Electronic Trade Company","sections":[{"content":"On September 17, 2026, OFAC designated Pishtaz Simorgh Electronic Trade Company under Executive Order 13902, which authorizes sanctions against persons operating in Iran's digital asset sector. The designation was announced as part of Operation Economic Outcast, the Trump Administration's whole-of-government campaign against Iranian financial networks, described by Treasury as targeting entities that enable Iran to move oil revenue and fund the IRGC. As a designated entity, all U.S.-held property interests of Pishtaz Simorgh are blocked, and U.S. persons are broadly prohibited from transacting with the company. The entity is also subject to secondary sanctions, meaning non-U.S. persons risk designation for engaging with it. OFAC records list the company's Iran National ID as 14012169913 and its registration number as 611800. The company's domain www.pishtazsimorgh.com was also identified in the official designation record.","heading":"OFAC Designation and Sanctions Status","severity":"critical","sources":[{"credibility":1,"name":"OFAC Iran-related Designations — September 17, 2026","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20260917"},{"credibility":1,"name":"Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime — U.S. Treasury Press Release","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0632"}]},{"content":"Pishtaz Simorgh Electronic Trade Company was established in 2024 and is registered at No. 2, 35th Street, Alvand Street, Argentina Square, Tehran, Iran — the same registered address as BitBank. OFAC designates the company as a subsidiary of Dot One Value Creation Group, itself the primary holding company of the Dot One conglomerate controlled by Iranian financier Babak Zanjani. Dot One Value Creation Group had been separately designated by OFAC on July 24, 2026, as part of a broader action targeting Zanjani's commercial ecosystem, which spans logistics, telecommunications, aviation, transportation, and digital assets. Mohammad Mahdi Zaker Hossein is identified by OFAC as the CEO of Pishtaz Simorgh and simultaneously holds a managerial role within Dot One Value Creation Group. He was also individually designated on September 17, 2026. The co-registration address with BitBank and the shared ownership chain through Dot One are cited by Treasury as indicators that the companies function as a coordinated operational unit rather than independent entities.","heading":"Corporate Structure and Ownership","severity":"critical","sources":[{"credibility":1,"name":"OFAC Iran-related Designations — September 17, 2026","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20260917"},{"credibility":1,"name":"Treasury Further Dismantles Iranian Financier Zanjani's Network — U.S. Treasury Press Release (July 24, 2026)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":2,"name":"OFAC Sanctions BitBank, Expanding Action Against Babak Zanjani's Digital Asset Network — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-bitbank-expanding-action-against-babak-zanjanis-digital-asset-network"}]},{"content":"OFAC identifies Pishtaz Simorgh as the developer of BitBank's digital asset software. BitBank (also operating under the name BitBank3, at domains www.bitbank3.com and www.bitbank.com) is described by Treasury as a priority digital asset venture controlled by Zanjani and promoted by him via social media since at least 2024. According to OFAC's findings, between June and July 2026, Zanjani allegedly used BitBank to transfer hundreds of millions of dollars' worth of Bitcoin to the IRGC. Treasury also states that Hormuz Safe Marine Services Authority — itself a previously sanctioned entity — used BitBank beginning in June 2026 to transfer payments to the Iranian regime. By developing and maintaining the technical platform through which these alleged transactions were routed, Pishtaz Simorgh is characterized by OFAC as part of the operational backbone of this alleged sanctions-evasion infrastructure. OFAC's action extends enforcement beyond the exchange itself to the entity that built the underlying software, reflecting a broader approach to targeting technical enablers of sanctions evasion. These are regulatory findings at the designation stage; no criminal conviction or court judgment against Pishtaz Simorgh has been publicly reported as of the date of this investigation.","heading":"Role in BitBank and Alleged IRGC Transfers","severity":"critical","sources":[{"credibility":1,"name":"Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime — U.S. Treasury Press Release","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0632"},{"credibility":2,"name":"US Sanctions Iranian Crypto Exchange and Its Software Developer Over Alleged IRGC Bitcoin Transfers — CryptoSlate","type":"news_article","url":"https://cryptoslate.com/us-sanctions-iranian-crypto-exchange-and-its-software-developer-over-alleged-irgc-bitcoin-transfers/"},{"credibility":2,"name":"Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime — GlobalSecurity.org","type":"news_article","url":"https://www.globalsecurity.org/wmd/library/news/iran/2026/09/iran-260917-treasury01.htm"}]},{"content":"Three individuals connected to the Zanjani network were designated alongside Pishtaz Simorgh on September 17, 2026. Mohammad Mahdi Zaker Hossein is identified as Pishtaz Simorgh's CEO and a manager within Dot One Value Creation Group. Hossein Ali Zaker Hossein is described by OFAC as having participated in much of Zanjani's alleged sanctions-evasion activity, including brokering digital asset transactions that allegedly reached the IRGC, as well as involvement in oil export operations. Seyed Adel Heidari holds the position of Vice Chairman of Dot One's board of directors. The two Zaker Hossein individuals share a surname, though their precise familial relationship is not specified in available OFAC records. All three were designated under the same Executive Order 13902 authority as Pishtaz Simorgh.","heading":"Associated Individuals Designated","severity":"high","sources":[{"credibility":1,"name":"OFAC Iran-related Designations — September 17, 2026","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20260917"},{"credibility":1,"name":"Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime — U.S. Treasury Press Release","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0632"}]},{"content":"Pishtaz Simorgh's designation is the fourth major OFAC action targeting the Zanjani network since January 2026. On January 30, 2026, OFAC designated Babak Zanjani personally along with exchanges Zedcex and Zedxion — the first-ever U.S. sanctions against digital asset exchanges specifically linked to the IRGC; those two platforms reportedly processed over $94 billion in transactions since 2022. On July 24, 2026, Treasury expanded its action by designating Dot One Value Creation Group and eight associated entities spanning gold, rail, aviation, barter, ride-sharing, and financial technology, as well as four individuals including Zanjani's sister and his significant other. The September 17, 2026 action added BitBank, Pishtaz Simorgh, and three executives, and simultaneously deployed a sectoral determination under Executive Order 13902 that enables Treasury to sanction any person operating in or supporting Iran's digital asset sector without requiring a separate terrorism nexus finding. Treasury also coordinated the September 17 action with the U.S. Department of State, which issued a parallel statement through its Office of the Spokesman. Zanjani himself was sentenced to death in Iran in 2016 for embezzling from the state-owned National Iranian Oil Company; that sentence was reportedly commuted in 2024, after which he re-emerged as a prominent backer of regime-linked commercial ventures.","heading":"Broader Zanjani Network Context","severity":"high","sources":[{"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":1,"name":"Treasury Further Dismantles Iranian Financier Zanjani's Network — U.S. Treasury Press Release (July 24, 2026)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":1,"name":"Operation Economic Outcast Dismantles Iran's Sanctions Evasion Network — U.S. Department of State","type":"regulatory","url":"https://www.state.gov/releases/office-of-the-spokesman/2026/09/operation-economic-outcast-dismantles-irans-sanctions-evasion-network"},{"credibility":2,"name":"Babak Zanjani — Wikipedia","type":"other","url":"https://en.wikipedia.org/wiki/Babak_Zanjani"},{"credibility":2,"name":"OFAC Designates Iranian-Linked Crypto Exchanges — Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/ofac-designates-iranian-crypto-exchanges-january-2026/"}]},{"content":"Any financial institution, exchange, or service provider that has processed transactions involving Pishtaz Simorgh, BitBank, Dot One Value Creation Group, or associated addresses faces exposure under U.S. sanctions law. The September 17, 2026 sectoral determination under Executive Order 13902 significantly expands this risk: it allows OFAC to designate parties operating in Iran's digital asset sector broadly, without requiring a specific terrorism or IRGC link to be demonstrated for each target. Secondary sanctions risk extends to non-U.S. persons. Cryptocurrency platforms, liquidity providers, and over-the-counter desks that have had exposure to BitBank's on-chain addresses should conduct sanctions screening against OFAC's SDN list and consult current OFAC guidance. As of the date of this investigation, no on-chain address cluster for Pishtaz Simorgh itself has been publicly published by OFAC, though BitBank's associated addresses may be disclosed in separate SDN list entries.","heading":"Compliance and Counterparty Risk","severity":"high","sources":[{"credibility":1,"name":"Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime — U.S. Treasury Press Release","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0632"},{"credibility":2,"name":"OFAC Sanctions BitBank, Expanding Action Against Babak Zanjani's Digital Asset Network — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-bitbank-expanding-action-against-babak-zanjanis-digital-asset-network"},{"credibility":2,"name":"BitBank Faces U.S. Sanctions Over Alleged IRGC Bitcoin Transfers — Crypto.news","type":"news_article","url":"https://crypto.news/bitbank-faces-u-s-sanctions/"}]}],"sources_used":[{"credibility":1,"name":"OFAC Iran-related Designations — September 17, 2026","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20260917"},{"credibility":1,"name":"Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime — U.S. Treasury Press Release","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0632"},{"credibility":1,"name":"Treasury Further Dismantles Iranian Financier Zanjani's Network — U.S. Treasury Press Release (July 24, 2026)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":1,"name":"Treasury Launches Unprecedented Campaign Against Iranian Regime on Economic D-Day — U.S. Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0613"},{"credibility":1,"name":"Operation Economic Outcast Dismantles Iran's Sanctions Evasion Network — U.S. Department of State","type":"regulatory","url":"https://www.state.gov/releases/office-of-the-spokesman/2026/09/operation-economic-outcast-dismantles-irans-sanctions-evasion-network"},{"credibility":2,"name":"OFAC Sanctions BitBank, Expanding Action Against Babak Zanjani's Digital Asset Network — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-bitbank-expanding-action-against-babak-zanjanis-digital-asset-network"},{"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":"research","url":"https://www.chainalysis.com/blog/ofac-designates-iranian-crypto-exchanges-january-2026/"},{"credibility":2,"name":"US Sanctions Iranian Crypto Exchange and Its Software Developer Over Alleged IRGC Bitcoin Transfers — CryptoSlate","type":"news_article","url":"https://cryptoslate.com/us-sanctions-iranian-crypto-exchange-and-its-software-developer-over-alleged-irgc-bitcoin-transfers/"},{"credibility":2,"name":"Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime — GlobalSecurity.org","type":"news_article","url":"https://www.globalsecurity.org/wmd/library/news/iran/2026/09/iran-260917-treasury01.htm"},{"credibility":2,"name":"BitBank Faces U.S. Sanctions Over Alleged IRGC Bitcoin Transfers — Crypto.news","type":"news_article","url":"https://crypto.news/bitbank-faces-u-s-sanctions/"},{"credibility":2,"name":"Treasury Sanctions Iranian Crypto Exchange BitBank Over IRGC Ties — Hoodline","type":"news_article","url":"https://hoodline.com/2026/09/treasury-sanctions-iran-s-bitbank-crypto-exchange-tied-to-zanjani-irgc-cash/"},{"credibility":2,"name":"Babak Zanjani — Wikipedia","type":"other","url":"https://en.wikipedia.org/wiki/Babak_Zanjani"},{"credibility":2,"name":"DOT ONE VALUE CREATION GROUP — OpenSanctions","type":"regulatory","url":"https://www.opensanctions.org/entities/NK-VTqp8GmUnCUvbM7kNGXMPu/"}],"summary":"Pishtaz Simorgh Electronic Trade Company is a Tehran-based software firm established in 2024 and designated by the U.S. Treasury's Office of Foreign Assets Control (OFAC) on September 17, 2026. The company developed the digital asset exchange platform BitBank, operated as a subsidiary of the previously sanctioned Dot One Value Creation Group, and is connected to sanctioned Iranian financier Babak Zanjani's alleged Iran Revolutionary Guard Corps (IRGC) sanctions-evasion network. All U.S.-held property interests are blocked and the entity is subject to secondary sanctions.","timeline":[{"date":"2016-01-01","event":"Babak Zanjani sentenced to death in Iran for embezzling funds from the National Iranian Oil Company.","source":"Wikipedia — Babak Zanjani","source_url":"https://en.wikipedia.org/wiki/Babak_Zanjani"},{"date":"2024-01-01","event":"Zanjani's death sentence commuted; he re-emerges and is appointed CEO of Dot One Value Creation Group.","source":"U.S. Treasury Press Release — Operation Economic Outcast (sb0632)","source_url":"https://home.treasury.gov/news/press-releases/sb0632"},{"date":"2024-01-01","event":"Pishtaz Simorgh Electronic Trade Company established in Tehran; BitBank platform development begins.","source":"OFAC SDN Designation Record — September 17, 2026","source_url":"https://ofac.treasury.gov/recent-actions/20260917"},{"date":"2026-01-30","event":"OFAC designates Babak Zanjani, Zedcex, and Zedxion — the first U.S. sanctions action against an IRGC-linked digital asset exchange.","source":"OFAC Sanctions Zedcex and Zedxion — TRM Labs","source_url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-zedcex-and-zedxion-in-first-ever-designation-of-an-irgc-linked-digital-asset-exchange"},{"date":"2026-06-01","event":"According to OFAC, Zanjani begins using BitBank to transfer Bitcoin to the IRGC; Hormuz Safe Marine Services Authority also begins using BitBank to route payments to the Iranian regime.","source":"U.S. Treasury Press Release — Operation Economic Outcast (sb0632)","source_url":"https://home.treasury.gov/news/press-releases/sb0632"},{"date":"2026-07-24","event":"OFAC designates Dot One Value Creation Group and eight associated Dot One entities, along with four individuals, in a second major action against the Zanjani network.","source":"Treasury Further Dismantles Iranian Financier Zanjani's Network — U.S. Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0576"},{"date":"2026-08-24","event":"Operation Economic Outcast formally launched by Treasury, described as a whole-of-government campaign to sever Iran's remaining economic lifelines.","source":"Treasury Launches Unprecedented Campaign Against Iranian Regime on Economic D-Day — U.S. Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0613"},{"date":"2026-09-17","event":"OFAC designates Pishtaz Simorgh Electronic Trade Company, BitBank, and three individuals (Mohammad Mahdi Zaker Hossein, Hossein Ali Zaker Hossein, Seyed Adel Heidari) under Executive Order 13902. Treasury simultaneously issues a sectoral determination covering Iran's digital asset sector.","source":"OFAC Iran-related Designations — September 17, 2026","source_url":"https://ofac.treasury.gov/recent-actions/20260917"}]},"v":1}