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{"actor":"system:backfill","investigation_id":"d11d9b3b-4d64-4d8a-8133-7f0f7793fb1c","kind":"publish","page_slug":"bitbank-iranian-exchange","published_at":"2026-09-27T12:03:19.909Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"BitBank (Iranian Exchange)","sections":[{"content":"On September 17, 2026, OFAC designated BitBank (also known as BitBank3) under Executive Order 13902, which authorizes sanctions against Iran's digital asset sector. The designation was announced as part of Operation Economic Outcast, described by the Trump Administration as a 'whole-of-government economic campaign against the Islamic Republic of Iran and its enablers.' Concurrent designations were issued against BitBank's software developer Pishtaz Simorgh Electronic Trade Company, and three individuals: Mohammad Mahdi Zaker Hossein (CEO of Pishtaz Simorgh), Seyed Adel Heidari (vice chairman of Dot One Value Creation Group's board), and Hossein Ali Zaker Hossein (Dot One executive). U.S. persons are generally prohibited from transacting with any designated entity absent an OFAC license, and all U.S.-controlled property interests of designated parties are blocked.","heading":"OFAC Designation and Legal Status","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury Press Release: Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0632"},{"credibility":2,"name":"TRM Labs: OFAC Sanctions BitBank, Expanding Action Against Babak Zanjani's Digital Asset Network","type":"research","url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-bitbank-expanding-action-against-babak-zanjanis-digital-asset-network"},{"credibility":2,"name":"CoinDesk: Iran's Strait of Hormuz Toll Booth Ran Through a Bitcoin Exchange, U.S. Says","type":"news_article","url":"https://www.coindesk.com/policy/2026/09/18/iran-s-strait-of-hormuz-toll-booth-ran-through-a-bitcoin-exchange-u-s-says"}]},{"content":"According to Treasury's September 17, 2026 press release, Babak Zanjani allegedly used BitBank between June and July 2026 to transfer hundreds of millions of dollars worth of Bitcoin to the Islamic Revolutionary Guard Corps (IRGC). The IRGC is itself a U.S.-designated foreign terrorist organization. These are allegations made by OFAC in the context of a civil sanctions designation, not a criminal conviction; no court has adjudicated these claims. TRM Labs, in a supporting analysis, identified approximately $1 billion in IRGC-linked transaction activity across Zanjani's earlier exchange network (Zedcex and Zedxion) between 2023 and 2025, with IRGC-linked flows representing roughly 56% of observed volume and peaking at approximately 87% in 2024.","heading":"Alleged Role in IRGC Bitcoin Transfers","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury Press Release: Operation Economic Outcast","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0632"},{"credibility":2,"name":"TRM Labs: OFAC Sanctions BitBank, Expanding Action Against Babak Zanjani's Digital Asset Network","type":"research","url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-bitbank-expanding-action-against-babak-zanjanis-digital-asset-network"},{"credibility":2,"name":"Decrypt: Treasury Sanctions Crypto Exchange Behind Iran's Bitcoin Tolls on Hormuz Ships","type":"news_article","url":"https://decrypt.co/378604/treasury-sanctions-crypto-exchange-behind-irans-bitcoin-tolls-on-hormuz-ships"}]},{"content":"According to OFAC, since June 2026 Iran has charged shipping vessels between $1 million and $2 million for passage through the Strait of Hormuz, collected via the Iranian regime's Hormuz Safe Marine Services Authority. Treasury alleges that the Hormuz Safe Marine Services Authority used BitBank as a conduit to pass these Bitcoin toll payments on to the Iranian regime. The Hormuz Safe Marine Services Authority was itself separately designated by OFAC in July 2026. These allegations originate from U.S. government enforcement actions and have not been tested in court.","heading":"Strait of Hormuz Toll Scheme","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury Press Release: Operation Economic Outcast","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0632"},{"credibility":2,"name":"CoinDesk: Iran's Strait of Hormuz Toll Booth Ran Through a Bitcoin Exchange, U.S. Says","type":"news_article","url":"https://www.coindesk.com/policy/2026/09/18/iran-s-strait-of-hormuz-toll-booth-ran-through-a-bitcoin-exchange-u-s-says"},{"credibility":2,"name":"The National: US sanctions crypto exchange run by Iranian billionaire processing 'Tehran tollbooth' fees","type":"news_article","url":"https://www.thenationalnews.com/news/2026/09/24/us-sanctions-crypto-exchange-run-by-iranian-billionaire-processing-tehran-tollbooth-fees/"}]},{"content":"OFAC alleges BitBank is controlled by Babak Zanjani, an Iranian financier with a documented history of U.S. and international sanctions exposure. Zanjani founded the Sorinet Group of companies in the 2000s, which U.S. authorities later alleged was used to facilitate oil sales for the Iranian government in violation of sanctions. The U.S. Treasury first designated Zanjani in 2013, alleging his network moved billions of dollars for the Iranian government and routed money through entities in Malaysia, Turkey, Tajikistan, and the UAE. In 2013 Iranian authorities arrested Zanjani; in March 2016 an Iranian court sentenced him to death for embezzling approximately $2.7 billion from the National Iranian Oil Company. His sentence was commuted in 2024. By 2025 he had publicly re-emerged backing regime-linked ventures. OFAC re-designated Zanjani along with his exchanges Zedcex and Zedxion on January 30, 2026, followed by a broader network designation on July 24, 2026 targeting Dot One Value Creation Group and affiliated entities.","heading":"Controlling Party: Babak Zanjani","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury: Treasury Further Dismantles Iranian Financier Zanjani's Network (July 2026)","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":3,"name":"Wikipedia: Babak Zanjani","type":"other","url":"https://en.wikipedia.org/wiki/Babak_Zanjani"},{"credibility":2,"name":"Kharon: One Iranian Tycoon's Roller-Coaster: An Oil Empire, a Death Sentence, Freedom and Now Western Sanctions","type":"news_article","url":"https://www.kharon.com/brief/iran-news-babak-zanjani-us-uk-sanctions-dotone"},{"credibility":1,"name":"U.S. State Department: Sanctioning an Iranian Financial Evasion Network (July 2026)","type":"regulatory","url":"https://www.state.gov/releases/office-of-the-spokesperson/2026/07/sanctioning-an-iranian-financial-evasion-network"}]},{"content":"BitBank's software was developed by Pishtaz Simorgh Electronic Trade Company, itself a subsidiary of Dot One Value Creation Group, the conglomerate at the center of Zanjani's post-2024 business empire. According to TRM Labs analysis, BitBank integrates with a broader digital ecosystem including MyDot (a social platform), DOTO (a purpose-built digital asset), and the Dot One Smart Chain, an EVM-compatible blockchain with native DOTO token support, as well as wrapped DOTO, USDT, and ETH. The exchange is accessible at bitbank3.com. Zanjani's earlier exchanges Zedcex and Zedxion, both UK-registered, were sanctioned in January 2026 before BitBank emerged as an alleged replacement vehicle.","heading":"Technical Infrastructure and Broader Network","severity":"high","sources":[{"credibility":2,"name":"TRM Labs: OFAC Sanctions BitBank, Expanding Action Against Babak Zanjani's Digital Asset Network","type":"research","url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-bitbank-expanding-action-against-babak-zanjanis-digital-asset-network"},{"credibility":2,"name":"CryptoPotato: Iranian Crypto Exchange BitBank Lands on US Treasury's Sanctions List","type":"news_article","url":"https://cryptopotato.com/iranian-crypto-exchange-bitbank-lands-on-us-treasurys-sanctions-list/"}]},{"content":"BitBank's OFAC SDN designation means that any U.S. person or entity — including exchanges, custodians, on-ramps, and payment processors — that processes transactions with or for BitBank faces significant legal exposure under U.S. sanctions law. Secondary sanctions risk extends to non-U.S. persons who materially assist sanctioned parties. Any assets or property interests of BitBank, Pishtaz Simorgh Electronic Trade Company, or the designated individuals that come under U.S. jurisdiction must be blocked and reported to OFAC. The AML Intelligence and CryptoRank outlets have flagged the designation as a signal for compliance teams operating in digital asset markets.","heading":"Compliance Risk for Counterparties","severity":"critical","sources":[{"credibility":2,"name":"AML Intelligence: US sanctions BitBank, Iranian financier's crypto exchange","type":"news_article","url":"https://www.amlintelligence.com/2026/09/news-us-sanctions-iranian-financiers-crypto-exchange-bitbank/"},{"credibility":2,"name":"CryptoRank: Iranian Crypto Exchange BitBank Lands on US Treasury's Sanctions List","type":"news_article","url":"https://cryptorank.io/news/feed/66034-iranian-crypto-exchange-bitbank-lands-on-us-treasurys-sanctions-list"}]}],"sources_used":[{"credibility":1,"name":"U.S. Treasury: Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0632"},{"credibility":1,"name":"U.S. Treasury: Treasury Further Dismantles Iranian Financier Zanjani's Network","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0576"},{"credibility":1,"name":"U.S. State Department: Sanctioning an Iranian Financial Evasion Network","type":"regulatory","url":"https://www.state.gov/releases/office-of-the-spokesperson/2026/07/sanctioning-an-iranian-financial-evasion-network"},{"credibility":2,"name":"TRM Labs: OFAC Sanctions BitBank, Expanding Action Against Babak Zanjani's Digital Asset Network","type":"research","url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-bitbank-expanding-action-against-babak-zanjanis-digital-asset-network"},{"credibility":2,"name":"CoinDesk: Iran's Strait of Hormuz Toll Booth Ran Through a Bitcoin Exchange, U.S. Says","type":"news_article","url":"https://www.coindesk.com/policy/2026/09/18/iran-s-strait-of-hormuz-toll-booth-ran-through-a-bitcoin-exchange-u-s-says"},{"credibility":2,"name":"Decrypt: Treasury Sanctions Crypto Exchange Behind Iran's Bitcoin Tolls on Hormuz Ships","type":"news_article","url":"https://decrypt.co/378604/treasury-sanctions-crypto-exchange-behind-irans-bitcoin-tolls-on-hormuz-ships"},{"credibility":2,"name":"AML Intelligence: US sanctions BitBank, Iranian financier's crypto exchange","type":"news_article","url":"https://www.amlintelligence.com/2026/09/news-us-sanctions-iranian-financiers-crypto-exchange-bitbank/"},{"credibility":2,"name":"CryptoPotato: Iranian Crypto Exchange BitBank Lands on US Treasury's Sanctions List","type":"news_article","url":"https://cryptopotato.com/iranian-crypto-exchange-bitbank-lands-on-us-treasurys-sanctions-list/"},{"credibility":2,"name":"The National: US sanctions crypto exchange run by Iranian billionaire processing 'Tehran tollbooth' fees","type":"news_article","url":"https://www.thenationalnews.com/news/2026/09/24/us-sanctions-crypto-exchange-run-by-iranian-billionaire-processing-tehran-tollbooth-fees/"},{"credibility":2,"name":"Kharon: One Iranian Tycoon's Roller-Coaster: An Oil Empire, a Death Sentence, Freedom and Now Western Sanctions","type":"news_article","url":"https://www.kharon.com/brief/iran-news-babak-zanjani-us-uk-sanctions-dotone"},{"credibility":1,"name":"GlobalSecurity: Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime","type":"regulatory","url":"https://www.globalsecurity.org/wmd/library/news/iran/2026/09/iran-260917-treasury01.htm"},{"credibility":2,"name":"CryptoRank: Iranian Crypto Exchange BitBank Lands on US Treasury's Sanctions List","type":"news_article","url":"https://cryptorank.io/news/feed/66034-iranian-crypto-exchange-bitbank-lands-on-us-treasurys-sanctions-list"},{"credibility":3,"name":"Wikipedia: Babak Zanjani","type":"other","url":"https://en.wikipedia.org/wiki/Babak_Zanjani"}],"summary":"BitBank is an Iranian cryptocurrency exchange, also known as BitBank3, launched in 2024 and alleged by the U.S. Treasury to be controlled by sanctioned Iranian financier Babak Zanjani. On September 17, 2026, the U.S. Office of Foreign Assets Control (OFAC) designated BitBank as part of Operation Economic Outcast, alleging that between June and July 2026 the platform was used to transfer hundreds of millions of dollars in Bitcoin to the Islamic Revolutionary Guard Corps (IRGC) and to process Strait of Hormuz maritime toll payments collected by the Iranian regime.","timeline":[{"date":"2013-01-01","event":"U.S. Treasury first designates Babak Zanjani, alleging his Sorinet network moved billions of dollars for the Iranian government in violation of sanctions.","source":"U.S. Department of the Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0375"},{"date":"2013-12-01","event":"Iranian authorities arrest Zanjani on charges of embezzling approximately $2.7 billion from the National Iranian Oil Company.","source":"Wikipedia: Babak Zanjani","source_url":"https://en.wikipedia.org/wiki/Babak_Zanjani"},{"date":"2016-03-01","event":"Iranian court sentences Zanjani to death for embezzlement. The sentence is later commuted in 2024.","source":"Wikipedia: Babak Zanjani","source_url":"https://en.wikipedia.org/wiki/Babak_Zanjani"},{"date":"2024-01-01","event":"Zanjani's death sentence is commuted. He re-emerges publicly by 2025 as a backer of regime-linked economic projects, including digital asset ventures.","source":"TRM Labs","source_url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-bitbank-expanding-action-against-babak-zanjanis-digital-asset-network"},{"date":"2024-01-01","event":"BitBank is reportedly launched as an Iranian cryptocurrency exchange, accessible at bitbank3.com.","source":"AML Intelligence","source_url":"https://www.amlintelligence.com/2026/09/news-us-sanctions-iranian-financiers-crypto-exchange-bitbank/"},{"date":"2026-01-30","event":"OFAC re-designates Babak Zanjani and sanctions his two UK-registered exchanges Zedcex Exchange Limited and Zedxion Exchange Limited.","source":"TRM Labs","source_url":"https://www.trmlabs.com/resources/blog/ofac-sanctions-bitbank-expanding-action-against-babak-zanjanis-digital-asset-network"},{"date":"2026-06-01","event":"According to OFAC, the Hormuz Safe Marine Services Authority begins using BitBank to route Bitcoin toll payments (collected from ships at $1M-$2M per passage) to the Iranian regime.","source":"U.S. Department of the Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0632"},{"date":"2026-07-24","event":"OFAC designates four individuals and nine entities in Zanjani's broader network, including Dot One Value Creation Group, ZEDX DMCC, ZedPay, and BZ Diamond.","source":"U.S. Department of the Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0576"},{"date":"2026-08-24","event":"Treasury Secretary Scott Bessent announces Operation Economic Outcast as 'Economic D-Day,' targeting Iran's financial channels.","source":"OFAC / GlobalSecurity","source_url":"https://www.globalsecurity.org/wmd/library/news/iran/2026/09/iran-260917-treasury01.htm"},{"date":"2026-09-17","event":"OFAC designates BitBank, Pishtaz Simorgh Electronic Trade Company, and three individuals under Executive Order 13902, alleging BitBank transferred hundreds of millions of dollars in Bitcoin to the IRGC between June and July 2026.","source":"U.S. Department of the Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0632"}]},"v":1}