The US Department of the Treasury said on July 24 that its Office of Foreign Assets Control (OFAC) has designated four more individuals and nine entities in countries including Turkey and the UAE for forming key components of the wider Iranian sanctions evasion network of Iranian billionaire business magnate Babak Zanjani.

“The Iranian regime continues to pay a steep economic price for its reckless behavior, with the rial plunging to another record low and inflation up massively,” US Secretary of the Treasury Scott Bessent said in a comment on the development.

The designation targets Zanjani’s Iran-based operations under the “Dot One” conglomerate and a series of companies outside Iran that have supported his flagship OFAC-designated digital asset exchanges Zedcex Exchange Limited (Zedcex) and Zedxion Exchange Limited (Zedxion) as well as their managers and executives.

Re-emerged in 2025

Zanjani has leveraged a diverse portfolio, including financial services, gold and precious gem production, along with digital asset trading, major transportation and infrastructure projects. The range and diversity of the portfolio has enabled him to obscure ownership, launder revenue and expand his capacity to move funds covertly through Iran and offshore.

Zanjani was sentenced to death in Iran in 2016 for embezzling millions from the OFAC-designated National Iranian Oil Company (NIOC), but his sentence was commuted in 2024. 

By 2025, he had publicly re-emerged as a backer of regime-linked economic projects.  Alongside high‑profile infrastructure and transportation ventures, Zanjani built a network of digital asset companies, including Zedcex and Zedxion, used in part to launder money for the OFAC-designated Islamic Revolutionary Guard Corps (IRGC).

Through combined infrastructure, Zanjani’s enterprises have served as both public‑facing commercial ventures and covert financial platforms enabling sanctions evasion and support for Iranian state‑linked entities.

In January, OFAC designated Zanjani and his two largest UK-based digital asset exchanges, namely Zedcex and Zedxion. Multiple Zedcex and Zedxion-attributed addresses have processed funds on behalf of “wallets” attributed to the IRGC, the most powerful branch of the Iranian Armed Forces and also a business and industrial empire.

Zarrab’s partner in Halkbank case

Turks remember Zanjani as Reza Zarrab’s partner in the Halkbank (HALKB) Iran sanctions-busting case. After Zarrab became a US asset, Iran’s mullahs rushed to jail Zanjani. He was sentenced to death before cameras in melodramatic scenes.

On July 14, Zarrab received a “time served” sentence, meaning he faces no additional incarceration. It was handed down by New York judge Richard Berman after prosecutors credited Zarrab with providing essential help in the Halkbank case.

Diverse Dot One

Following the commutation of his death sentence, Zanjani returned to the Iranian public eye with the establishment of his multiple Iran-based “Dot One” projects, set up across diverse industries.

Over the past two years, Zanjani has served as both a public-facing chief executive and a covert financial backer for the companies. He has frequently used his social media profiles to promote and celebrate Dot One ventures, including the April 2025-dated $800mn rail contract Dot One Rail Company secured with Islamic Republic of Iran Railways.

As both Iranian and international press increasingly scrutinised Zanjani’s role within the Dot One conglomerate, the companies obfuscated their ties with him. 

Located in Dot One Tower in Tehran, Dot One Value Creation Group (Dot One Value) is the primary holding company for the Dot One conglomerate.  Dot One Value purports to be involved in services including logistics, telecommunications, aviation, transportation and digital assets.

Zanjani was appointed CEO at this company as early as 2024 and retains control over Dot One Value.

Gold bar minter, custodian

DotOne Gold Company is Zanjani’s gold bar minter, producer and custodian company. It is integral to the operations of Tala Token, a digital asset token that is allegedly gold-backed. Significant quantities of Tala Token passed through Zedcex infrastructure in early 2025.

OFAC has designated DotOne Value and DotOne Gold Company pursuant for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Zanjani.

The Dot One conglomerate’s railway construction, clearing house service, airline service and ride-sharing service operations are handled by DotOne Rail Company, DotOne Barter Company, DotOne Airlines Company and DotOne Trip, respectively. OFAC has also designated each of these companies.

Zedpay, Istanbul and Zedx, Dubai

Zedcex and Zedxion, now designated by OFAC, have relied on companies based in Turkey and the UAE for material, technological and financial support.

Istanbul-based Zedpay is a financial technology company that provides digital wallet and global transfer services. It has been directly integrated into Zedxion’s platform, allowing users to utilise their Zedpay digital wallets while trading on Zedxion and providing Zedxion with fiat settlement and cross-border payment capabilities to which it would otherwise not have access. 

Dubai-based Zedx is, meanwhile, an entity that has acted on Zedcex’s behalf, including in regard to Zedcex’s exchange wallets. Additionally, OFAC is designating Sukhrob Oimakhmadov, the manager of Zedx.

Dubai-based BZ Diamond is a dealer of lab-grown and natural diamonds managed by Zanjani’s sister, Bahareh Morteza Zanjani. BZ Diamond has supported Zedxion digital asset projects by promoting Zedxion’s NFT marketplace, offering a BZ Diamond token on the Zedxion blockchain and conducting multiple transactions with Zedxion and Zedcex wallets, including in sending assets to Zedxion.

OFAC is also designating Bahareh together with Solmaz Bani, who has registered websites for Zanjani’s companies.

All property and interests in property of the designated persons described above that are in the US or in the possession or control of US persons are blocked and must be reported to OFAC.

Any entities that are owned, directly or indirectly, individually or in the aggregate, to 50% or more by one or more blocked persons, are also blocked. Unless there is authorisation from a general or specific license issued by OFAC, or an exemption, OFAC’s regulations generally prohibit all transactions by US persons or within (or transiting) the US that involve any property or interests in property of the designated or otherwise blocked persons.