OFAC designates four individuals and nine entities in expansion of Zanjani 'Dot One' network
On 24 July 2026 the US Treasury's Office of Foreign Assets Control designated four individuals and nine entities under Executive Order 13902, describing them as components of a sanctions-evasion network built around the Iranian financier Babak Zanjani. OFAC named the Iran-based "Dot One" conglomerate — its holding company Dot One Value Creation Group and subsidiaries DotOne Gold Company, DotOne Rail Company, DotOne Barter Company, DotOne Airlines Company and DotOne Trip — together with three offshore firms it said supported Zanjani's previously designated exchanges Zedcex and Zedxion: Istanbul-based Zedpay Finansal Sistem Ve Hizmetleri Anonim Sirketi, Dubai-based Zedx DMCC and Dubai-based BZ Diamond FZCO. The four individuals are Zedpay chairperson Mehdi Rezazadeh, Zedx manager Sukhrob Oimakhmadov, Zanjani's sister Bahareh Morteza Zanjani, and Solmaz Bani.
For this desk the payments layer is the point. OFAC stated that Zedpay was integrated directly into Zedxion's platform, giving the exchange the fiat settlement and cross-border payment capability it would otherwise have lacked; it described Zedx DMCC as acting on Zedcex's behalf over the exchange's wallets, and DotOne Gold Company as custodian for Tala Token, an allegedly gold-backed asset OFAC said moved through Zedcex infrastructure in early 2025. This is the connective tissue — settlement, custody, corporate vehicles — that lets an exchange named as IRGC-linked keep functioning after its front end is sanctioned. The action blocks all property and interests of the named persons under US jurisdiction and reaches any entity owned 50 percent or more by them.
Three things remain open, and they are the desk's read rather than the notice's. The widely repeated figure that Zedcex and Zedxion processed more than $94bn since 2022 does not appear in this release — it traces to reporting around the January designation, and at least one account puts the specifically IRGC-attributed sum far lower, so the 'much of it IRGC-linked' framing is not established by the primary document. The full SDN annex has not yet been cross-checked against the press release, and the registered names on the list may differ from the readable names used here. And whether mainstream-exchange exposure to these flows draws follow-on action is not yet clear — the question the desk will keep tracking.